On March 25, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) added over 80 companies to its Entity List through two Final Rules. These are the first listings by BIS under President Donald Trump’s second term and the listings heavily focus on China. According to BIS, these entities “have been determined by

Samir D. Varma
Trump Signs EO Imposing an Additional 25% Tariff on Countries That Buy Venezuelan Oil
On March 24, 2025, President Donald Trump signed an Executive Order (EO) declaring that any country purchasing oil from Venezuela, “whether directly from Venezuela or indirectly through third parties,” will pay a 25% tariff on their exports to the United States. The EO tasks the Secretary of Commerce with determining whether a country buys Venezuelan…
BIS Seeks Public Comments on Section 232 Investigations of Imports of Copper and Lumber
The Department of Commerce’s Bureau of Industry and Security (BIS) has issued Federal Register notices announcing that interested parties may submit written comments, data or other information pertinent to these investigations. Comments are due no later than April 1, 2025.
Section 232 National Security Investigation of Imports of Copper
This investigation was initiated on February…
OFAC Once Again Extends Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On March 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5R, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 3, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
Reversing the Biden Administration, OFAC Announces the Wind Down of Venezuela General License 41
On March 4, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 41A within its Venezuela-Related Sanctions Program: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela.” The Biden Administration had issued the precursor to General License (GL) 41A, GL 41…
USTR Proposes Actions Against China’s Unfair Trade Practices in Maritime, Logistics & Shipbuilding Sectors
Key Notes:
Trump Administration Initiates Section 232 Investigation into Imports of Timber and Lumber that May Lead to New Tariffs
On March 1, 2025, President Donald Trump signed an Executive Order (EO) initiating an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on national security of imports of timber, lumber and their derivative products (including paper products, furniture and cabinetry) dumped into the U.S. market. The EO states…
USTR Announces Proposed Actions in Response to China’s Targeting of Maritime and Shipbuilding Sectors; Seeks Public Comment
On February 21, 2025, the Office of the U.S. Trade Representative (USTR) announced its proposed actions in response to an earlier determination finding that China was targeting the maritime, logistics, and shipbuilding sectors for dominance. This determination followed an investigation under Section 301 of the Trade Act of 1974. This determination authorizes actions in response. USTR has proposed…
President Trump Issues America First Investment Policy Memorandum Impacting FDI into the U.S. and Outbound Investment to Foreign Adversaries
On February 21, 2025, President Trump issued the America First Investment Policy Memorandum (“Memorandum”). The Memorandum aims to promote foreign direct investment (FDI) from “allies and partners” while restricting inbound investment from and outbound investment to “foreign adversaries,” such as China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and the Nicolás Maduro…
USTR Seeks Public Comment on Unfair and Non-Reciprocal Foreign Trade Practices
On February 20, 2025, the Office of the United States Trade Representative (USTR) announced that it is seeking comments from the public to identify and address unfair and non-reciprocal foreign trade practices. This initiative is part of the broader America First Trade Policy Presidential Memorandum and the Reciprocal Trade and Tariffs Presidential Memorandum.
The…