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
Samir D. Varma
Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.
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…
Reversing the Biden Administration, State Department Recreates the Cuba Restricted List
On February 6, 2025, the State Department republished the “Cuba Restricted List” identifying entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel. The Cuba Restricted List is significant because direct financial transactions with the enumerated entities and subentities are…
President Trump Announces “Fair and Reciprocal Plan” to Address U.S. Trade Relationships and to Counter Non-Reciprocal Trade with Other Countries
In a February 13, 2025 Memorandum, President Donald Trump instructed the Secretary of Commerce and the U.S. Trade Representative, with input from other agencies, to initiate “all necessary actions to investigate the harm to the United States from any non-reciprocal trade arrangements adopted by any trading partners.” Upon completion of this investigation, the president…
President Trump Announces New Tariffs on Imported Steel and Aluminum Articles and Derivatives from All Countries with No Exemptions or Exclusions
UPDATE: On February 14, the Federal Register released the formal Presidential Proclamations on the steel and aluminum tariffs that include the annexes for each Proclamation that detail the list of in-scope steel or aluminum articles and derivatives that will be subject to the 25% ad valorem tariffs. The links in this post have been updated…
President Trump Issues Executive Order on Countering Iran’s Malign Influence
On February 4, 2025, President Donald Trump issued an Executive Order (EO) stating that Iran’s malign behavior and influence threaten the national interest of the United States and that it is “in the national interest to impose maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop…
President Trump Initiates Tariffs on Canada, Mexico and China Under the IEEPA – Tariffs on Mexico and Canada Suspended until March 4 but Tariffs on China Start February 4
UPDATE: On February 7, President Donald Trump issued an executive order (EO) addressing the additional duties placed on imports into the United States of products of China. The article below stated that use of duty-free de minimis treatment on imports for shipments under $800 was being removed for shipments from China. The president has since…
President Trump Announces “America First Trade Policy”
- Directing the Secretary of Commerce, Secretary of the Treasury and the U.S. Trade Representative to “investigate the causes of our country’s large and persistent
Department of Commerce Adjusts Levels of Civil Monetary Penalties for 2025
On January 15, 2025, the Department of Commerce’s inflation-adjusted civil monetary penalties for 2025 went into effect. The adjustments, which the Department of Commerce (“Commerce”) published in the Federal Register on December 30, 2024, update the penalty rates for violations of laws and regulations enforced by the agency and its bureaus.
While over 40 civil…
