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
BIS Publishes Final Rule Prohibiting the Sale and Importation of Connected Vehicles with Sufficient Nexus to China and Russia
On January 16, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule prohibiting the sale and importation of connected vehicles incorporating certain hardware and software components (or those components sold separately) with a sufficient nexus to the People’s Republic of China (PRC) or Russia. The new prohibitions go into
DDTC Issues Interim Final Rule to Amend Provisions of the ITAR and USML Categories
On January 17, 2025, the Department of State’s Directorate of Defense Trade Controls (DDTC) published an Interim Final Rule that will amend §§ 121.0 and 121.1 of the International Traffic in Arms Regulations (ITAR) by revising certain U.S. Munitions List (USML) definitions, adding new definitions, and updating certain parts of the USML under categories II
CBP Publishes Proposed Rule to Limit Duty Exemption for Certain Low-Value Shipments
On January 17, 2025, Customs and Border Protection (CBP) announced a Notice of Proposed Rulemaking (NPRM) intended to tighten the de minimis duty exemption for certain low-value shipments entering the United States. Under the proposed rule, merchandise subject to specific trade and national security actions would no longer qualify for the de minimis exemption and