On September 2, 2025, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of robotics and industrial machinery. According to the notice, the term “robotics and industrial machinery” for this investigation includes, among other things
OFAC Amends Remaining Syria-Related Sanctions Regulations
The Office of Foreign Assets Control (OFAC) issued a Final Rule effective September 25, 2025 amending the Syria-Related Sanctions Regulations at 31 C.F.R. Part 569. The heading of these regulations is being changed to the “Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations.” These amended regulations further implement Syria-related Executive Order 14312 (June 30, 2025).
USTR Initiates Public Consultation Process for USMCA Joint Review
Update: On November 7, 2025, the Office of the U.S. Trade Representative issued a notice rescheduling the public hearing on the operation of the Agreement between the United States of America, the United Mexican States, and Canada (USMCA). Originally scheduled for November 17, the hearing will now take place from December 3 to 5
USTR Seeks Comment on Possible Extension of Remaining China Section 301 Product Exclusions
On September 16, 2025, the Office of the U.S. Trade Representative (USTR) issued a notice and request for public comments on the possible extension of the remaining 178 product exclusions in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The USTR has extended these exclusions
Annual Blocked Property Reports Due to OFAC by September 30
All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2025. This does applies to all relevant persons, not only financial institutions.
This report is pursuant to 31 C.F.R.
Trump Administration Announces Changes to Japan Tariffs
On September 16, 2025, the Department of Commerce’s International Trade Administration (ITA) released a Federal Register notice announcing changes to the Harmonized Tariff Schedule of the United States (HTSUS) as to general tariffs on imports of Japanese goods in order to implement the United States-Japan Agreement (see Executive Order 14345). Under the original framework
U.S. Supreme Court to Review the Legality of Trump Administration’s IEEPA-Based Tariffs
On September 9, 2025, the U.S. Supreme Court agreed to review a consolidation of two cases challenging the legality of tariffs imposed by President Donald Trump under the International Emergency Economic Powers Act (IEEPA). It has scheduled oral arguments for the first week of November, an unusually swift timeline for the Court.
The first case
DOJ and DHS Launch Joint Trade Fraud Task Force: What Multinational Companies Need to Know
On August 29, 2025, the U.S. Department of Justice (DOJ) announced a new Trade Fraud Task Force, an interagency initiative aimed at “robust enforcement” against importers and other parties who defraud the United States by evading tariffs or importing prohibited goods. The task force will coordinate closely with DHS agencies, including U.S. Customs and Border
Department of Commerce Relaxes Export Controls for Syria
On September 2, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule in the Federal Register easing licensing requirements for civilian exports to Syria. The rule implements the policy on Syria established in Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (June 30, 2025) that called for
Federal Circuit Rules that Trafficking and Reciprocal Tariffs Violate IEEPA
On August 29, 2025, the U.S. Court of Appeals for the Federal Circuit (“the Court” or “Federal Circuit”) in a 7-4 ruling determined that President Donald Trump exceeded his authority by imposing certain tariffs under the International Emergency Economic Powers Act (IEEPA). The Court also affirmed the grant of declaratory relief of the U.S. Court