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
Scott E. Diamond**
Scott is a senior policy advisor with more than 25 years' experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.
**Not licensed to practice law.
CBP Issues Guidance on Energy, Energy Resources and Critical Minerals from Canada Subject to 10% IEEPA Tariffs; President Trump Issues Executive Order Addressing Mineral Production
UPDATE: On March 24, 2025, Customs and Border Protection (CBP) issued a message noting the release of an updated list of impacted HTSUS codes covering “energy” and “energy resources” from Canada that are now subject to 10% tariffs since March 4, 2025. The list now specifically includes all crude and crude mixtures along with…
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…
Trump Administration Imposes Section 232 Steel and Aluminum 25% Tariffs March 12, 2025; EU and Canada Retaliate
As previously announced by President Donald Trump, the Section 232 steel and aluminum 25% ad valorem tariffs went into effect 12:01 a.m., March 12, 2025, against all steel and aluminum articles and all listed derivatives, including many automotive, construction and consumer products. Aluminum articles and their derivative products from Russia are subject to 200% tariffs.
USTR Releases President Trump’s 2025 Trade Policy Agenda and 2024 Annual Report
On March 3, 2025, the Office of the U.S. Trade Representative (USTR) delivered President Donald Trump’s 2025 Trade Policy Agenda, 2024 Annual Report, and World Trade Organization at Thirty report to Congress. This year’s trade agenda seeks to strengthen the middle class and national defense and to address trade deficits by focusing on a “Production…
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…
The United States Delays Implementation of IEEPA Tariffs Against Canada and Mexico for USMCA-Qualifying Goods Until April 2, 2025
President Donald Trump issued two executive orders (“EOs”) on March 6, 2025 delaying the 25% tariffs imposed against imports of products of Canada and Mexico (10% tariffs for imports of energy products of Canada) pursuant to the International Emergency Economic Powers Act (“IEEPA”) until April 2, 2025. The EOs specifically provide that goods qualifying and entered…
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
- The USTR issued a determination and report in January 2025 finding that China’s acts, policies, and practices of in the maritime, logistics, and shipbuilding sectors burden or restrict U.S. commerce and are actionable under Section 301 of the Trade Act of 1974.
- The USTR is proposing actions that could include significant port service
Tariffs Against Canada and Mexico Enter Into Force March 4, 2025
The Trump administration implemented tariffs against Canada and Mexico effective March 4, 2025, arising from declared national emergencies at both the northern and southern U.S. borders pursuant to the International Economic Emergency Powers Act (IEEPA).
Implementation of Tariffs
On March 3, 2025, U.S. Customs and Border Protection (CBP) issued draft Federal Register notices (to be…
