On June 18, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 55D, “Authorizing Certain Services Related to Sakhalin-2.” This general license authorizes certain services that would otherwise be prohibited under OFAC’s Russia sanctions program related to Sakhalin-2 involving the maritime transport of crude oil originating from
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.
US and UK Implement General Terms of Trade Deal
On June 16, 2025, the United States and the United Kingdom formally implemented the General Terms for the United States of America and the United Kingdom of Great Britain and Northern Ireland Economic Prosperity Deal (the “General Terms”). In a related Executive Order (EO), President Donald Trump set forth agreements reached with the UK regarding…
USTR Proposes Modifications to Section 301 Actions on Chinese Vessels and Maritime Transport Operators
On June 12, the Office of the U.S. Trade Representative (USTR) proposed two modifications to its April 17 announcement of actions under Section 301, which are scheduled to take effect starting on October 14, 2025. The actions aim to counter China’s dominance in the maritime sector.
The first proposed modification would revise the method for…
CAFC Maintains President Trump’s IEEPA Tariffs Pending Final Decision
On June 10, 2025, the U.S. Court of Appeals for the Federal Circuit (CAFC) issued a stay keeping both tranches of President Donald Trump’s tariffs implemented under the International Emergency Economic Powers Act of 1977 (IEEPA) (50 U.S.C. § 1701 et seq.) in effect until final adjudication by the appellate court. The per curiam (…
CIT Enjoins IEEPA Tariffs but CAFC Issues Temporary Stay – Analysis & Recommendations
- On May 28, the U.S. Court of International Trade (CIT) permanently enjoined tariffs imposed by President Donald Trump under the International Emergency Economic Powers Act (IEEPA), finding that he exceeded statutory and constitutional authority by imposing broad tariffs on imports from China, Canada, Mexico, and other countries.
- The CIT held that IEEPA does
Second Federal Court Determines IEEPA Tariffs Likely Invalid
On May 29, 2025, the U.S. District Court for the District of Columbia (USDC-DC) issued a preliminary injunction ruling staying the imposition of President Donald Trump’s use of the International Emergency Economic Powers Act (IEEPA). This preliminary injunction applies to tariffs that would be paid by the two named plaintiffs – Learning Resources, Inc. and…
After CIT Blocks President Trump’s IEEPA Tariffs, CAFC Stays Order Pending Review of the CIT’s Judgment and Injunction
On May 29, 2025, the Court of Appeals for the Federal Circuit (CAFC) stayed the decision of the Court of International Trade (CIT) from the previous day, which had vacated both tranches of President Donald Trump’s tariffs implemented under the International Emergency Economic Powers Act of 1977 (IEEPA) (50 U.S.C. § 1701 et seq.). President…
Treasury Relaxes U.S. Economic Sanctions on Syria
On May 23, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) No. 25 relaxing sanctions against the Government of Syria and twenty-eight (28) previously blocked Syrian entities and persons. GL 25 authorizes transactions that would otherwise be prohibited under the U.S. economic sanctions on Syria, including new investment…
CBP Issues Notice Addressing Refunds to Address Tariff “Stacking” Updates
On May 16, 2025, Customs and Border Protection (CBP) issued a Notice to implement President Donald Trump’s earlier Executive Order (EO) 14289 that eliminated the “stacking” (or accumulation) of certain overlapping tariffs. These overlapping tariffs included the IEEPA tariffs on Canada and Mexico, the Section 232 automobile and automotive part tariffs, and the Section 232…
Commerce Rescinds Biden Administration’s AI Diffusion Rule
On May 13, 2025, the Department of Commerce announced that it was rescinding a January 15, 2025 Interim Final Rule that revised the controls under the Export Administration Regulations (EAR) on advanced computing integrated circuits (ICs) and added a new control on artificial intelligence (AI) model weights for certain advanced closed-weight dual-use AI models. See…
