Timely news and analysis of the latest developments in international trade law
On November 10, 2025, the U.S. Department of State, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control, issued a Tri-Seal Advisory on sanctions and export controls relief for Syria.
The advisory provides that the United States no longer imposes comprehensive sanctions on Syria and that the…
On November 1, 2025, the White House published a Fact Sheet announcing that the Department of Commerce’s Bureau of Industry and Security (“BIS”) will suspend the new “50% Rule”—also known as the “Affiliates Rule”—for one year, beginning November 10, 2025. The suspension was among several concessions reached during trade negotiations between the United States and…
On October 7, 2025, BIS posted a second tranche of requests made by the public for inclusion on the list of derivative products subject to Section 232 tariffs on steel and aluminum derivative products. BIS received 95 inclusion requests in the second submission period that opened on September 15 and closed on September 29. The…
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule in which it announced that it was rescinding in its entirety an earlier Interim Final Rule issued during President Joseph Biden’s Administration that imposed new export license requirements for firearms and related ammunition and components. The Final…
As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule that expands the export control restrictions of its Entity List to cover any affiliates that are at least 50% owned by one (or more) entities on the Entity List or the Military End-User (MEU) List. Previously…
On September 29, 2025, President Donald Trump issued a proclamation announcing that the Department of Commerce had concluded its investigation into the effects of imports of timber, lumber, and their derivative products (collectively, wood products) pursuant to Section 232 of the Trade Expansion Act of 1962 and found certain wood products are being imported into…
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 personal protective equipment (PPE), medical consumables, and medical equipment including devices. Interested parties may submit written comments, data, analyses, or…
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…
In Proclamation 10908, “Adjusting Imports of Automobiles and Automobile Parts into The United States,” on March 26, 2025, President Trump ordered the Secretary of Commerce to create a process for including additional automobile parts for passenger vehicles and light trucks to Section 232 tariffs on imports. A new interim final rule published on September 17…
