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For the first time, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) invoked the Fentanyl Sanctions Act and the Fend OFF Fentanyl Act on June 25, 2025, to issue three separate orders that each designate a Mexico-based financial institution as a “primary money laundering concern in connection with illicit opioid trafficking.” The three…

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 (…

President Donald Trump issued a Proclamation on June 3, 2025 increasing the previously imposed Section 232 tariffs on aluminum and steel products and their derivatives from 25% to 50%. These increased tariffs were effective June 4, 2025. The proclamation excluded products of the United Kingdom which stay at 25% until July 9, 2025.

U.S. Customs…

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…

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…

On April 29, 2025, President Trump signed a Proclamation amending the previously announced tariffs on automobile parts used in passenger vehicles and light trucks. This amendment follows Proclamation 10908, which announced 25% section 232 tariffs on imports of certain final, assembled passenger vehicles and light trucks (“automobiles”), effective April 3, 2025, and imports of…

On April 29, 2025, President Donald Trump issued an Executive Order (EO) clarifying that each of the tariffs he has imposed pursuant to the International Emergency Economic Powers Act (IEEPA) and Section 232 of the Trade Expansion Act of 1962, serve separate and distinct policy purposes, but should “not all have a cumulative effect (or ‘stack’…

UPDATED: This blog post has been updated with additional information and links upon the release of the Annexes to the Executive Order. Readers should note that the breadth and depth of this Executive Order and the implementation of these tariffs is unprecedented, thus the situation regarding interpretation and their implementation remains fluid. It is expected…

On April 2, 2025, the Annex to the Presidential Proclamation imposing 25% tariffs under Section 232 of the Trade Expansion Act of 1962 on imports of automobiles and certain automobile parts was released along with U.S. Customs and Border Protection (US-CBP) guidance regarding the fully assembled automobile provisions. As previously reported, see Thompson Hine Update…

On March 26, 2025, President Donald Trump issued a Proclamation imposing 25% tariffs under Section 232 of the Trade Expansion Act of 1962 on imports of automobiles and certain automobile parts, citing “a critical threat to U.S. national security.” The tariffs will apply to final assembled automobiles, entered for consumption or withdrawn from warehouse for…