On September 24, 2025, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against bicycles, bicycle parts, and bicycle accessories produced by Giant Manufacturing Co. Ltd. in Taiwan. The WRO follows an investigation into the company where CBP discovered several International Labour Organization (ILO) forced labor indicators, including abusive working and living
Supply Chain
New Process Announced for Adding Automobile Parts to Section 232 Tariffs
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…
BIS Now Accepting Requests to Add Products to Section 232 Steel and Aluminum Tariffs
On September 17, 2025, the Bureau of Industry and Security (BIS) published a Federal Register notice that it will again accept requests for new derivative products to be subject to Section 232 tariffs on steel and aluminum articles. The request window is open from September 15 through September 29, 2025. Requests must provide detailed information…
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…
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…
FinCEN Issues Advisory and Financial Trend Analysis on Chinese Money Laundering Networks
Continuing U.S. Enforcement Targeting of Cartels and Related Support
On August 28, 2025, the Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2025-A003 and an accompanying Financial Trend Analysis to alert U.S. financial institutions of the significant and escalating threat posed by Chinese money laundering networks (CMLNs).
The first component, Advisory FIN-2025-A003, urges vigilance in detecting…
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…
UFLPA Annual Strategy Update: U.S. Department of Homeland Security Designates New High-Priority Sectors and Adds 78 Entities to Forced Labor List
- the Entity List
Commerce Publishes Federal Register Notice Modifying HTSUS for Implementing General Terms of U.S. and UK Trade Deal
The U.S. Department of Commerce’s International Trade Administration (ITA) has published a Federal Register notice indicating that effective June 30, 2025, in consultation with U.S. Customs and Border Protection and the U.S. International Trade Commission, it has revised relevant provisions of the Harmonized Tariff Schedule of the United State (HTSUS) to conform with changes specified…
Section 232 Aluminum and Steel Tariffs Increased to 50% Except for UK; Significant Changes Made to Calculating and “Stacking” of Tariffs
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…