Tariffs/Trade Policy

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On November 20, 2025, President Donald Trump issued an Executive Order modifying the scope of certain ad valorem tariffs on Brazil implemented on July 30, 2005, pursuant to the International Emergency Economic Powers Act (IEEPA). These earlier tariffs placed a 40% duty rate on certain articles of Brazil, including numerous agricultural products, coffee and beef.…

According to a Joint Statement issued by the White House on November 13, 2025, the United States and the Republic of Ecuador have entered into a Framework for an Agreement on Reciprocal Trade to “provide access to each other’s markets and increase alignment on economic and national security matters.” As noted in a separate White…

On November 13, 2025, the United States and the Argentine Republic entered a framework for an Agreement on Reciprocal Trade. The Agreement seeks “to drive long-term growth, expand opportunity, and create a transparent and rules-based environment for commerce and innovation.”  While representatives from both countries continue to negotiate and finalize the formal agreement, it will…

On November 13, 2025, the United States and the Republic of Guatemala entered a framework for an Agreement on Reciprocal Trade. The Agreement aims to strengthen the countries’ economic partnership established in 2006 under the Dominican Republic–Central America–United States Free Trade Agreement (“CAFTA-DR”). While representatives from both countries continue to negotiate and finalize the formal…

On November 13, 2025, the United States and the Republic of El Salvador entered a framework for an Agreement on Reciprocal Trade. The Agreement aims to strengthen the countries’ economic partnership established in 2006 under the Dominican Republic–Central America–United States Free Trade Agreement (“CAFTA-DR”). The framework agreement is one of several reached by the…

On November 14, 2025, President Donald Trump issued an executive order exempting various agricultural products from the reciprocal tariff regime established under the International Emergency Economic Powers Act (“IEEPA”). Listed in Annex I of the executive order by their tariff codes within the Harmonized Tariff Schedule of the United States (“HTSUS”), these agricultural products include…

On November 14, 2025, the United States, the Swiss Confederation (Switzerland), and the Principality of Liechtenstein (Liechtenstein) agreed to a framework for negotiations on an Agreement on Reciprocal Trade.  While representatives from the three countries continue to negotiate the formal agreement and hope to conclude any agreement during the first quarter of 2026, the key…

Key Notes

  • Tariff undervaluation may result in criminal charges.
  • False country of origin may result in government procurement-related fraud charges, not only tariff-related fraud charges.

The Department of Justice (DOJ) in September announced the unsealing of an indictment charging two Colorado companies and three executives with a multiyear scheme to sell Chinese made forklifts to…

On November 5, 2025, the U.S. Supreme Court heard oral arguments in a high-profile consolidated appeal challenging whether President Donald Trump lawfully invoked the International Emergency Economic Powers Act (“IEEPA”) to impose tariffs.  The cases challenge two sets of tariffs Trump implemented earlier this year: (1) tariffs against Canada, China, and Mexico in response to…