Tariffs/Trade Policy

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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 May 12, the U.S. Department of Justice (DOJ) issued updated policy memoranda relating to the investigation and prosecution of white collar crimes, including its White-Collar Enforcement Plan, Revised Corporate Enforcement and Voluntary Self-Disclosure Policy, Memorandum on Selection of Monitors in Criminal Division Matters, and the Criminal Division’s Corporate Whistleblower Awards Pilot Program Revisited. These…

On May 8, 2025, the White House published general terms for a future trade deal “to enhance [the] economic partnership” between the United States and the United Kingdom. The general terms, which names the forthcoming agreement as the U.S.-UK Economic Prosperity Deal, “do[] not constitute a legally binding agreement” but rather memorialize a set of…

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’…

On April 17, 2025, the Office of the U.S. Trade Representative (USTR) announced targeted actions “to restore American shipbuilding” after its determination that China was implementing “unreasonable acts, policies, and practices to dominate the maritime, logistics, and shipbuilding sectors.” Although the specific details of the targeted actions differ from USTR’s proposed actions (see Update…

On April 11, 2025, President Donald Trump issued a Presidential Memorandum providing clarification of allowable exceptions under Executive Order 14257 of April 2, 2025 (i.e., implementation of reciprocal tariffs). The memorandum clarifies that one excepted product is the importation into the United States of “semiconductors.” The memo proceeds to define this term as including products…

On April 9, 2025, President Donald Trump issued an Executive Order (EO) announcing that he was pausing the country-specific reciprocal tariffs and, instead, leaving in place for 90 days the baseline 10% tariffs on all countries that was implemented on April 5, 2025. The President, however, noted that this pause would not apply to imports…

On April 8, 2025, President Donald Trump issued a new Executive Order (EO) to address China’s retaliatory 34 percent tariff it is scheduled to impose on all goods imported into China originating from the United States beginning on April 10, 2025. The President has stated that effective with respect to goods entered for consumption, or…