On July 7, 2025, based on “additional information and recommendation from various senior officials”, President Donald Trump issued an Executive Order determining that it is “necessary and appropriate” to again extend the suspension on reciprocal tariffs originally implemented by an earlier Executive Order on April 2, 2025. The proposed reciprocal tariffs will be suspended until…

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 30, 2025, President Donald Trump issued an Executive Order (EO) that removes sanctions on Syria, provides for the issuance of waivers that will permit the relaxation of export controls and other restrictions on Syria, and otherwise seeks to support “the positive actions” taken by the new Syrian government under President Ahmed al-Sharaa. The…

On June 30, 2025, President Donald Trump reissued National Security Presidential Memorandum (NSPM-5) to address U.S. policy towards Cuba. This version of NSPM-5 revises and amends the earlier version of NSPM-5 issued in June 2017 (see Thompson Hine Update of June 20, 2017).

NSPM-5 includes several policy statements including continued support of economic…

On June 24, 2025, in a press release, the Department of Commerce’s International Trade Administration (ITA) announced new procedures for U.S. producers of auto parts to request that additional auto parts be included in the list of auto parts that are subject to 25% tariffs under the Section 232 review of automobiles and auto…

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…

The Ninth Circuit Court of Appeals has upheld a $26 million fraud verdict against a pipe importer for violating the False Claims Act (FCA) by making false statements on customs forms to avoid paying antidumping duties on Chinese-made pipe fittings. The court rejected the importer’s argument that the Tariff Act provides the exclusive remedy for…

On June 18, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 55D, “Authorizing Certain Services Related to Sakhalin-2.” This general license authorizes certain services that would otherwise be prohibited under OFAC’s Russia sanctions program related to Sakhalin-2 involving the maritime transport of crude oil originating from…

On June 16, 2025, the United States and the United Kingdom formally implemented the General Terms for the United States of America and the United Kingdom of Great Britain and Northern Ireland Economic Prosperity Deal (the “General Terms”). In a related Executive Order (EO), President Donald Trump set forth agreements reached with the UK regarding…

On June 12, the Office of the U.S. Trade Representative (USTR) proposed two modifications to its April 17 announcement of actions under Section 301, which are scheduled to take effect starting on October 14, 2025. The actions aim to counter China’s dominance in the maritime sector.

The first proposed modification would revise the method for…