On September 16, 2025, the Office of the U.S. Trade Representative (USTR) issued a notice and request for public comments on the possible extension of the remaining 178 product exclusions in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The USTR has extended these exclusions…

All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2025. This does applies to all relevant persons, not only financial institutions.

This report is pursuant to 31 C.F.R.

On September 16, 2025, the Department of Commerce’s International Trade Administration (ITA) released a Federal Register notice announcing changes to the Harmonized Tariff Schedule of the United States (HTSUS) as to general tariffs on imports of Japanese goods in order to implement the United States-Japan Agreement (see Executive Order 14345).  Under the original framework…

Executive Order 14346 (EO 14346) provides new procedures for implementing trade and security agreements and modifies the Trump administration’s approach to reciprocal tariffs. EO 14346 builds on previous trade actions, particularly those established under EO 14257, by expanding Annex II to EO 14257 – the list of items that are exempt from the reciprocal tariffs…

On September 9, 2025, the U.S. Supreme Court agreed to review a consolidation of two cases challenging the legality of tariffs imposed by President Donald Trump under the International Emergency Economic Powers Act (IEEPA).  It has scheduled oral arguments for the first week of November, an unusually swift timeline for the Court.

The first case…

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…

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…

On September 2, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule in the Federal Register easing licensing requirements for civilian exports to Syria.  The rule implements the policy on Syria established in Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (June 30, 2025) that called for…

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…

On August 28, 2025, the Office of the U.S. Trade Representative (USTR) announced the extension of remaining product exclusions in the Section 301 Investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation. Based on continued consideration of the comments received in response to the December 29, 2023 Federal Register…