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Global Trade & Sanctions Law

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Key Takeaways from the CFIUS 2024 Annual Report

The Committee on Foreign Investment in the United States (CFIUS) recently published its 2024 Annual Report. Filing volume for both declarations and notices remains lower compared to their peaks in 2021 and 2022, respectively. While CFIUS continues to clear the vast majority of transactions it reviews without mitigation, compliance site…

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Snapshot of Current Tariff Actions and Negotiations

In the past several weeks the Trump administration has taken multiple actions on tariffs, based on several different legal authorities. The landscape is shifting almost continuously, and more changes are likely coming. A number of the tariff actions are linked to the results of bilateral negotiations that involve commitments to…

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Tariffs and Insolvency: Legal Consequences of Tariffs in Insolvency Processes

Under the Trump administration, the U.S. has adopted sweeping tariffs on nearly every trading partner, with a promise of more on a range of strategic sectors including industrial metals and critical minerals, pharmaceuticals, semiconductors, and automobiles. These actions have provoked countermeasures from China and others. While these developments are rightly…

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Trump Administration Imposes Secondary Tariffs on India Over Russian Oil Imports

On August 6, 2025, President Trump published a new Executive Order imposing secondary tariffs on India in response to its continued importation of Russian-origin crude oil. This marks both an escalation in U.S. trade negotiations with India and the first major Russia-related enforcement action of his second term. It also…

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UK Expands Whistleblower Protections to Bolster Sanctions Enforcement

On June 26, 2025, the UK government brought into force the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 (“2025 Amendment”), marking a notable development in the UK government’s sanctions enforcement strategy. The 2025 Amendment expands the statutory protections given to whistleblowers to cover the reporting of breaches of UK…

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UK Investment Screening Regime: Still Expecting Amendments

On 23 June 2025, the UK government published its new Modern Industrial Strategy document (the “IS Document”), outlining the government’s current strategies for UK economic growth. The policy paper focuses on eight priority sectors: professional and business services; advanced manufacturing; clean energy; creative industries; defence; digital technologies; financial services; and…

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Two Federal Courts Invalidate “Reciprocal” and Other Emergency Tariffs, But Relief Paused Pending Appeal

In a landmark decision, the U.S. Court of International Trade (CIT) has ruled against President Trump’s imposition of tariffs under the International Emergency Economic Powers Act (IEEPA). In its decision (involving two consolidated cases, V.O.S. Selections, Inc. et al. v. United States of America et al. and The State of…

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Trump Administration Rescinds Biden’s AI Diffusion Rule

Two days before its scheduled effective date, the Department of Commerce’s Bureau of Industry and Security (BIS) announced the rescission of the Biden administration’s Artificial Intelligence (AI) Diffusion Rule on May 13. The Framework for Artificial Intelligence Diffusion, issued as an interim final rule on January 15, 2025, established new…

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President Trump Initiates Section 232 Investigations into Pharmaceuticals, Semiconductors, Critical Minerals and Trucks

The Trump administration has intensified its America First Trade Policy initiatives by announcing three new investigations under Section 232 of the Trade Expansion Act of 1962 by the Department of Commerce. As foreshadowed in the administration’s Day 1 Executive Order, last week Commerce announced the initiation of investigations into whether imports…

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President Trump Imposes Far-Reaching “Reciprocal” Tariffs, Implements Tariffs on Automobiles and Closes De Minimis Loophole for Chinese Imports

On April 2, 2025, President Trump signed a sweeping Executive Order (EO) imposing tariffs designed to address what the Trump administration has characterized as persistent trade imbalances allegedly caused by unfair trade practices. Invoking the International Emergency Economic Powers Act (IEEPA), the Administration declared trade deficits a national emergency and…