Between March 4, 2025 and March 6, 2025, U.S. trade policy in North America changed course multiple times as the Trump Administration initially implemented previously-paused tariffs on imports from Canada and Mexico, and two days later, suspended tariffs on all Canadian and Mexican imports that meet the rules of origin for…
Global Trade & Sanctions Law
Trump Administration Announces Sweeping Tariffs Under “Fair and Reciprocal Plan”
Following days of speculation, President Donald Trump announced on February 13, 2025, a new tariff policy outlined in a Presidential Memorandum entitled the “Fair and Reciprocal Plan” (Plan). The Memorandum directs key trade and economic U.S. government agencies to take action against trading partners that impose tariffs, taxes, non-tariff barriers…
The Trump Administration Reinstates and Expands Section 232 Tariffs on Steel and Aluminum
On February 10, 2025, President Trump issued two Presidential Proclamations reimposing and expanding tariffs on all steel and aluminum imports into the United States pursuant to Section 232 of the Trade Adjustment Act of 1962. These measures effectively supersede prior alternative arrangements, including tariff-rate quotas (TRQs) negotiated with key U.S.…
Trump 2.0: U.S. Tariffs on China Take Effect; Mexico and Canada Granted 30-Day Pause
Following President Trump’s February 1, 2025, announcement of a sweeping set of tariffs on imports from Canada, Mexico, and China, citing immigration concerns and the flow of fentanyl, trade tensions have lurched unpredictably between escalation and temporary resolution. While negotiations between heads of state on February 3, 2025, led to…
Trump 2.0: U.S. Imposes Tariffs on Key Trading Partners
After months of anticipation, on February 1, 2025, President Trump announced the imposition of significant tariffs on Mexico, Canada, and China through three Executive Orders (EOs). While additional details are expected to be published in the Federal Register in days to come, the tariffs mark a significant shift in U.S.…
Trump 2.0: America First Trade Policy Takes Shape
On January 20, 2025, Donald J. Trump was inaugurated as the 47th President of the United States. Within hours of taking office, President Trump issued dozens of executive orders and an “America First Trade Policy” memorandum outlining his administration’s trade priorities and signaling an aggressive approach to reshaping U.S. trade,…
BIS Issues Interim Final Rule Establishing a Framework for Artificial Intelligence Diffusion
On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR), establishing new export controls targeting advanced artificial intelligence (AI) chips and model weights for advanced AI models to protect against national security risks associated with AI while promoting American…
BIS Issues Interim Final Rule on Advanced Computing Integrated Circuits, Providing Long-Awaited Guidance on Due Diligence Procedures
On January 15, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) updating export controls on advanced computing semiconductors. This IFR seeks to ensure that customers of “front-end fabricators” and Outsourced Semiconductor Assembly and Test (OSAT) companies cannot evade controls on…
EU Calls On Member States to Review Outbound Investments in Critical Technologies
On January 16, 2025, the European Commission issued a recommendation encouraging EU Member States to begin reviewing outbound investments in critical technologies including AI, semiconductors and quantum technologies to assess whether such transactions pose risks to EU economic security (the “Recommendation”). The Recommendation constitutes a call for Member States to…
Framework for Collaboration Between U.S. and UK Sanctions Authorities
Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024, formalizing a framework to govern cooperation including in relation to exchanging information, coordinating investigations, training personnel,…