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Chase D. Kaniecki

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Chase Kaniecki’s practice focuses on international trade and national security matters, including CFIUS and global foreign direct investment, economic sanctions, export controls, customs, and trade remedies.

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For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.

On February 1, President Trump issued executive orders announcing sweeping tariffs on products of Canadian, Mexican, and Chinese origin.  As discussed in our previous publication, effective February 4, all products of Chinese origin became subject to an additional 10% tariff pursuant to these orders, while the imposition of tariffs on products of Canadian and Mexican origin were delayed by one month after President Trump reached last-minute agreements with Canadian Prime Minister Justin Trudeau and Mexican President Claudia Sheinbaum to delay the tariffs during ongoing negotiations. Continue Reading President Trump Imposes Tariffs on Canada and Mexico, Additional Tariffs on China

For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.

On February 21, 2025, President Trump issued a memorandum to various U.S. government agencies setting forth an “America First Investment Policy” (the “Memorandum”).  While the Memorandum is a call to arms for the Committee on Foreign Investment in the United States (“CFIUS”) to further restrict Chinese investments into the United States and for the U.S. government to use the recently implemented U.S. Outbound Investment Security Program (“OISP”) to restrict additional U.S. outbound investment into China (described in our alert memorandum linked here), the Memorandum also aims to facilitate inbound investment from allies and partners. Continue Reading President Trump Issues “America First Investment Policy”: Confirms U.S. Openness to Foreign Investment from Allies and Partners, Calls for Enhanced Restrictions on Investments from and into China

On December 27, 2024, the U.S. Department of Justice, National Security Division (“DOJ”) issued a final rule implementing a new regulatory program designed to prevent certain countries (China, Cuba, Iran, North Korea, Russia, and Venezuela) and covered persons from having access to Americans’ bulk sensitive personal data and U.S. government-related data (“Final Rule”).[1]  The Final Rule, which implements Executive Order (“E.O.”) 14117 issued on February 28, 2024, builds on an Advanced Notice of Proposed Rulemaking published March 5, 2024, which we previously discussed here, and a Notice of Proposed Rulemaking published on October 29, 2024.[2]  The Final Rule will enter into effect on April 8, 2025.  However, certain due diligence, audit, and reporting requirements will not require compliance until October 6, 2025. Continue Reading DOJ Issues Final Rule Targeting Bulk Sensitive Personal and U.S. Government-Related Data Transactions Involving Countries of Concern

For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.

On February 10, President Trump issued proclamations (the “Proclamations”) imposing and expanding 25% tariffs on imported steel and aluminum products under Section 232 of the Trade Expansion Act of 1962 (“Section 232”).  As discussed in our previous blog post (available here), the first Trump administration imposed tariffs on steel and aluminum products under Section 232, but numerous countries subsequently received exemptions from the tariffs.  The Executive Order re-imposes tariffs on all countries that previously received exemptions, increases tariffs on aluminum from 10% to 25%, and re-expands the scope of existing tariffs on steel and aluminum to cover derivative steel and aluminum products.  The new steel and aluminum tariffs will go into effect on March 12, 2025; details regarding the new tariffs will be published in the Federal Register within ten days of March 12.Continue Reading President Trump Re-Imposes and Expands Tariffs on Steel and Aluminum

On February 1, President Trump issued executive orders imposing sweeping tariffs on products of Canadian, Mexican, and Chinese origin pursuant to his authority under the International Emergency Economic Powers Act, 50 U.S.C. 1701, et seq. (IEEPA), after expanding previously-declared national emergencies to respond to the “extraordinary threat posed by illegal aliens and drugs, including deadly fentanyl.”  Continue Reading President Trump Imposes Additional Tariffs on China, Delays Tariffs on Canada and Mexico

For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.

With President Trump taking office last week, U.S. and non-U.S. companies are bracing for a new wave of potential tariffs, which the President has repeatedly promised to impose during his second term.  In the months and days leading up to the election, President Trump touted his plan for extensive, across-the-board tariffs even against allies, including Canada, Mexico, and the European Union.Continue Reading Trump Tariffs: What’s Happened, What’s Potentially Coming, and How to Prepare

The following is part of our annual publication Selected Issues for Boards of Directors in 2025. Explore all topics or download the PDF.

The second Trump Administration is expected to mark the return of a more transactional foreign policy approach, with an openness to dealmaking supported by the aggressive use (or threat) of trade controls. Boards should, therefore, expect the U.S. government to continue to rely on trade controls as a key foreign policy tool. Although specific actions remain uncertain, significant change is possible on a number of fronts, including sanctions relating to China, Russia, Iran, Syria and Venezuela.  Continue Reading Trade Controls: Recent Developments and Changes on the Horizon for 2025

On January 15, 2025, the European Commission (the “EC”) published a recommendation (the “Recommendation”)[1] addressed to all EU Member States urging them to review “outbound investments” in certain critical technologies sectors, notably semiconductors, artificial intelligence (“AI”), and quantum technologies.Continue Reading The EU Commission Urges Member States to Review Outbound Investments

On January 10, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued sweeping new sanctions targeting Russia’s energy sector, including the imposition of a new petroleum services ban, expanded secondary sanctions authority, and designations of certain Russian oil producers, insurance providers, and more than 180 so-called “shadow fleet” vessels.  Until this time, U.S. sanctions specific to the Russian energy sector generally were limited to a ban on maritime services for oil and petroleum products sold at or below the relevant price caps, designations of specific projects, traders, or vessels, and certain pre-2022 targeted sectoral sanctions and secondary sanctions authorities. Continue Reading OFAC Expands Sanctions against Russian Energy Sector