The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) recently published its 2024 Annual Report, which provides information regarding transactions reviewed by CFIUS during 2024.[1] Key takeaways from the 2024 Annual Report are below. Continue Reading CFIUS Releases 2024 Annual Report: Key Takeaways
President Trump Expands Global Reciprocal Tariffs and Imposes Additional Tariffs on Brazil, Canada, and India
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.
The Trump administration issued a series of executive orders in late July and early August 2025, implementing substantial tariff increases on imports from numerous countries. These developments represent an escalation from the initial reciprocal tariff framework established in April 2025 (discussed here), with new measures targeting specific countries for distinct policy reasons. The comprehensive nature of these orders, affecting approximately 70 countries with reciprocal tariff rates ranging from 10% to 41%, alongside varying country-specific tariffs reaching as high as 40% for Brazil, 35% for Canada, and 25% for India, likely will have a major impact on global supply chains and international commerce.Continue Reading President Trump Expands Global Reciprocal Tariffs and Imposes Additional Tariffs on Brazil, Canada, and India
President Trump Issues Order Requiring Chinese Company to Divest Interest in U.S. Video Processing Technology Company
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 July 8, 2025, President Trump issued an order (the “Order”) requiring a Chinese company, Suirui Group Co., Ltd., and its Hong Kong subsidiary, Suirui International Co., Limited (collectively, “Suirui”), to divest its interest and rights in Jupiter Systems, LLC (“Jupiter”), a California-based company specializing in video processing technology.Continue Reading President Trump Issues Order Requiring Chinese Company to Divest Interest in U.S. Video Processing Technology Company
President Trump Announces Plans to Impose Modified Reciprocal Tariffs and New Tariffs on Canada and Mexico on August 1
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 April 2, 2025, President Trump issued an executive order imposing sweeping reciprocal tariffs pursuant to the International Emergency Economic Powers Act, 50 U.S.C. 1701, et seq. (“IEEPA”), after previously imposing tariffs on certain items of Mexican and Canadian origin, effective April 2, under IEEPA.[1] On April 9, 2025, President Trump announced a 90-day pause on the imposition of reciprocal tariff rates above 10% for most countries to allow for trade deal negotiations. On July 7, 2025, President Trump signed an Executive Order extending the pause on the imposition of reciprocal tariff rates above 10% for most countries to August 1, 2025, if trade negotiations are not completed by that date. Continue Reading President Trump Announces Plans to Impose Modified Reciprocal Tariffs and New Tariffs on Canada and Mexico on August 1
U.S. Government Formally Terminates Economic Sanctions on Syria
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 June 30, 2025, President Trump issued Executive Order 14312 (the “Executive Order”) terminating several national emergencies related to Syria, revoking executive orders that imposed sanctions and export restrictions on Syria, and directing the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”), U.S. Department of State, and U.S. Department of Commerce to ease trade and finance restrictions on Syria and its new government, led by President Ahmed al-Sharaa. The Executive Order also expands an earlier executive order of October 2019, E.O. 13894, to impose additional sanctions on individuals and entities associated with the regime of former Syrian President Bashar al-Assad.Continue Reading U.S. Government Formally Terminates Economic Sanctions on Syria
U.S. Government Suspends Economic Sanctions on Syria; EU and UK Take Similar Actions
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 May 23, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”), titled “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons.” Effective immediately, GL 25 suspends nearly all OFAC sanctions on Syria, in line with President Trump’s prior announcement that he intended to lift sanctions on Syria following the ouster of former Syrian President Bashar al-Assad and the establishment of a new government under Syrian President Ahmed al-Sharaa.Continue Reading U.S. Government Suspends Economic Sanctions on Syria; EU and UK Take Similar Actions
U.S. Court of International Trade Strikes Down Trump’s IEEPA Tariffs
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 May 28, 2025, the U.S. Court of International Trade (“CIT”) issued a decision holding that President Trump exceeded his authority under the International Emergency Economic Powers Act of 1977, 50 U.S.C. 1701, et seq. (“IEEPA”) in imposing fentanyl trafficking-related tariffs on Canada, Mexico, and China (referred to by the CIT as “Trafficking Tariffs”), and the broad reciprocal tariffs announced on April 2, 2025 (referred to by the CIT as “Worldwide and Retaliatory Tariffs”).[1] In a Per Curium opinion, the three-judge panel granted summary judgment to a group of private plaintiffs and state attorneys general who had challenged the Trump administration tariffs imposed under IEEPA, vacated the Executive Orders imposing the tariffs, and enjoined collection of the tariffs.[2] On May 29, 2025, the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) temporarily stayed the CIT’s order, keeping the relevant tariffs in effect while the Federal Circuit considers the case. Continue Reading U.S. Court of International Trade Strikes Down Trump’s IEEPA Tariffs
U.S. and UK, China Agree to Trade Deals Limiting Reciprocal Tariffs
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.
President Trump has announced two new trade deals negotiated by the United States: the U.S.-UK Economic Prosperity Deal (“EPD”), announced on May 8, and an executive order, Modifying Reciprocal Tariff Rates to Reflect Discussions with the People’s Republic of China, issued on May 12 (the “PRC Reciprocal Tariff EO”). Continue Reading U.S. and UK, China Agree to Trade Deals Limiting Reciprocal Tariffs
DOJ Issues Additional Guidance as Data Security Program Enters into Effect; Limits Enforcement for First 90 Days
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 April 11, 2025, the U.S. Department of Justice, National Security Division (“DOJ”) issued a compliance guide (“Compliance Guide”), a set of frequently asked questions (“FAQs”), and a 90-day limited enforcement policy (“Enforcement Policy”) relating to implementation of the Data Security Program, codified at 28 C.F.R. Part 202 (“DSP”). The DSP is a regulatory program designed to prevent certain countries of concern—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. The DSP largely went into effect on April 8, 2025. Continue Reading DOJ Issues Additional Guidance as Data Security Program Enters into Effect; Limits Enforcement for First 90 Days
President Trump Imposes Sweeping Reciprocal Tariffs
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.
Update as of April 10, 2025: On April 9, 2025, President Trump announced a 90-day pause on the imposition of reciprocal tariff rates above 10% for most countries. For all countries other than China, Canada, and Mexico, tariffs are paused at the 10% rate effective April 5, 2025, pending negotiations for the potential reduction or elimination of reciprocal tariffs. Tariffs on Canadian and Mexican-origin products continue to apply as described below. Reciprocal tariffs on Chinese-origin products remain in effect and have increased as the Chinese and U.S. governments imposed retaliatory tariffs on U.S.- and Chinese-origin products, respectively.
On April 2, 2025, President Trump issued an executive order (the “E.O.”) imposing sweeping reciprocal tariffs pursuant to the International Emergency Economic Powers Act, 50 U.S.C. 1701, et seq. (“IEEPA”).[1] Effective April 5, 2025, all products from all trading partners, unless exempted, will be subject to additional 10% tariffs. In addition, increased country-specific tariffs, as detailed in Annex I of the E.O. (copied below), will enter into effect on April 9, 2025.Continue Reading President Trump Imposes Sweeping Reciprocal Tariffs