On October 7, 2026, the U.S. Department of the Treasury (Treasury) announced that it had issued the first civil monetary penalty under the Outbound Investment Security Program (OISP) in July 2026.[1] Treasury penalized Amidi, LLC (Amidi), a U.S. entity, $200,000 for failing to notify Treasury of an investment by its controlled foreign entity, a Chinese fund, in a Chinese artificial intelligence (AI) and robotics company. Amidi also is the parent entity of Plug and Play Tech Center, a Silicon Valley-based global innovation platform and startup accelerator. Although the underlying investment was modest in dollar terms, the announcement is significant as the first publicly announced enforcement action under the OISP, which took effect on January 2, 2025.
Continue Reading Treasury Imposes First Penalty Under the Outbound Investment Security ProgramTrump Administration Imposes New Section 301 Tariffs on 60 Trading Partners, New Section 338 Tariffs on Canada
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 23, 2026, the Trump administration announced new tariffs (Forced Labor Tariffs) on goods from 60 economies, including the European Union (EU) and China, alleging these economies either failed to enforce forced labor prohibitions or failed to adopt a forced labor import prohibition. The new duties took effect on July 24, 2026, replacing the temporary 10% global tariff imposed by President Trump under Section 122 of the Trade Act of 1974 (Section 122 Tariffs), which expired on July 24, 2026. Section 122 Tariffs originally were imposed after the Supreme Court struck down the administration’s prior tariffs imposed under the International Emergency Economic Powers Act (IEEPA).[1] Although the Trump administration has stated that the Forced Labor Tariffs will apply to 99% of imports into the United States, the duties (ranging from 10 to 12.5%) have a number of exemptions and exclusions, including products subject to tariffs imposed under Section 232 of the Trade Expansion Act (Section 232 Tariffs).
Continue Reading Trump Administration Imposes New Section 301 Tariffs on 60 Trading Partners, New Section 338 Tariffs on CanadaDepartment of Defense Adds Major Technology, Automotive, and Biotechnology Firms to 1260H Chinese Military Companies List
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 8, 2026, the U.S. Department of Defense (DOD) published an updated list of “Chinese military companies” operating in the United States as required by Section 1260H of the National Defense Authorization Act (NDAA) for Fiscal Year 2021 (the 1260H List), which was last published on January 7, 2025.[1] The updated list adds dozens of entities, including some of the largest publicly traded companies in China, spanning the automotive and electric vehicle, e-commerce, artificial intelligence, robotics, semiconductors, solar technology, and biotechnology sectors. These additions continue the trend of a steady expansion of the 1260H List from traditional defense and state-owned enterprises.[2] The updated 1260H List now identifies nearly 200 entities, including a number of subsidiaries listed alongside their parent companies. Notable new additions include BYD, NIO, Alibaba, Baidu, Unitree, TP-Link, and WuXi AppTec.[3] The update also removed 10 entities from the prior list.
Continue Reading Department of Defense Adds Major Technology, Automotive, and Biotechnology Firms to 1260H Chinese Military Companies ListPresident Trump Issues Order Requiring Chinese Company to Divest Interest in U.S. Video Processing Technology Company
By Chase D. Kaniecki, B.J. Altvater, Ana Carolina Maloney & Ben Perez on
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 CompanyU.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 TariffsPresident 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
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 ChinaMOFCOM Issues Final Determination on Trade and Investment Barrier Investigation into the EU’s Foreign Subsidies Regulation
By François-Charles Laprévote, Cunzhen Huang, Wanjie Lin, Huanbing Xu & Mengchu Tian on
On January 9, 2025, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) released its decision in a trade and investment barrier investigation into the European Union’s Foreign Subsidies Regulation (“FSR”).
Continue Reading MOFCOM Issues Final Determination on Trade and Investment Barrier Investigation into the EU’s Foreign Subsidies RegulationDOJ Issues Final Rule Targeting Bulk Sensitive Personal and U.S. Government-Related Data Transactions Involving Countries of Concern
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 ConcernCommerce Takes Next Step in Furtherance of Import Prohibition on Connected Vehicles and Systems from China and Russia
By Chase D. Kaniecki, Catherine Johnson & Ryan Brown on
On September 26, 2024, a Notice of Proposed Rulemaking (NPRM) was published in the Federal Register to establish regulations that would generally prohibit the sale or import into the United States of certain “connected vehicles” integrating specific pieces of hardware and software, or those components sold separately, with a sufficient nexus to the People’s Republic of China (PRC) or Russia (the Proposed Rule).[1] The Proposed Rule, which was issued by the U.S. Department of Commerce, Bureau of Industry and Security (BIS), follows an earlier Advanced Notice of Proposed Rulemaking (ANPRM) published on March 1, 2024 and addresses comments received in response to the ANPRM.[2]
Continue Reading Commerce Takes Next Step in Furtherance of Import Prohibition on Connected Vehicles and Systems from China and RussiaThe European Commission targets Chinese battery electric vehicles with provisional duties to counteract subsidies
By François-Charles Laprévote, Wanjie Lin & William Kocemba on
On July 4, 2024, the European Commission imposed provisional countervailing duties on imports of battery electric vehicles (BEVs) from China.
Continue Reading The European Commission targets Chinese battery electric vehicles with provisional duties to counteract subsidies