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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 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

As of July 8, the U.S. Department of Justice (“DOJ”) is scheduled to begin full enforcement of its Data Security Program (“DSP”) and the recently issued Bulk Data Rule after its 90-day limited enforcement policy expires, ushering in “full compliance” requirements for U.S. companies and individuals.[1] Continue Reading Enforcement Countdown: Is DOJ Ready for the Bulk Data Rule “Grace Period” to End?

On June 16, 2025, the Department of Justice’s National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas announced a landmark declination to prosecute private equity firm White Deer Management LLC following its voluntary self-disclosure of sanctions violations committed by an acquired company.[1]  This marks the first application of the safe harbor provisions for voluntary self-disclosure in connection with mergers and acquisitions—a policy put in place during the previous administration—and demonstrates the benefits of NSD’s enforcement policies while highlighting continued enforcement priorities across administrations.Continue Reading DOJ National Security Division Issues First Declination Under Merger-Related Safe Harbor Provisions

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

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

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

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

On April 9, 2025, the EU approved new trade countermeasures targeting c.€18 billion of U.S.-origin products in response to 25% tariffs imposed by the Trump II administration on steel and aluminium imports.  These new measures apply alongside 2018 and 2020 countermeasures targeting c.€8 billion worth of U.S. goods, which were due to come back into effect on April 15.  On April 10, the EU announced a 90-day pause on these countermeasures to facilitate trade negotiations with the U.S.Continue Reading The EU’s Latest Response to Trump II 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

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.

In the final weeks of the Biden Administration and early days of the second Trump Administration, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued a series of new rules amending the Export Administration Regulations (“EAR”) to further expand and refine export controls on advanced computing items, semiconductor manufacturing equipment (“SME”), artificial intelligence (“AI”) items, and related technology destined to the People’s Republic of China (including Hong Kong) (“China”) and Macau.Continue Reading BIS Further Restricts Exports of Artificial Intelligence and Advanced Chips to China