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
International Trade
U.S. Government Suspends Economic Sanctions on Syria; EU and UK Take Similar Actions
Posted in Enforcement, European Union, International Trade, Sanctions, Syria, U.S., U.S. Trade, United Kingdom
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 National Security Division Issues Second Declination Under Corporate Enforcement Policy
On April 30, 2025, the Department of Justice’s (“DOJ”) National Security Division (“NSD”), alongside the U.S. Attorney’s Office for the Northern District of California, announced a declination to prosecute Universities Space Research Association (“USRA”) for criminal export control violations committed by a former employee.[1] This marks only the second declination issued by NSD under its Enforcement Policy for Business Organizations (the “Policy”), following voluntary self-disclosure.Continue Reading DOJ National Security Division Issues Second Declination Under Corporate Enforcement Policy
The EU’s Latest Response to Trump II Tariffs
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
The EU’s Possible Response to Trump II Tariffs
On February 1, 2025, U.S. President Donald Trump imposed a 25% additional tariff on imports of Canadian- and Mexican-origin goods (since suspended for 30 days) and a 10% additional tariff on imports of Chinese-origin goods. On February 10, President Trump announced a 25% tariff on steel and aluminum imports,[1] and is preparing “a comprehensive plan” to tackle “non-reciprocal trading arrangements”.[2] The EU is a key target of the new measures, with the EU’s 10% tariff on imported cars and ban on U.S. shellfish imports identified as unfair trade barriers. As with Canada and Mexico, any EU tariffs may be driven by other strategic objectives, such as NATO expenditure and a takeover of Greenland.Continue Reading The EU’s Possible Response to Trump II Tariffs
President Trump Re-Imposes and Expands Tariffs on Steel and Aluminum
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
Commerce Issues Final ICTS Rule; Takes Steps to Implement the Program
By Chase D. Kaniecki, Samuel H. Chang & Ryan Brown on
On December 5, 2024, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) implementing the procedures BIS will follow when reviewing information and communications technology (“ICTS”) transactions that may pose a risk to U.S. national security pursuant to Executive Order (E.O.) 13873.[1] In particular, the Final Rule authorizes the Secretary of Commerce (the “Secretary”) (or the Secretary’s designee, e.g., the Under Secretary of Commerce for Industry and Security) to review, prohibit, or impose mitigation measures on certain types of transactions (“Covered ICTS Transactions”) that involve ICTS designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary and that pose an undue or unacceptable risk to U.S. national security. We consider each of these concepts below, after which we discuss the review, prohibition, and mitigation processes associated with covered transactions.Continue Reading Commerce Issues Final ICTS Rule; Takes Steps to Implement the Program
OFAC Sanctions Gazprombank, Continues to Target Russian Financial Sector and Foreign Financial Institutions
On November 21, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) designated additional entities operating in the Russian financial services sector, including Gazprombank Joint Stock Company (“Gazprombank”), the largest and, until November 21, most significant remaining non-sanctioned Russian bank that has served as the primary conduit for processing payments for Russian gas sold to third countries since March 2022. Specifically, OFAC designated Gazprombank pursuant to Executive Order 14024 (“E.O. 14024”) for operating or having operated in the financial services sector of the Russian Federation economy, and noted that Gazprombank had served as a “conduit for Russia to purchase military materiel,” and also was used by the Russian government to pay military personnel and their families.Continue Reading OFAC Sanctions Gazprombank, Continues to Target Russian Financial Sector and Foreign Financial Institutions