U.S. Trade

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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.

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

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.

Earlier this month, the U.S. Department of Commerce (Commerce), Bureau of Industry and Security (BIS) held its annual Update Conference on Export Controls and Policy (the Conference). During the Conference, key government officials signaled an intent to ramp up enforcement of the Export Administration Regulations (EAR) going forward. For example, in opening remarks to Conference attendees, U.S. Secretary of Commerce Howard Lutnick said there would be a “dramatic” increase in enforcement by BIS under the Trump administration, including increased fines and penalties for parties that violate the EAR.Continue Reading U.S. Government Signals Intent to Increase Enforcement of U.S. Export Controls

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 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

The Russian financial services sector remains a key target of U.S., UK, and EU sanctions.  As discussed below, a number of recent such sanctions against Russia and countermeasures by the Russian government  have further complicated efforts for investors seeking to divest listed securities from Russia.Continue Reading Sanctions on Russian Securities Infrastructure Create Additional Hurdles to Divesting from Russia

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 Russia