U.S.

Subscribe to U.S. via RSS

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.

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

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

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 China

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 Concern

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

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

On January 10, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued sweeping new sanctions targeting Russia’s energy sector, including the imposition of a new petroleum services ban, expanded secondary sanctions authority, and designations of certain Russian oil producers, insurance providers, and more than 180 so-called “shadow fleet” vessels.  Until this time, U.S. sanctions specific to the Russian energy sector generally were limited to a ban on maritime services for oil and petroleum products sold at or below the relevant price caps, designations of specific projects, traders, or vessels, and certain pre-2022 targeted sectoral sanctions and secondary sanctions authorities. Continue Reading OFAC Expands Sanctions against Russian Energy Sector