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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 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.

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