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.

Shortly after publication of this post, the Trump administration filed a petition for a writ of certiorari to the U.S. Supreme Court, which has expedited its review with oral arguments scheduled for November 5, 2025. The tariffs will remain in effect pending the Supreme Court’s review.

On August 29, 2025, the U.S. Court of Appeals for the Federal Circuit (the “Federal Circuit”) issued a 7-4 decision upholding the U.S. Court of International Trade’s (the “CIT”) May 28, 2025 ruling striking down President Trump’s fentanyl trafficking-related tariffs imposed on Canada, Mexico, and China (referred to by the Federal Circuit as “Trafficking Tariffs”), and the broad reciprocal tariffs announced on April 2, 2025 (referred to by the Federal Circuit as “Reciprocal Tariffs”).[1] The Federal Circuit’s opinion held 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 the challenged Trafficking Tariffs and Reciprocal Tariffs. In a concurrent order, the Federal Circuit stayed the effects of its opinion until October 14, 2025, while the U.S. government appeals the ruling to the U.S. Supreme Court.

Continue Reading U.S. Court of Appeals for the Federal Circuit Rules Against Trump’s IEEPA Tariffs

The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) recently published its 2024 Annual Report, which provides information regarding transactions reviewed by CFIUS during 2024.[1] Key takeaways from the 2024 Annual Report are below.   

Continue Reading CFIUS Releases 2024 Annual Report: Key Takeaways

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.

The Trump administration issued a series of executive orders in late July and early August 2025, implementing substantial tariff increases on imports from numerous countries.  These developments represent an escalation from the initial reciprocal tariff framework established in April 2025 (discussed here), with new measures targeting specific countries for distinct policy reasons.  The comprehensive nature of these orders, affecting approximately 70 countries with reciprocal tariff rates ranging from 10% to 41%, alongside varying country-specific tariffs reaching as high as 40% for Brazil, 35% for Canada, and 25% for India, likely will have a major impact on global supply chains and international commerce.

Continue Reading President Trump Expands Global Reciprocal Tariffs and Imposes Additional Tariffs on Brazil, Canada, and India

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 July 8, 2025, President Trump issued an order (the “Order”) requiring a Chinese company, Suirui Group Co., Ltd., and its Hong Kong subsidiary, Suirui International Co., Limited (collectively, “Suirui”), to divest its interest and rights in Jupiter Systems, LLC (“Jupiter”), a California-based company specializing in video processing technology.

Continue Reading President Trump Issues Order Requiring Chinese Company to Divest Interest in U.S. Video Processing Technology Company

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 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

I. Introduction

    On June 11, 2025, the Council of the European Union (the “Council”) put forward changes[1] to the draft new EU FDI Regulation proposed by the European Commission (the “EC”) in January 2024, following changes put forward by the European Parliament (the “Parliament”) in May 2025.  These proposals will now kick-off trilogue negotiations among the EU institutions with the aim of reaching a political agreement on the final text of the revised regulation in due course.[2]

    Continue Reading The Draft New EU FDI Regulation – The EU Institutional ‘Game Of Thrones’ Continues

    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