If the White House wants tariffs, but the courts strike down the Reciprocal Tariffs, what other options are out there?Continue Reading A Time Machine and a Bag of Hammers: U.S. Tariffs are not Over

Timely Updates and Analysis on Key International Trade Law Issues
If the White House wants tariffs, but the courts strike down the Reciprocal Tariffs, what other options are out there?Continue Reading A Time Machine and a Bag of Hammers: U.S. Tariffs are not Over
In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria
On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT) unanimously struck down the extensive tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA). The CIT held that the imposition of the tariffs exceeded the authority granted to the President by Congress under IEEPA. The Court issued a permanent injunction blocking the administration from enforcing the IEEPA tariffs, and ordered the administration to issue the necessary administrative orders within 10 days to end them. In response, the government appealed the case to the U.S. Court of Appeals for the Federal Circuit.Continue Reading Federal Court Strikes Down IEEPA Tariffs
Recently, the Texas House of Representatives introduced HB 5007, along with its companion bill SB 2117. The legislation—“Relating to the establishment of the Texas Committee on Foreign Investment to review certain transactions involving certain foreign entities; creating a civil penalty”—is currently under committee review. If enacted, the Lone Star State would become the first state to establish its own interagency committee to screen foreign investments, modeled in part on the federal Committee on Foreign Investment in the United States (CFIUS).Continue Reading Big State, Big Scrutiny: Texas Steps into the Foreign Investment Review Arena
A serious step up in civil and criminal enforcement of customs laws, including tariff evasion, is imminent. In a May 12 memorandum, the Department of Justice’s new Chief of the Criminal Division, Matthew Galeotti, counted as one of the “most urgent” threats to the country “[t]rade and customs fraud, including tariff evasion.” Earlier in the Administration, in a February 2025 speech, Michael Granston, Deputy Assistant Attorney General for the DOJ’s Commercial Litigation Branch identified, as a key example of new enforcement activity, efforts to enforce payment of customs duties on imported goods and reiterated that enforcement against “illegal foreign trade practices” would be a priority for the Administration. Continue Reading Department of Justice Tariff Enforcement Likely to Surge After Tariff Increases and the Administration’s Increased Focus on Protecting Domestic Business
Years ago, when I was a baby lawyer living in a group house in DC, we had a toaster—my toaster. I had owned the toaster…
Continue Reading Throwing Away the Toaster: Where AI Controls Are Now and May be HeadingThis week, underscoring a commitment to national security, the White House and the Food and Drug Administration (FDA) issued separate communications that aim to bolster domestic drug manufacturing while tightening oversight of foreign facilities. But they also raise questions about implementation, industry impact, and long-term effects. This is another step from the Department of Commerce Bureau of Industry and Security’s (BIS) Section 232 investigation into pharmaceuticals initiated on April 1, 2025. These developments, while unsurprising, should be viewed within the constellation of broader administration policy, and could make real progress on furthering the manufacturing onshoring agenda for the critical life sciences industry.Continue Reading Onshoring Pharma Ops: Reading Recent EO and Policy Tea Leaves
Some importers are finding, to their surprise, that the Trump Administration’s 25% tariffs on aluminum and steel create an exemption from the 125% tariffs on Chinese goods.Continue Reading Not What You Think: Some Trump Tariffs Exempt Your Goods from Other Trump Tariffs
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III
The implementation of new 25% Section 232 duties on steel, aluminum, and certain derivatives, effective March 12, 2025, which are in addition to any special rate of duty otherwise applicable, are affecting importers globally. Here is a breakdown of what these new tariffs entail:Continue Reading Overview of Section 232 Tariffs on Steel and Aluminum: What Importers Need to Know
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II
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