On April 16, 2025, the Department of Commerce announced that it initiated an investigation on April 1, 2025, under Section 232 of the Trade Expansion Act, into imports of semiconductors, semiconductor manufacturing equipment (SME), and related products to evaluate how those imports may impact national security.Continue Reading Who is Stacking the Chips: U.S. Commerce Department Launches Section 232 Investigation into Semiconductor Imports
The U.S. Department of Justice (DOJ)’s new data security rule went into effect April 8, 2025. The rule creates what are effectively export controls and requires companies to take measures to prevent U.S. sensitive personal and government-related data from falling into the hands of foreign adversaries. The rule targets transactions (including data brokerage, vendor agreements, employment agreements, and investment agreements) involving access to bulk sensitive personal data or government-related data when those transactions involve identified covered persons or countries of concern (China, Russia, Iran, North Korea, Cuba, and Venezuela). Continue Reading DOJ Announces 90-Day Grace Period for Companies to Comply with New Data Security Rules on Foreign Adversary Access to U.S. Sensitive Data
In the context of the tariffs imposed by the Trump Administration on imported goods, a prevalent misconception has arisen that foreign suppliers automatically bear the cost of these tariffs. The reality, however, is more complex. The actual payment of tariffs is significantly influenced by the specific contractual agreements between U.S. buyers and their foreign suppliers.Continue Reading Understanding the Allocation of Tariff Payments
On April 2, President Trump issued an Executive Order (EO) imposing global reciprocal tariffs (White House Fact Sheet). The EO drew enough parallels to the Smoot-Hawley Tariff Act that Trump mentioned it in his Rose Garden announcement. The EO imposes a 10% baseline tariff on all imports to the United States beginning April 3, 2025.Continue Reading Blockading the Ports: U.S. Imposes 10% Global Tariff; Higher Reciprocal Tariff Rates by Country
UPDATE: On February 5, 2025, the Trump administration issued an executive order delaying the cancellation of de minimis until “adequate systems are in place to fully and expediently process and collect tariff revenue applicable”. Imports from China below the value of $800 will generally not be subject to the 10% tariff or Section 301 duties.Continue Reading The First Wave: U.S. Imposes Tariffs on Canada (or not?), Mexico (or not?), and China (well, yeah, probably so)
With President Donald Trump commencing his second term, significant changes are anticipated across global industries. His series of sweeping executive actions have already sparked pushback and legal challenges.Continue Reading Tracking the New Administration’s Executive Actions Changes
Tariffs remain the focus of the incoming Trump Administration. Over the past several months, the announcements from president-elect Trump and his transition team have been dynamic. We expect the Trump trade policy team to use creative methods to deliver aggressive new tariff policies this year.Continue Reading Trump Tariffs Survival Guide: 10 Strategies for U.S. Importers
The wine industry faced significant challenges due to tariffs imposed by President Trump’s first administration. During the presidential campaign, and since his election on November 5, 2024, President Trump has made it clear that he will enact higher tariffs as a key part of the political agenda of his second administration. A few days ago, he nominated Jamieson Greer as his pick for U.S. Trade Representative as the nation’s top trade official, who served as chief of staff to Robert Lighthizer, then U.S. Trade Representative during Trump’s first term; if confirmed by the U.S. Senate, Mr. Greer is expected “to pursue an ambitious trade agenda.” This post highlights the history of Trump’s tariffs on wine, their effects, and what might be expected in his new term.Continue Reading The Impact of Trump’s Tariffs on the Wine Industry: Past and Future
On December 2, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) issued a new set of regulations targeting semiconductors manufacturing equipment (SME) and high-bandwidth memory (HBM) chips. The updates are a part of BIS’s ongoing efforts to target semiconductors in attempt to slow down China’s advancement of AI. In the race to artificial general intelligence, advanced-node semiconductors play an outsized role in a country or company’s ability to progress.Continue Reading The Persistence of (High Bandwidth) Memory: Semiconductor Manufacturing Equipment and Korean Semiconductor Manufactures Face Harsher Restrictions Under New HBM Rules
You have always dreamed of going to space. All of us have at some point or another. And the only thing standing between you and that dream were overly-restrictive commodity and technology export licensing requirements on certain space items to specified countries! (well, that, and gravity, and the fact that you are not a billionaire[1], and maybe a few other things).Continue Reading Ticket to Ride – The Commercial Space Activity Exception and Space Tourism: Reduced Export Controls Ease Cross-Border Collaborations (Part IV of IV)
On October 29, 2024, the Department of Justice (DOJ) published its Proposed Rule outlining prohibitions and restrictions on certain transactions involving bulk U.S. sensitive personal data and U.S. Government-related data. As you may recall from our previous article, this rule stems from recent Executive Order (EO) 14117 on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” The Proposed Rule has potential implications for any business that collects, retains, or deals in data on U.S. persons or certain other data relating to the U.S. Government. Here, we discuss some of the more interesting developments in the Proposed Rule and how it could affect your business.Continue Reading Data, Deals, and Diplomacy, Part II: Big Obligations for Big Data