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On February 24, 2025, the EU adopted its 16th package of sanctions against Russia, Belarus and non-government-controlled areas of Ukraine, symbolically marking the third anniversary of the start of Russia’s invasion of Ukraine and constituting the largest set of updates that we have seen in the past two years. On the same day, the UK also issued new designations under its Russia sanctions regime impacting 107 entities, individuals and ships. See a summary of the updates below.

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Between March 4, 2025 and March 6, 2025, U.S. trade policy in North America changed course multiple times as the Trump Administration initially implemented previously-paused tariffs on imports from Canada and Mexico, and two days later, suspended tariffs on all Canadian and Mexican imports that meet the rules of origin for preferential tariff treatment of the United States-Mexico-Canada Agreement (USMCA). The Trump Administration also increased across-the-board tariffs on imports from China to 20%, which remain in place.  These measures, introduced through a novel use of the International Emergency Economic Powers Act (IEEPA), come after an initial 30-day delay in imposing tariffs on the North American trading partners on February 3, 2025.   Continue reading →

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Following days of speculation, President Donald Trump announced on February 13, 2025, a new tariff policy outlined in a Presidential Memorandum entitled the “Fair and Reciprocal Plan” (Plan).  The Memorandum directs key trade and economic U.S. government agencies to take action against trading partners that impose tariffs, taxes, non-tariff barriers (NTBs), or other restrictions on U.S. goods and services. At this time, no new tariffs have been implemented.

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On February 10, 2025, President Trump issued two Presidential Proclamations reimposing and expanding tariffs on all steel and aluminum imports into the United States pursuant to Section 232 of the Trade Adjustment Act of 1962. These measures effectively supersede prior alternative arrangements, including tariff-rate quotas (TRQs) negotiated with key U.S. trading partners such as the European Union (EU), the United Kingdom (UK), Japan and others, while also revoking country-specific exemptions previously granted to Canada and Mexico. The Proclamations represent a substantial escalation of U.S. trade policy in the metals sector and reaffirm the national security rationale that underpinned the original Section 232 tariffs imposed in 2018.

 

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Following President Trump’s February 1, 2025, announcement of a sweeping set of tariffs on imports from Canada, Mexico, and China, citing immigration concerns and the flow of fentanyl, trade tensions have lurched unpredictably between escalation and temporary resolution. While negotiations between heads of state on February 3, 2025, led to a 30-day pause on both U.S. tariffs for Canada and Mexico and parallel retaliatory measures, the 10% tariff on imports from China took effect at 12:01 a.m. on February 4, 2025. 

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After months of anticipation, on February 1, 2025, President Trump announced the imposition of significant tariffs on Mexico, Canada, and China through three Executive Orders (EOs). While additional details are expected to be published in the Federal Register in days to come, the tariffs mark a significant shift in U.S. trade policy. At this time, negotiations appear underway between the United States, Mexico, and Canada relating to the timing of the tariffs. 

Key points are outlined below.  

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On January 20, 2025, Donald J. Trump was inaugurated as the 47th President of the United States. Within hours of taking office, President Trump issued dozens of executive orders and an “America First Trade Policy” memorandum outlining his administration’s trade priorities and signaling an aggressive approach to reshaping U.S. trade, sanctions and national security policies. However, “Day 1” tariffs did not materialize despite previous announcements by President Trump that China, Canada and Mexico would be targeted. President Trump has informally suggested that 25% tariffs for Mexico and Canada and an additional 10% tariff for China remain possible by February 1, 2025.

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On January 13, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule (IFR), establishing new export controls targeting advanced artificial intelligence (AI) chips and model weights for advanced AI models to protect against national security risks associated with AI while promoting American AI technological leadership. This framework is a tailored strategic initiative designed to regulate the spread of advanced AI models and prevent their access by malicious actors. It enables “secure and responsible foreign entities and destinations” to utilize leading U.S. AI models and the powerful IC clusters needed for their training. Entities that do not comply with established safety and security protocols will not be granted access.

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On January 15, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) updating export controls on advanced computing semiconductors. This IFR seeks to ensure that customers of “front-end fabricators” and Outsourced Semiconductor Assembly and Test (OSAT) companies cannot evade controls on advanced computing ICs by misrepresenting the performance capabilities of their integrated circuit (IC) designs.

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On January 16, 2025, the European Commission issued a recommendation encouraging EU Member States to begin reviewing outbound investments in critical technologies including AI, semiconductors and quantum technologies to assess whether such transactions pose risks to EU economic security (the “Recommendation”). The Recommendation constitutes a call for Member States to establish or adapt existing investment screening mechanisms in consultation with relevant stakeholders. The  underlying objectives of the Recommendation are to: (i) ensure the protection of home-grown EU technologies that could bolster military or intelligence capabilities of adversarial states; and (ii) foster a fact-based understanding of the risks posed by outbound investments.

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