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Global Trade & Sanctions Law

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Trump 2.0: U.S. Tariffs on China Take Effect; Mexico and Canada Granted 30-Day Pause

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…

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Trump 2.0: U.S. Imposes Tariffs on Key Trading Partners 

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.…

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Trump 2.0: America First Trade Policy Takes Shape

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,…

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BIS Issues Interim Final Rule Establishing a Framework for Artificial Intelligence Diffusion

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…

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BIS Issues Interim Final Rule on Advanced Computing Integrated Circuits, Providing Long-Awaited Guidance on Due Diligence Procedures

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…

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EU Calls On Member States to Review Outbound Investments in Critical Technologies

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…

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Framework for Collaboration Between U.S. and UK Sanctions Authorities  

Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024, formalizing a framework to govern cooperation including in relation to exchanging information, coordinating investigations, training personnel,…

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EU Sanctions Update: The 15th Russia Package Amongst Other Updates

On December 16, 2024, the EU issued its 15th package of sanctions against Russia, new designations under the Belarus sanctions regime, and the first designations under the hybrid threats sanctions regime adopted in October 2024. These updates are summarized below. 1. Asset Freeze Measures Russia (Regulation 269/2014) New designations: 54…

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The Treasury Department Finalizes U.S. Outbound Investment Rules

Colleagues Nancy A. Fischer, Matthew R. Rabinowitz, Zachary C. Rozen, Samantha Franks, Erin Kwiatkowski and Marcus Burden recently broke down the key points of a U.S. Department of the Treasury Final Rule that establishes significant new parameters for U.S. outbound investments in sensitive technologies within countries of concern. TAKEAWAYS The Final Rule formalizes a…

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BIS Proposes Rules to Protect from Chinese and Russian Connected Vehicle Technology

On September 23, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released for public inspection a Notice of Proposed Rulemaking that seeks to prohibit the sale or import of connected vehicles (CVs) with certain hardware and software that have a sufficient nexus to the People’s Republic of…