2025

On 7 October 2025, the European Commission presented a proposal for a new regulation to introduce rigorous trade measures on steel entering the EU market. The proposal is subject to the ordinary legislative procedure, under which the European Parliament and the Council act as co‑legislators to amend and ultimately adopt the text. We therefore expect…

The distinctive features that set a luxury brand’s products apart aren’t created only on the factory floor. For example, a company’s sketches from Paris, R&D in Milan, and artisanal prototypes perfected in Tokyo all flow into the production line. These upstream inputs (known as assists) must be carefully managed to avoid issues when the final…

On September 29, the Bureau of Industry and Security (BIS) released an interim final rule expanding its controls under the Export Administration Regulations (EAR) to cover foreign entities owned directly or indirectly, individually or in aggregate, 50% or more by one or more persons listed on (1) the Entity List, (2) the Military End-User (MEU) List, or (3) the Specially Designated Nationals and Blocked Persons List (SDN List) designated under a program listed in 15 C.F.R. § 744.8(a)(1) (collectively, “Listed Persons”). BIS is referring to these new controls as the Affiliates Rule.

Exports, reexports, and transfers (in-country) to foreign entities captured by the Affiliates Rule will be subject to the most restrictive license requirements, license exception eligibility, and license review policy applicable to their owners. The Affiliates Rule is effective immediately.

Continue Reading BIS adopts 50% rule to cover affiliates of listed entities

With tariffs and trade measures continuing to reshape global markets, companies are navigating how best to respond, often considering price and supply chain adjustments as part of the process. As antitrust enforcers scrutinize competitor conduct, our antitrust and international trade teams have collaborated to launch a two-part podcast series, focusing on the practical impact of…

Tonzip Maritime Ltd v. 2Rivers Pte Ltd (formerly Coral Energy Pte Ltd) [2025] EWHC 2036 (Comm)

A. Key facts

On 5 November 2021, Tonzip Maritime Ltd (Owners), owner of the vessel CATALAN SEA (the Vessel), entered into a voyage charterparty with 2Rivers Pte Ltd (formerly Coral Energy Pte Ltd) (2Rivers) for the carriage of oil from Primorsk, Russia, to Aliaga, Turkey (the Charterparty).

Continue Reading Refusing voyage orders: Sanctions risk assessments must be based on evidence, not speculation

On August 6, 2025, the Committee on Foreign Investment in the United States (CFIUS) released its annual report to Congress for calendar year 2024. This annual publication includes the 325 covered transactions—consisting of 209 written notices and 116 declarations—that were filed for CFIUS’s review last year.

CFIUS is an interagency committee authorized to review…

On 18 July 2025, the EU announced the 18th sanctions package against Russia and Belarus. The legislative texts were published on 19 July 2025. As of this date, the latest restrictions indicate a misalignment between the EU / UK, and other G7 members, including the United States.

Continue Reading EU-nough Russian Oil – EU’s 18th Sanctions Package

The Department of Justice (DOJ) is reshaping the Criminal Division’s white-collar program to focus on tariff and trade fraud. In the past months, DOJ has significantly narrowed the scope of Foreign Corrupt Practices Act enforcement. Now, DOJ is dedicating significant additional resources and attention to tariff evasion. On July 10, acting Assistant Attorney General of…

  • On July 8, 2025, President Trump indicated that the United States would impose 50% tariffs on copper imports. The tariffs are expected to be imposed by end of July or start of August.
  • In response to the threat of tariffs, the global copper market has experienced significant change, as traders and end users
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