According to President Trump, “Tariff is the most beautiful word in the dictionary.” Throughout his presidential campaign, Trump promised to use tariffs as a central part of his foreign policy strategy. His America First Trade Policy memorandum also directs the administration to review various tariff- and tariff-adjacent levers the United States could use to further
Tariff mitigation through alternative sourcing: Navigating customs country of origin compliance risks
In a time of escalating tariff tensions, companies are investing heavily in analyzing the impact of tariff changes on their business and adapting to the shifting trade landscape. To mitigate tariff impacts and maintain competitiveness, many explore supply chain adjustments, such as alternative sourcing or relocating production. While “tariff engineering” is becoming an increasingly popular
False Claims Act: 2024 enforcement trends and what to expect in 2025
In 2024, the Department of Justice saw a record number of qui tam actions under the False Claims Act (FCA), with total settlements and judgments exceeding $2.9 billion. Throughout this next year, we expect to see this uptick in enforcement continue, especially in light of the Trump administration’s crackdown on diversity, equity, and inclusion policies
Trump adjusts steel and aluminum tariffs; directs Customs to increase enforcement
On February 10, President Trump signed two proclamations adjusting the already-existing Section 232 tariffs on imports of steel and aluminum. He also directed U.S. Customs and Border Protection (CBP) to “dramatically increase” its enforcement efforts to prevent circumvention.
Increased tariff enforcement
The proclamations direct CBP to prioritize reviews of the classification of imported steel and
U.S. imposes tariffs on Canada, China, and Mexico; retaliation promised
Update: After a February 3 call with Mexico’s president, President Trump announced on Truth Social that the tariffs on Mexican goods will be paused for one month. He is also scheduled to speak with Prime Minister Trudeau, which could result in the Canadian tariffs being paused. More details to come.
Key takeaways
- U.S. imposes tariffs
Navigating the FY 2025 NDAA: Impact on U.S. government contracting
On December 23, 2024, President Biden signed The National Defense Authorization Act (NDAA) for Fiscal Year 2025 (P.L. 118-159) into law. The legislation authorizes $895.2 billion in funding for Department of Defense (DoD) and Department of Energy (DOE) national security programs. Beyond authorizing spending and setting other priorities, NDAA introduces a range of provisions –
DHS expands UFLPA Entity List by over one-third
Effective January 15, the Department of Homeland Security (DHS) added 37 China-based companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, marking the single largest expansion of the UFLPA Entity List since its creation in 2022. Included in the additions is a large supplier of critical minerals, as well as one of
U.S. tightens controls on advanced computing chips and global AI diffusion
On January 13, the Bureau of Industry and Security (BIS) released an interim final rule to revise U.S. export controls on advanced computing integrated circuits (ICs) and add a new control on artificial intelligence (AI) model weights for certain advanced, closed-weight, dual-use AI models. According to news reports, Biden administration officials have indicated that they
Federal judge halts enforcement of Arkansas’s foreign land ownership laws
On December 9, 2024, the U.S. District Court for the Eastern District of Arkansas (the Court) issued a preliminary injunction enjoining Arkansas’s enforcement of Acts 636 and 174 (the Acts), which impose certain restrictions on foreign ownership of land and digital asset mining businesses in Arkansas. The Court’s decision addresses concerns a crypto mining company
Treasury Department issues final rule creating U.S. outbound investment security program
On October 28, 2024, the U.S. Department of the Treasury issued its long-awaited final rule (Final Rule) implementing an outbound investment security program. Stemming from Executive Order 14105 (Outbound Order), the new program targets U.S. investment in China, Hong Kong, and Macau related to a defined set of technologies and products that pose