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
Navigating international trade: why developing a global customs valuation policy is a must for luxury brands
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
BIS adopts 50% rule to cover affiliates of listed entities
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
Antitrust considerations amid shifting tariffs
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
BIS relaxes export controls on Syria
- New License
CFIUS annual report for 2024: Key takeaways
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
DOJ dedicates significant resources to priority of investigating and prosecuting tariff evasion
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
Potential U.S. tariffs on copper imports and the ‘short squeeze’: Legal considerations for physical sale and purchase contracts
- 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
U.S. Moves to Ban Foreign Adversary Purchases or Control of Farmland and Launches National Farm Security Action Plan
On July 8, 2025, the U.S. Department of Agriculture (USDA) announced the National Farm Security Action Plan (Action Plan), a sweeping initiative to protect American agriculture as a matter of national security. Among its most consequential provisions are forthcoming restrictions on foreign adversaries (e.g., China) from purchasing or controlling U.S. farmland. Highlights of the Action
Key customs and trade considerations for data centers
As global trade barriers rise and regulatory frameworks grow more complex, data centers must implement robust legal strategies to address customs valuation, origin rules, import/export controls, and maintenance-related trade challenges.
In a recent post, published as part of our Data Centers: Bytes and Rights series, we highlight and examine five key compliance areas that