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
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
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
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
Federal court permanently enjoins “fentanyl” and reciprocal tariffs; Trump requests stay
Update: On May 29, the Court of Appeals for the Federal Circuit issued an immediate administrative stay of the CIT’s judgment and injunction. The plaintiffs-appellees will have until June 5 to respond to the government’s motion for a stay. The government will have until June 9 to file a reply brief. The Federal Circuit will
U.S. eases Syrian sanctions; export controls remain unchanged
On May 23, the Office of Foreign Assets Control (OFAC) issued Syria General License 25, which authorizes a significant portion of previously prohibited transactions. The general license does not, however, amend or modify any of the existing Syria-related export controls under the International Traffic in Arms Regulations or Export Administration Regulations.
What does the
BIS plans to rescind Biden-era AI diffusion rule; imposes other controls on AI chips
On May 13, 2025, the Bureau of Industry and Security (BIS) announced its intent to rescind the Biden administration’s Framework for Artificial Intelligence Diffusion (AI Diffusion Rule) that is scheduled to go into effect on May 15. BIS will publish a Federal Register notice formalizing its decision. In the meantime, Under Secretary of Commerce for
USTR imposes fees and restrictions on certain maritime transport services
On April 17, 2025, the U.S. Trade Representative (USTR) announced a series of fees and restrictions intended to address China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance. The announcement follows the USTR’s year-long investigation into China’s acts, policies, and practices under Section 301 of the Trade Act of 1974.
Maritime transport services
U.S. imposes 10% baseline tariffs; higher reciprocal tariffs for targeted countries
Updated: April 3, 2025 at 3:30 p.m. ET to reflect the specific exemptions outlined in the unofficial version of the Harmonized Tariff Schedule of the United States (HTSUS) modifications that will implement the reciprocal tariffs.
On April 2, President Trump signed a pair of executive orders as part of a “Liberation Day” ceremony in the