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
national security
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 –…
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…
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Recent activity in the EU around tariffs on Ukrainian and Russian grain imports
Background
Russia’s military action against Ukraine has had a profound impact on Ukraine’s ability to trade with the rest of the world. Under such exceptional circumstances and to mitigate the negative economic impact of Russia’s aggression on Ukraine, the EU decided in May 2023 to grant sweeping concessions to Ukraine in the form of trade-liberalisation…

The EU is ready to introduce mandatory supply chain due diligence obligations under CS3D
On 14 December 2023, the two EU co-legislators, the Council of the EU and the European Parliament, provisionally reached an agreement on the Corporate Sustainability Due Diligence Directive (CS3D). In essence, the Directive sets out an obligation for companies to comply with human rights and environmental due diligence and provides for an enforcement mechanism with…

Decarbonizing across borders: Navigating CCUS in the U.S. and the EU’s CBAM
At the forefront of addressing the global challenge of climate change is the effort to reduce carbon.
In their latest podcast, Pittsburgh’s energy transactional partner, Ryan Haddad and Brussels’ international trade and customs partner, Yves Melin explore how Carbon capture, utilization, and sequestration (CCUS) and the Carbon Border Adjustment Mechanism (CBAM) could interact in the…

EU CBAM Implementing Regulation on the reporting obligations has been officially published
With less than two weeks until the start of the Carbon Border Adjustment Mechanism (CBAM) transitional period (1 October 2023 – 31 December 2025), the European Commission published the CBAM Implementing Regulation on the reporting obligations in the Official Journal of the European Union on 15 September 2023. During the transitional period, declarants are required…

All eyes on the EU’s anti-subsidy investigation on Chinese electric vehicles: Candidate for first parallel market investigation under the EU’s FSR?
On 13 September 2023, European Commission President Ursula von der Leyen announced in her annual State of the Union Address that the European Commission (Commission) will launch an anti-subsidy investigation into Chinese subsidies to electric vehicle (EV) makers in China under EU trade rules. The Commission’s concern is that “global markets are now flooded with…

The President of the European Commission announces an anti-subsidy investigation on Chinese electric vehicles
During her annual State of the European Union speech on 13 September 2023, the President of the European Commission, Ursula von der Leyen, announced that “the Commission is launching an anti-subsidy investigation into electric vehicles coming from China.” An anti-subsidy measure (i.e., countervailing duties) is one of the trade defence instruments that a World Trade…