As Russian Energy Week concluded last week, Western governments strike to the heart of Russia’s energy sector with sanctions packages to cut of revenue that funds Russia’s continued war against Ukraine. Three significant packages were announced in October 2025: the U.S.’s sanctions targeting the Russian energy sector, the UK’s latest sanctions against the Russian oil industry, and the EU’s 19ᵗʰ package of sanctions.
Continue Reading Striking Russian Oil and The Ripple Effects

On October 17, 2025, the Trump Administration released a significant proclamation imposing new Section 232 duties on medium- and heavy-duty vehicles (MHDVs) (such as trucks); MHDV parts; and buses. These changes further expand tariff coverage over sectors critical to U.S. industrial capacity and national security, and bring a few new complexities to both importers and domestic manufacturers.
Continue Reading Not Only Tariffs on Trucks: Trump Administration’s Proclamation Amends the Tariff Landscape on Automobiles, Steel, and Aluminum

Update (November 2025): BIS suspended implementation of the Affiliates Rule for one year, temporarily reversing the extension of Entity List and MEU-related controls to foreign affiliates that are 50% or more owned by listed entities. In a final rule effective November 10, 2025, BIS stayed the interim rule’s amendments to the EAR until November 9, 2026, absent further extension. During the suspension period, the EAR reverts to the prior “legally distinct” test, meaning foreign affiliates are not automatically covered solely by virtue of 50% ownership. The suspension comes as result of trade negotiations with China, which we discuss our recent…
Continue Reading Not Your Usual Monday: BIS Adopts 50 Percent Rule for Entity List, MEU List & Related EAR Controls

The pace of U.S. regulatory changes regarding Syria continues to increase. Building on our previous posts (“Syria-ous Changes for Middle East Business?” and “Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means”), we describe below the recent developments that have resulted in significant easing of export controls.
Continue Reading Keeping an EAR Out for Syria: BIS Reduces Export Controls

Key Takeaways

• On July 24, 2025, the European Commission opened infringement procedures against 18 Member States for failing to fully transpose Directive (EU) 2024/1226 by the May 20, 2025 deadline.

• The Directive harmonizes criminal offences and penalties for violations of EU sanctions, including asset freeze breaches, arms embargo violations, and circumvention schemes.

• Penalties include prison sentences of up to 5 years for individuals and fines up to 5% of worldwide turnover or EUR 40 million for companies, plus additional restraining measures.

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Continue Reading “Lost in Transposition” – Commission Targets 18 Member States Over Sanctions Enforcement Gaps

On August 7, 2025, President Trump’s reciprocal tariffs fully came into effect. The overall U.S. effective tariff rate has now risen to an estimated 18.6%, which is the highest rate since 1934. Several countries continue to negotiate the applied tariff rates.
Continue Reading Tariff Update: Reciprocal Tariffs and Other Recent Changes

The United States has taken a historic step by terminating the Syria Sanctions Program, marking the most significant shift in U.S. foreign policy towards Syria since the fall of the Assad regime. In our earlier post, we outlined the initial steps taken by the U.S., EU, and UK to relax longstanding sanctions on Syria. Since then, the U.S. has introduced additional measures aimed at promoting commercial re-engagement, although several restrictions remain in place. Companies interested in doing business with Syria must stay current on evolving export control, sanctions, and compliance requirements.
Continue Reading Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means

If the White House wants tariffs, but the courts strike down the Reciprocal Tariffs, what other options are out there?
Continue Reading A Time Machine and a Bag of Hammers: U.S. Tariffs are not Over

In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.
Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria

On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT) unanimously struck down the extensive tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA). The CIT held that the imposition of the tariffs exceeded the authority granted to the President by Congress under IEEPA. The Court issued a permanent injunction blocking the administration from enforcing the IEEPA tariffs, and ordered the administration to issue the necessary administrative orders within 10 days to end them. In response, the government appealed the case to the U.S. Court of Appeals for the Federal Circuit.
Continue Reading Federal Court Strikes Down IEEPA Tariffs

Years ago, when I was a baby lawyer living in a group house in DC, we had a toaster—my toaster. I had owned the toaster since college and it was showing its age. Eventually, you had to hold down the thing[1] to keep the bread lowered in the slots and toasting. But the appliance still heated bread and produced toast. One morning, I became so frustrated with that toaster and the thing-holding-down effort that I threw the toaster out, fully intending to get a new toaster.

The following day, my housemate, we’ll call him Mike,[2] raised an important…
Continue Reading Throwing Away the Toaster: Where AI Controls Are Now and May be Heading

Some importers are finding, to their surprise, that the Trump Administration’s 25% tariffs on aluminum and steel create an exemption from the 125% tariffs on Chinese goods.
Continue Reading Not What You Think: Some Trump Tariffs Exempt Your Goods from Other Trump Tariffs

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III