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BIS Issues One-Year Suspension of Affiliates Rule Expansion

On November 10, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule titled “One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities.” As the title indicates, the final rule formally enacts a one-year suspension of the BIS Affiliates Rule, which had been in … Continue Reading

China Expands Export Control on Rare Earth Minerals and More

On October 9, 2025, China’s Ministry of Commerce (MOFCOM) announced two new decrees (the “New Rules”) significantly expanding and strengthening export controls over the rare earth supply chain: Decree No. 61 primarily targets foreign-made rare earth metals and products, while Decree No. 62 focuses on the control of rare earth-related technology.… Continue Reading

Russia Adopts Fast Track Mechanism for Selling Federal Assets

On September 30, 2025, President Vladimir Putin signed Decree No. 693 “On Certain Particularities of the Sale of Property in Federal Ownership” (here). The measure took effect the moment it was published. The decree is expressly framed as a response to “unfriendly” actions by the United States and its allies. It is adopted “to protect … Continue Reading

A Discussion on 232 Tariff Revisions

Squire Patton Boggs representatives have recently led several discussions with US Customs and Border Protection (CBP) over the current evolution of Section 232 regulations on aluminum and steel. Based on these conversations and our own evaluation of the landscape, we provide the following summation of the 232 regulatory revisions released on June 3, 2025 and … Continue Reading

EU Lifts Key Sanctions on Syria: Legal and Compliance Implications Amid Evolving Opportunities

Earlier this week, the Council of the EU adopted a series of legal instruments giving effect to what had been agreed on 20 May 2025, to significantly reduce sanctions on the Syrian Arab Republic. As a result, all EU economic restrictive measures targeting Syria have been lifted, except for those maintained on specific security-related grounds. … Continue Reading

EU Adopts 17th Sanctions Package Against the Russian Federation: Further Targets the “Shadow Fleet” and Expands Export Controls

On 20 May 2025, the European Council announced its 17th sanctions package against the Russian Federation. The latest measures reinforce the EU’s strategic objective of undermining Russia’s capacity to finance and sustain its war efforts in Ukraine.… Continue Reading

European Commission Previews New Round of Countermeasures Against the United States

In April 2025, the European Union (“EU”) set tariffs on a series of US imports but immediately suspended their application until 14 July 2025. This was due to the US almost simultaneously announcing that it would be softening its across-the-board tariffs. In the case of EU exports, this meant going from a 20% to a … Continue Reading

Committee on Foreign Investment in the US (CFIUS) “Fast-Track” Pilot Program Being Developed

On May 8, 2025, the US Department of the Treasury (Treasury) announced that it “will establish a fast-track process” to facilitate the review by CFIUS of foreign investment into the US from “allies and partners sources . . . where there is verifiable distance and independence from foreign adversaries or threat actors.” The announcement noted … Continue Reading

A Summary of China’s Retaliation Actions Since The Trump Administration

This summary helps to navigate the various retaliation actions China has taken in the past 50 days after President Trump took office on January 20, 2025, to counter the US trade restrictions, including (i) imposing additional tariff on certain US origin products, (ii) adding 12 US companies to the Unreliable Entity List, (iii) control of … Continue Reading

DOJ’S False Claims Act Based Civil Cyber-Fraud Initiative in 2024

The US Department of Justice’s Civil Cyber-Fraud (CCF) Initiative employs the powerful False Claims Act (FCA), with two recent FCA settlements under the CCF Initiative indicating scrutiny on cybersecurity compliance to combat emerging cyber threats.  Whether the CCF Initiative continues in current form, it nonetheless underscores the importance for contractors, subcontractors, grantees, and other forms … Continue Reading

The EU Suspends Certain Sanctions on Syria to Support Economic Stabilisation, Political Transition and Reconstruction

To help the Syrian people achieve a peaceful and inclusive political transition, to aid the swift economic recovery and reconstruction of the country and to facilitate its eventual reincorporation into the global financial system, the EU has suspended with immediate effect a number of sanctions and restrictive measures that had targeted key sectors of the … Continue Reading

Final Rule Implementing ICTS Supply Chain Executive Order 13873 In Effect

On May 15, 2019, President Trump issued Executive Order 13873 – Securing the Information and Communications Technology and Services Supply Chain (“EO” or “EO 13873”). After taking comments on a proposed implementing rule, the Department of Commerce (“DOC” or “Secretary”), on the very eve of the Biden Administration taking office, issued an Interim Final Rule … Continue Reading

Bipartisan Push to Strengthen American Supply Chains

Members of Congress have demonstrated an early bipartisan interest in continuing to promote US supply chain resilience, highlighting an avenue for bipartisanship in the foreign policy agenda of the new Trump Administration. Sen. Marsha Blackburn (R-Tennessee) has partnered with Democratic colleagues on the reintroduction of two pieces of legislation focused on supply chain resilience. Check … Continue Reading

UPDATE: US DOL Order Directing Departments to Cease Enforcement of Affirmative Action Requirements of EO 11246

US government contractors should be aware that following President Trump’s January 21 Executive Order “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” on January 24, acting U.S. Department of Labor (DOL) Secretary Vincent Micone issued an agency Order instructing DOL employees to cease and desist “all investigative and enforcement activity” under Executive Order 11246 (Equal Employment … Continue Reading

New Antidumping and Countervailing Duty Petitions on Temporary Steel Fencing from China

On January 14, 2025, ZND US Inc (Petitioner or ZND), domestic producer of temporary steel fencing, filed petitions with the U.S. Department of Commerce (DOC) and the U.S. International Trade Commission (ITC) seeking the imposition of antidumping duties (AD) and countervailing duties (CVD) on temporary steel fencing from China. Such structures include fencing for construction … Continue Reading

EU Publishes Regulation Banning Products Made With Forced Labour

On 12 December 2024, the Forced Labour Regulation (FLR) was published prohibiting products made with forced labour on the EU market. This is the definitive and legally binding version of the FLR.  As detailed in an earlier client insight, the prohibition on products made with forced labour, as set out in the FLR, and the resulting obligations and associated checks and enforcement, will only enter … Continue Reading

New Antidumping and Countervailing Duty Petitions on Active Anode Materials from China

On December 17, 2024, American Active Anode Material Producers, a trade association consisting of domestic manufacturers of certain active anode materials, filed petitions with the US Department of Commerce (DOC) and the US International Trade Commission (ITC) seeking the imposition of antidumping (AD) and countervailing duties (CVD) on imports of such materials from China. The … Continue Reading

The EU Strengthens Sanctions Against Russia with 15th Package of Restrictive Measures

On 16 December 2024, the European Union (EU) adopted its 15th package of sanctions against Russia in response to its ongoing aggression toward Ukraine. The new measures target key sectors of Russia’s military-industrial complex, including the “shadow fleet” and companies that support this complex. In a significant development, the EU has imposed fully-fledged sanctions – … Continue Reading

Key Updates on the Enhanced Due Diligence and Circumvention Requirements Under Council Regulation 833/2014

On 11 December 2024, the European Commission issued important updates to its Consolidated FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014 (FAQs). These updates cover multiple topics, including due diligence requirements, circumvention and the introduction of a new chapter dedicated specifically to enhanced due diligence for operators involved in … Continue Reading

US Outbound Investment Regulations to Take Effect on January 2, 2025

On October 28, 2024, the Department of the Treasury’s (Treasury) Office of Investment Security issued a final rule[1] (“Final Rule” or “Outbound Investment Regulations”) containing the regulations that will implement, effective on January 2, 2025, an outbound investment regulatory regime that captures certain types of US person-involved investments in, or with, Chinese interests if the … Continue Reading
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