The Month in International Trade – February 2025
Client Alert | 13 min read | 03.07.25
Top Trade Developments
- Coalition of the Willing: EU and UK, but not the US, Impose Russia Sanctions
- President Trump Announces America First Investment Policy
- USTR Proposes Actions, Requests Comments on China’s Maritime, Logistics, and Shipbuilding Sectors
- Cartels, Foreign Terrorist Organizations, and the High Stakes for Business
- China Technology Transfer Control Act Introduced to Strengthen Export Controls vis-à-vis China
- EU-US Steel Agreement Suspending Tariffs Expires on March 31, 2025, EU Tariffs May Resume and Other Products are Affected
- White House Updates Section 232 Tariffs on Steel, Aluminum
- White House Amends Feb 1st Executive Order, Temporarily Reinstates De Minimis Eligibility for China-Origin Goods
- “Maximum Pressure” on Iran is Back: What This Means for Sanctions and Export Controls
Crowell Speaks
This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Jana del-Cerro, Anand Sithian, or Simeon Yerokun or any member of the International Trade Group.
Top Trade Developments
Coalition of the Willing: EU and UK, but not the US, Impose Russia Sanctions
As they have on each previous anniversary, the EU and UK released new sanctions against Russia on February 24, 2025, to mark the three-year anniversary of Russia’s full-scale invasion of Ukraine. For the first time, the United States did not do the same, electing to issue a limited set of Iran-related sanctions on the anniversary instead. The EU package was more fulsome than the UK package, including new port and airport restrictions, additional trade restrictions (including an aluminium ban), enhanced military end-user restrictions, and additional asset freezes and vessel designations.
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For more information, contact: Sophie Davis, Vassilis Akritidis, Nicola Phillips, Dj Wolff, Carlton Greene
President Trump Announces America First Investment Policy
On February 21, 2025, President Trump issued a National Security Policy Memorandum (“NSPM”) announcing the Administration’s “America First Investment Policy” (the “Investment Policy”) affirming the United States’ commitment to open investment while safeguarding national security. Aimed at promoting investment in the United States from allied countries while imposing stricter measures on both inbound and outbound investments from “foreign adversaries,” the Investment Policy incentivizes foreign investment in the United States by announcing a “fast track” process “to facilitate greater investment from specified allied and partner sources in United States businesses involved with United States advanced technology and other important areas.” The NSPM defines “foreign adversaries” to include the People’s Republic of China (the “PRC” or “China”), including Hong Kong and Macau, Cuba, Iran, North Korea, Russia, and the Maduro regime in Venezuela.
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For more information, contact: Caroline Brown, Addie Cliffe, Nimrah Najeeb, Riley Delfeld, Dilan Wickrema
USTR Proposes Actions, Requests Comments on China’s Maritime, Logistics, and Shipbuilding Sectors
On February 21, 2025, the Office of the United States Trade Representative (USTR) announced its proposed actions following the Section 301 investigation of China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance.
The Section 301 investigation was initiated on April 17, 2024. Following the investigation, USTR determined that China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance is unreasonable and burdens U.S. commerce, in part because it displaces foreign firms and restricts business opportunities in the U.S.
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For more information, contact: Dan Cannistra, Jasmine Masri, Ivy Xun
Cartels, Foreign Terrorist Organizations, and the High Stakes for Business
The new Trump administration is focusing intensely on “cartels” and other transnational criminal organizations, particularly in the Western Hemisphere. Many of the entities designated as FTOs today are active in Latin America and the United States and sometimes seek to extort money or have other dealings with legitimate businesses operating in their territories. The State Department’s designation of eight such entities will not only raise the pressure on the entities designated but also will create new risks and pressures for companies operating in areas where these FTOs are active. Below, we summarize the recent developments and the ramifications of these designations for businesses.
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For more information, contact: Erik Woodhouse, Carlton Greene, Alexander Kramer, Jeremy Iloulian, Laurel Saito
China Technology Transfer Control Act Introduced to Strengthen Export Controls vis-à-vis China
On February 7, 2025, Representative Mark Green (R-TN-7) introduced the China Technology Transfer Control Act, a bill which would restrict the export to the People’s Republic of China (“PRC”) certain “national interest technology” and intellectual property. According to a statement by Rep. Green, the bill is intended as a sign to “get serious about protecting our sensitive technologies and to impose severe costs when China uses our technology for malign purposes,” citing Tiktok, DeepSeek, and RedNote (also known as Xiaohongshu) as recent examples of malign Chinese influence on U.S. national and economic security.
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For more information, contact: Jana del-Cerro, Jeremy Iloulian, Andrew Schlegel
EU-US Steel Agreement Suspending Tariffs Expires on March 31, 2025, EU Tariffs May Resume and Other Products are Affected
On February 10, 2025, President Trump signed a new Proclamation abolishing as of March 12, 2025 the quota system for the EU and imposing 25% tariffs on all steel products imported into the U.S.. This effectively puts the end to current agreement between the U.S. and the EU which kept the tariffs on steel and aluminum at bay on both sides of the Atlantic for past years.
The EU immediately announced that this U.S. action will trigger firm and proportionate countermeasures. EU Trade Ministers are expected to convene on February 12, 2025, to prepare a coordinated response.
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For more information, contact: Dan Cannistra, Maria Krestiyanova
White House Updates Section 232 Tariffs on Steel, Aluminum
On February 10, 2025, the White House released an executive order (“EO” or “Order”) titled “Adjusting Imports of Steel into the United States” that reinstates a 25% tariff on imports of steel and steel derivative products into the United States. The administration has also previewed a parallel executive order on aluminum and aluminum derivative product imports.
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For more information, contact: John Brew, Dan Cannistra, Weronika Bukowski, Valerie Ellis, Emily Devereaux, Andrew Schlegel
White House Amends Feb 1st Executive Order, Temporarily Reinstates De Minimis Eligibility for China-Origin Goods
On February 5, 2025, the White House issued an amendment to an Executive Order (“EO”) issued by President Trump on February 1, titled “Imposing Duties to Address the Synthetic Opioid Supply Chain in the People’s Republic of China.” The amendment states that “de minimis treatment under 19 U.S.C. 1321 is available for otherwise eligible covered articles…but shall cease to be available for such articles upon notification by the Secretary of Commerce to the President that adequate systems are in place to fully and expediently process and collect tariff revenue” on said articles. While this amendment is a significant departure from the original text of the Order, which stated that “de minimis treatment…shall not be available” for any goods of Chinese origin, the amendment does not provide an estimated timeframe for the duration of de minimis reinstatement.
For more information, contact: John Brew, Andrew Schlegel
“Maximum Pressure” on Iran is Back: What This Means for Sanctions and Export Controls
On February 4, 2025, President Trump issued a National Security Presidential Memorandum (NSPM-2) on “Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran’s Malign Influence.” NSPM-2 directs U.S. government agencies to take a range of measures to reimpose “maximum pressure” sanctions on Iran.
However, alongside NSPM-2, the President also commented that he remains interested in a “verified nuclear peace agreement” that would allow Iran to “peacefully grow and prosper,” and that he hopes “we’re not going to have to use it very much,” referring to NSPM-2. Ultimately, the impact of NSPM-2 will depend on how fully it is implemented and how these differing goals interact in the coming months.
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For more information, contact: David (Dj) Wolff, Carlton Greene, Erik Woodhouse, Jana del-Cerro, Anand Sithian, and Jeremy Iloulian
Crowell Speaks
19th Annual Flagship Economic Sanctions Enforcement and Compliance
The National Press Club, Washington, DC (May 1, 2025)
Speaker: Erik Woodhouse
“Trump 2.0: Overview of National Security Trade Controls”
RFG Webinar (March 19, 2025)
Speaker: Erik Woodhouse
“ESG & Sustainability: New Risks, New Opportunities, and New Government Priorities”
Crowell and Moring Webinar (March 18, 2025)
Speaker: Jean-Baptiste Blancardi
“Advanced Anti-forced Labor Best Practices"
2025 International Compliance Professionals Association (ICPA) Annual Conference, Orlando, FL (March 10, 2025)
Speaker: Simeon Yerokun
“Conducting and Surviving Investigations”
2025 International Compliance Professionals Association (ICPA) Annual Conference, Orlando, FL (March 12, 2025)
Speaker: Derek Hahn
“Your Building Blocks for Economic Sanctions Proficiency”
ACI Webinar (March 6, 2025)
Speaker: Dj Wolff
“Navigating U.S. Trade Policy for Luxury Brands Now and Tomorrow”
Crowell Atelier: Networking Breakfast for Luxury Clients (March 5, 2025)
Speaker: Maria Vanikiotis
“Tariffs & Trade in the Trump Administration: Adding Value to Your Supply Chain”
Crowell & Moring 11th Annual In-House Recovery Conference, Dana Point, CA (March 4, 2025)
Speakers: Erik Woodhouse, Weronika Bukowski
“The Trump 2.0 Administration Trade Agenda and Congress in 2025”
Crowell & Moring 11th Annual In-House Recovery Conference, Dana Point, CA (March 4, 2025)
Speakers: Monica Gorman, Aaron Cummings
“National Security Law and Business”
Duke’s Center of Law, Ethics, and National Security (LENS) 30th Annual National Security Law Conference, Duke Law School, Durham, NC (February 28, 2025)
Panelist: Caroline Brown
Fordham Law School Sanctions Symposium
New York City, NY (February 21, 2025)
Speaker: Erik Woodhouse
New Tariffs and Trump Trade Policy
February 11, 2025 – WNYC The Brian Lehrer Show
Related Professionals: Monica Gorman
Trump Tariff Uncertainty Puts Businesses In a Bind
February 11, 2025 – SupplyChainBrain
Related Professionals: Dan Cannistra
“Trump Administration and Trade: Sanctions, Export Controls, Investment Restrictions, and Global Mobility”
Crowell and Moring Webinar (February 11, 2025)
Speakers: Erik Woodhouse, Caroline Brown, Jana del-Cerro, Nicole Simonian
EU prepares to use instrument against Trump’s trade blackmail and ‘techno-caste’
February 8, 2025 – El Diario
Related Professionals: Vassilis Akritidis, Jean-Baptiste Blancardi
Donald Trump’s Tariffs, Explained
February 7, 2025 – The Verge
Related Professionals: Monica Gorman
Trump’s Tariff Moves Put Energy Cos. In Scramble Mode
February 7, 2025 – Law360
Related Professionals: Evan Chuck, Aaron Cummings
How Trump’s Tariffs Against China And Possible Tariffs On Mexico And Canada Could Affect Americans (video clip)
February 6, 2025 – Forbes
Related Professionals: Monica Gorman
“Trump Administration and Trade: Tariffs and Customs”
Crowell and Moring Webinar (February 4, 2025)
Speakers: David Stepp, Dan Cannistra, John Brew, Evan Chuck, Aaron Cummings, Weronika Bukowski
“Anti-Boycott and 15 CFR Part 760 of the EAR: Clarifying the Six Prohibitions, Required Reports and Compliance Expectations”
ACI Global Export Controls (February 26, 2025)
Speakers: Jana del-Cerro
Contacts
Director of International Trade Services
Insights
Client Alert | 4 min read | 04.14.25
Foreign Corrupt Practices Act (“FCPA”) enforcement has been fairly predictable for many years as the Fraud Section of the Department of Justice (“DOJ”) has maintained exclusive authority over investigating claims and bringing enforcement actions in federal courts across the country. President Trump’s recent pause on FCPA enforcement, the first of its kind since the statute was passed in 1977, has created significant uncertainty for individuals and businesses operating internationally regarding the future of FCPA enforcement. While DOJ is in the process of assessing what the future of FCPA enforcement, state attorneys general are stepping in. On April 2, California Attorney General Rob Bonta issued a Legal Advisory (the “Advisory) to California businesses explaining that violations of the FCPA are actionable under California’s Unfair Competition Law (UCL). The announcement signals a shift in FCPA enforcement where states may take the lead and pursue FCPA enforcement through their state unfair competition laws.
Client Alert | 4 min read | 04.10.25
Hikma and Amici Curiae Ask Supreme Court to Revisit Induced Infringement by Generic “Skinny Labels”
Client Alert | 1 min read | 04.09.25
Client Alert | 12 min read | 04.09.25
