The Month in International Trade – March 2025

Foreign Investment Watch Names Caroline Brown a Top Adviser 2025

Top Trade Developments

• First Suit Against Trump IEEPA Tariffs Filed in Florida
• President Trump Threatens “Secondary” Tariffs on Countries Importing Venezuelan, Russian, or Iranian Oil
• Firms at Risk of Monetary Penalty for Breaches of UK Financial Sanctions Imposed on Russia
• The Trump Administration Targets China, Iran, and Pakistan in its First Export Regulatory Action
• The Maximum Pressure Campaign Escalates: OFAC Designates a Chinese Refiner of Iranian Crude
• Improving Export Control Transparency Act Introduced to Increase Transparency Regarding the Approval of Exports to Specific Countries and End-Users

Crowell Welcomes

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.

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Foreign Investment Watch Names Caroline Brown a Top Adviser 2025

Foreign Investment Watch named Crowell & Moring partner Caroline Brown to its list of Top Advisors 2025. The list recognizes the “top advisors who provide advice and counsel concerning foreign investment and national security in the U.S. and abroad.” This is the second consecutive year that Brown has been ranked.

Brown is a member of the firm’s White Collar and Regulatory Enforcement, International Trade, and Financial Services groups, as well as the steering committee of the firm's National Security Practice. Following a decade of service at the U.S. Departments of Justice and the Treasury and the White House, working to disrupt threat actors and guard the nation’s financial system against illicit use, she now advises corporations, senior executives, and boards of directors on national security and trade matters.

Brown helps clients navigate anti-money laundering and economic sanctions compliance and enforcement challenges, as well as cross border government investigations and transactions, including national security reviews by the Committee on Foreign Investment in the United States (CFIUS). Drawing on her DOJ experience coupled with her regulatory expertise, she handles high profile enforcement actions and representations before DOJ, CFIUS, the Office of Foreign Assets Control, and the Financial Crimes Enforcement Network.

While at the U.S. Department of Justice’s National Security Division, Brown worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. Brown also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

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Top Trade Developments

First Suit Against Trump IEEPA Tariffs Filed in Florida

A Florida-based small business is first out of the gate to challenge President Trump’s sweeping new tariffs under the International Emergency Economic Powers Act of 1977. The complaint was filed by conservative legal advocacy group New Civil Liberties Alliance (“NCLA”) on behalf of Emily Ley Paper, Inc.(doing business as “Simplified”), a small business based in Florida.

The plaintiff has requested that the Court (1) declare the China EOs unlawful and unconstitutional, (2) enjoin the suit’s defendants from implementing or enforcing the EOs, and (3) set aside the modifications made to the HTS resulting from the EOs.

Click here to continue reading the full version of this article.

For more information, contact: John Brew, Daniel W. Wolff, Andrew Schlegel

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President Trump Threatens “Secondary” Tariffs on Countries Importing Venezuelan, Russian, or Iranian Oil

In the last week, President Trump has threatened “secondary” tariffs in three distinct scenarios. While this is the first time that the Administration has used the term “secondary” tariffs, the terminology is likely intended to mirror that used in the sanctions context and, as with “secondary” sanctions, appears designed to be another mechanism by which the U.S. Administration could impose economic costs against third countries based on their alleged dealings with targets of U.S. sanctions.

Click here to continue reading the full version of this article.

For more information, contact: Dan Cannistra, Dj Wolff, Jeremy Iloulian, Ivy Xun

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Firms at Risk of Monetary Penalty for Breaches of UK Financial Sanctions Imposed on Russia

The UK’s Office of Financial Sanctions Implementation (“OFSI”) has imposed a monetary penalty of £465,000 against a multinational law firm’s Russian office (the “Russian Office”) for breaching UK financial sanctions against Russia following its invasion of Ukraine in February 2022. This is the first time OFSI has enforced against a law firm.

Click here to continue reading the full version of this article.

For more information, contact: Carlton Greene, Dj Wolff, Nicola Phillips, Sophie Davis

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The Trump Administration Targets China, Iran, and Pakistan in its First Export Regulatory Action

On March 25, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) released two final rules that announced the addition of 80 new entities to the Entity List (see BIS press release here). In its press release, BIS officials stated that the Entity List is only one of the powerful tools at their disposal, signaling the likelihood of more actions under BIS’ regulatory authorities.

Click here to continue reading the full version of this article.

For more information, contact: Jana del-Cerro, Jeremy Iloulian, Chandler Leonard, Ivy Xun

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The Maximum Pressure Campaign Escalates: OFAC Designates a Chinese Refiner of Iranian Crude

On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated the “teapot” Chinese oil refinery Shandong Shouguang Luqing Petrochemical Co., Ltd. (“Luqing Petrochemical”), its chief executive officer, eight vessels, and eleven vessel owners, managers, and operators, on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”). OFAC explains that Luqing Petrochemical purchased hundreds of millions of dollars’ worth of crude oil from Iran, at times using vessels linked to designated terrorist organization Ansarallah—also known as the Houthis—and the Iranian Ministry of Defense of Armed Forces Logistics.

Click here to continue reading the full version of this article.

For more information, contact: Dj Wolff, Erik Woodhouse, Jeremy Iloulian, Andrew Schlegel

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Improving Export Control Transparency Act Introduced to Increase Transparency Regarding the Approval of Exports to Specific Countries and End-Users

On February 26, 2025, Senators Jim Banks (R-Ind.) and Mark Warner (D-Va.) introduced the Maintaining American Superiority by Improving Export Control Transparency Act (the Act) in the United States Senate. A companion bill titled the same was reintroduced in the United States House of Representatives on March 5, 2025, by Congressman Ronny Jackson (R-TX-13).

Click here to continue reading the full version of this article.

For more information, contact: Jana del-Cerro, Jeremy Iloulian, Dilan Wickrema

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Crowell Welcomes

Heather Sanborn is an associate in Crowell & Moring’s International Trade Group and a resident in the firm’s DC office. She joins Crowell from Honigman LLP, where she was a Corporate Associate. In her role, she supported U.S. and international companies in navigating complex regulatory frameworks such as the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and Office of Foreign Assets Control (OFAC) sanctions. Heather also counseled foreign investors on transactions, conducted compliance audits, and provided trade compliance training.

Prior to Honigman LLP, Heather was a Corporate and Securities Associate at Cooley LLP, where she trained in CFIUS compliance export control regulations. She also represented issuers and underwriters in capital markets transactions and advised clients with disclosure and compliance obligations under the Exchange Act. She began her legal career at Schiff Hardin LLP as a Corporate Associate, advising US and international companies on corporate governance and compliance obligations under federal securities laws.

Heather graduated magna cum laude with a J.D. from Chicago-Kent College of Law, where she was a Law Review and Moot Court member, and an Honors Scholar. She holds a Master in Science in Health, Public Leadership and Management from the University of Birmingham, England, and a Bachelor of Arts in Political Science from the University of Illinois at Chicago, where she graduated cum laude.

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Crowell Speaks

“Trump 2.0’s Sanctions Policy in Practice: Former U.S. Government Officials and Industry Leaders Discuss the New Compliance Realities,” European Forum on Global Economic Sanctions, Berlin (June 5, 2025)
Speaker: Erik Woodhouse 

“Trade Risk to US Digital Infrastructure and AI Development,” Digital Infrastructure Policy & Investment Leadership Sumit, Gaylord National Resort Convention Center, National Harbor, Maryland (May 5, 2025)
Speaker: Nigel Cory

19^th Annual Flagship Economic Sanctions Enforcement and Compliance, The National Press Club, Washington, DC (May 1, 2025)
Speaker: Erik Woodhouse 

News Interview on the Impact of Tariffs on US relationship with China, Canada, Other Countries
April 8, 2025 – CTV Canada
Related Professionals: Monica Gorman 

Trump's tariff 'punch up' with China will not help Americans
April 7, 2025 – Times Radio (London)
Related Professionals: Monica Gorman

5 key details in Trump’s global tariffs order
April 4, 2025 – Supply Chain Drive
Related Professionals: Alexander Schaefer

Answering Listener Questions on Tariff Impacts
April 4, 2025 – BBC Radio 4
Related Professionals: Monica Gorman 

Trump’s tariff formula “astonishing”: Former White House official
April 2, 2025 – Singapore’s Channel News Asia
Related Professionals: Monica Gorman 

Under Trump’s tariffs, your shopping at retailers like T.J. Maxx, Temu, and Wayfair could see a shakeup
April 1, 2025 – Boston Globe
Related Professionals: Monica Gorman 

Tariffs are paused for USMCA-compliant goods. How can companies qualify?
March 19, 2025 – Supply Chain Drive
Related Professionals: Alexander Schaefer

“The New Era of National Security: Export Controls and Sanctions in 2025,” SABANY (March 19, 2025)
Speaker: Anand Sithian

“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 

“Conducting and Surviving Investigations,” 2025 International Compliance Professionals Association (ICPA) Annual Conference, Orlando, FL (March 12, 2025)
Speaker: Derek Hahn.

“Advanced Anti-forced Labor Best Practices,” 2025 International Compliance Professionals Association (ICPA) Annual Conference, Orlando, FL (March 10, 2025)
Speaker: Simeon Yerokun

How EU’s Anticoercion Tool May Counter New US Tariffs
March 10, 2025 – Law360
Related Professionals: Vassilis Akritidis, Jean-Baptiste Blancardi 

“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 11^th 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 11^th Annual In-House Recovery Conference, Dana Point, CA (March 4, 2025)
Speakers: Monica Gorman, Aaron Cummings