As of October 1, 2025, the U.S. Government has shut down as a result of the budget impasse in Congress. While essential services such as law enforcement remain operational, many departments have had to furlough staff and suspend non-critical functions.
For international trade-related operations, the impact varies by agency. Critical functions tied to national security—such as Section 232 investigations by the Department of Commerce and tariff collection by U.S. Customs and Border Protection—continue uninterrupted. However, many other trade-related activities, including export licensing at the Bureau of Industry and Security, are paused or significantly reduced. Below is an overview of how each agency is impacted, which will be updated to reflect any new announcements.
Customs and Border Protection (CBP)
CBP will remain largely operational, including managing the ports, collecting tariffs, and investigating trade violations.
Commerce Department
Bureau of Industry and Security (BIS)
During the shutdown, BIS will generally cease processing active license applications and accepting new license applications, in addition to commodity classification requests (CCATS). However, BIS’s Office of Export Administration will continue to process and review only “emergency license applications” involving the trade and economic national security of the U.S. BIS also reserves the ability to draft export regulations required to support U.S. and allied military activity.
BIS’s Office of Export Enforcement will continue conducting end-use checks as well as pursuing active and new investigations and enforcement actions.
Section 232 Investigations
Commerce’s contingency plans states that any investigations authorized under Section 232 of the Trade Expansion Act of 1962 (“Section 232) that is either in progress or commenced during the shutdown will continue as “necessary work to address the effect of imported articles on national security.”
International Trade Administration – Enforcement and Compliance
Commerce’s Trade and Enforcement Compliance Office, which oversees antidumping and countervailing (AD/CVD) duty litigation, will also cease regular options. For questionnaires and requests for clarification that are due before the Government re-opens, the Office is requesting responses by the same deadline. For all other submissions, parties may have an automatic 1-day extension, and if the Government remains closed, the response deadline will be within two business days after re-opening. The schedule for rebuttal case briefs will be set after the Government re-opens.
Treasury Department
Office of Foreign Assets Control (OFAC)
OFAC will also generally cease processing new and current license applications, but similar to BIS, we expect OFAC will review certain emergency license that are deemed necessary for U.S. national security. Further, OFAC will continue to administer the Specially Designated Nationals (“SDN)” list and enforce economic and trade sanctions.
Committee on Foreign Investment in the United States (CFIUS)
CFIUS activity and processing will generally cease. Treasury’s contingency plan confirms that “[a]ll deadlines or time limitations imposed on [CFIUS] for cases under review by CFIUS, including notices and declarations, will be tolled.” However, this refers to CFIUS’s own deadlines and thus does not appear to extend to any deadlines that may arise for private parties while the Government is closed.
State Department
Directorate of Defense Trade Controls (DDTC)
According to its website, DDTC’s services will be “significantly curtailed,” including Defense Export Control and Compliance System (DECCS) submissions for registrations, licenses, speaker requests, customer support, Advisory Opinions, and Commodity Jurisdiction determinations. Further, any requests pending as of September 30, 2025, will remain pending. Activities essential for U.S. national security will continue, which will likely include investigative and enforcement activities.
U.S. International Trade Commission (USITC)
The USITC has ceased regular operations. The USITC’s website states that “[h]earings and other Commission meetings will be rescheduled once regular operations resume.”
The Husch Blackwell team continues to monitor developments and will provide additional updates as they arise.