Tariffs & Trade Policy

Tariff Evasion Enforcement Continues To Be A Top Priority for DOJ and CBP

Recent developments highlight a coordinated, aggressive approach by the U.S. Government to crack down on schemes that undermine U.S. trade laws.

An Indonesian jewelry company, UBS Gold, its co-owner, and two employees were charged with conspiring to evade over $86 million in U.S. customs duties on jewelry imports. Two individuals were arrested and face up to 20 years in prison for wire fraud conspiracy, while UBS Gold faces fines up to $500,000 or twice the gain.

On November 20, 2025, the White House issued an Executive Order marking a significant shift in U.S. trade policy toward Brazil. This action updates the measures originally imposed under Executive Order 14323 from July 30, 2025, which had established a 40% additional ad valorem duty on certain Brazilian goods under the International Emergency Economic Powers Act (IEEPA) due to concerns over Brazil’s policies and practices impacting U.S. national security and foreign policy.

The U.S. Commerce Department’s Bureau of Industry and Security (BIS) has issued a final rule which will suspend BIS’s recently enacted Affiliates Rule effective as of November 10, 2025 and continuing through November 9, 2026.  The Trump Administration committed to make this change as part of its Deal on Economic and Trade Relations with China

Following the U.S. and China trade meetings last week, President Trump issued an Executive Order reducing the rate of fentanyl-related tariffs on China from 20% to 10%, effective November 10, 2025. These tariffs were originally imposed under the International Emergency Economic Powers Act (“IEEPA”) on February 1 and March 3, 2025 to address China’s failure to alleviate the influx of synthetic opioids into the U.S.

The Trump Administration announced in an executive order that it will institute and impose an additional 25% on imports of goods with a country of origin India effective August 27, 2025 to address India’s imports of Russian oil. The administration instituted these additional tariffs as India purchased Russian oil and the executive order states that the Commerce Secretary, Treasury Secretary and Secretary of State “shall determine whether any other country is directly or indirectly importing Russian Federation oil,” and “shall recommend whether and to what extent I should take action as to that country, including whether I should impose an additional ad valorem rate of duty of 25 percent on imports.”

On June 3, 2025, President Trump issued a Proclamation (“the Proclamation”) increasing the Section 232 duties on imports of aluminum and steel from 25% to 50%. The Proclamation states that the previously imposed steel and aluminum tariffs “have not yet enabled these industries to develop and maintain the rates of capacity production utilization that are

On May 8, 2025, the United States and the United Kingdom announced a new “trade agreement”. The Fact Sheet issued by the White House, can be found here. The Office of the United States Trade Representative has released the Agreements in Principle, which indicate that the terms of trade agreement are still a

On April 29, 2025, President Trump issued a Proclamation (the “Proclamation”) amending the tariffs applicable to imports of automobiles and automobile parts. For a complete discussion on the tariffs imposed on automobiles and automobile parts, see our separate blog posts here and here.

The Proclamation issued on April 29th, amends Proclamation 10908 which first

On April 2, 2025, President Trump published the Annex of automobiles and automobile parts subject to tariffs pursuant to Section 232 of the Trade Expansion Act of 1962.  This follows the President’s March 26, 2025 Proclamation announcing the forthcoming 25% tariffs on certain vehicles and related parts, which we previously reviewed here.  This Annex