Global Trade & Foreign Policy Insights

On February 6, 2025, President Trump issued Executive Order (EO) 14203, “Imposing Sanctions on the International Criminal Court,” blocking the property of the International Criminal Court’s (ICC) Chief Prosecutor and providing authority to designate any foreign persons that the Secretary of State (in consultation with the Secretary of the Treasury and the Attorney General) determines to have directly engaged in certain specified acts.

On April 2, 2025, President Trump signed two executive orders enacting sweeping reciprocal tariffs and eliminating the de minimis treatment for imports from China and Hong Kong. The accompanying Fact Sheet also continues to highlight sectors for which the Administration is seeking new investment in manufacturing. 

On March 27, 2025, the Securities and Exchange Commission hosted a roundtable discussion on artificial intelligence in the financial industry. Acting Chairman Mark T. Uyeda and Commissioners Hester M. Peirce and Caroline A. Crenshaw delivered remarks that highlighted the SEC’s efforts to assess AI’s evolving role in finance, including its benefits, risks, and regulatory implications.

On February 4, 2025, President Donald Trump issued his second National Security Presidential Memorandum (NSM-2), enacting “maximum pressure on the Iranian regime.” While Iran is already subject to robust and comprehensive U.S. economic sanctions and embargos, NSM-2 focuses on denying Iran nuclear weapons and intercontinental ballistic missiles, countering Iran’s development of weapons, and disrupting those who act on behalf of Iran (including Iran’s “surrogates” and “terror proxy groups”).

On 30 January 2025, the European Commission published its first annual report on the implementation of EU export controls and the modernised Dual-Use Regulation. The report marks an important milestone in the development of EU export control policy, providing a consolidated overview of the data for 2022 with a view to enhancing transparency in this area.

On February 25, 2025, President Trump signed the “Addressing The Threat To National Security From Imports of Copper” Executive Order., which orders the Department of Commerce to investigate the effects of copper imports on national security, which could lead to tariffs on all copper imports. The United States currently imports just under half of the refined copper it consumes. More than 90% of the copper imported by the United States comes from Chile, Canada, and Peru.

On February 13, 2025, President Trump hosted the Prime Minister of India, Narendra Modi, at the White House. Prime Minister Modi was the fourth head of state to meet with President Trump regarding the President’s threat that United States trading partners will face reciprocal tariffs.

On January 20, 2025, shortly after his inauguration, President Donald Trump signed the “Initial Rescissions of Harmful Executive Orders and Actions” Executive Order (EO) 14148. In order to “restore common sense to the Federal Government and unleash the potential of the American citizen,” EO 14148 rescinded 67 Executive Orders and 11 Presidential Memoranda from the Biden administration.

On February 11, 2025, President Trump issued a proclamation implementing tariffs on aluminum and derivative steel articles. The Proclamation effectively eliminated exemptions from tariffs for countries and territories, including Canada, Mexico, the European Union, the United Kingdom, Japan, and South Korea.

On February 10, 2025, President Trump issued a proclamation implementing tariffs on steel and derivative steel articles. Effective March 12, 2025, previous proclamations that exempted or adjusted tariffs on steel imports from various countries, including South Korea, Argentina, Australia, Brazil, Canada, Mexico, Japan, the United Kingdom, Ukraine, and the European Union, will be rescinded.

As anticipated, on Saturday, February 1, 2025, President Trump signed three executive orders imposing a 25% ad valorem rate of duty on Canadian and Mexican products; and a 10% rate of duty on Chinese products. 

On January 27th, President Trump threatened to impose tariffs on U.S. imports of copper and aluminum (metals needed for U.S. military hardware production), as well as steel.

On January 26, 2025, a feud between the United States and Colombia began pertaining to U.S. military flights carrying deportees to Colombia. After initially providing approval for the two aircraft to land in Colombia, Colombian President Gustavo Petro blocked their landing. According to his multiple social media posts, he explained that he was objecting to the use of military planes as opposed to commercial airlines to deport the migrants. In response, President Trump posted on social media that his administration will institute a number of actions against Colombia.

The 1984 Supreme Court decision in Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. established the ‘Chevron deference’ doctrine, which required courts to defer to administrative agency interpretations of ambiguous statutes if they were reasonable. This doctrine significantly impacted the financial services sector, making it difficult to challenge the US Department of the Treasury's actions, such as sanctions and penalties. 

On January 20th, President Trump issued a memorandum titled the America First Trade Policy to the Secretaries of State, the Treasury, Defense, Commerce, Homeland Security, and the Director of the Office of Management and Budget, the U.S. Trade Representative, the Assistant to the President for Economic Policy, and the Senior Counselor of Trade and Manufacturing. 

Following his inauguration on Monday, January 20, 2025, President Donald Trump held off on issuing an executive order instituting additional tariffs of any form.

Since well before the November 6 election, President-elect Trump and his team have been discussing the imposition of tariffs on certain trade partners. The scope of possibilities range from all imports being subject to a 10% to 20% additional tariff, to the imposition of a 60% tariff on imports from China, to tariffs on vehicles from Mexico reaching as high as 100% to 200%.

On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a six-page guidance statement to financial institutions about best practices under the Export Administration Regulations (EAR). 

On September 11, the U.S. Department of Commerce’s Bureau of Industry and Security published a proposed rule in the Federal Register that would require quarterly reporting by organizations, companies, and corporations organized in the U.S. (including branches outside the U.S.) if they plan to either engage in artificial intelligence model training or acquire, develop, or otherwise possess a high-performance computing cluster for AI training.