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.

Concrete Action Against Venezuela: On March 24, 2025, President Trump issued an Executive Order, authorizing the imposition of a 25% tariff on all goods imported into the United States from any country determined to be importing Venezuela crude oil or petroleum products extracted, refined, or exported from Venezuela on or after April 2, 2025.

The U.S. Department of Commerce, in coordination with the U.S. Departments of State and Justice will determine which country has imported Venezuelan oil (which includes indirect imports through third parties, as can be reasonably traced back to Venezuela). Commerce will be responsible for issuing regulations, guidance, and determinations to implement the order.

However, it will be the U.S. Department of State, in consultation with the U.S. Departments of the Treasury, Commerce, and Homeland Security, and the Office of the U.S. Trade Representative (“USTR”) that will decide whether or not to impose the 25% tariff on a particular country. Once the tariff is imposed, it will expire one year after the country last imported Venezuelan oil, or at an earlier date, if determined by Commerce in consultation with the U.S. Departments of State, Treasury, Homeland Security, and the USTR. This tariff would be in addition to any other tariffs already imposed on the specific country or product, such as existing duties imposed under IEEPA and Sections 232 and 301.

Based on publicly available information in a 2024 brief published by the U.S. Energy Information Administration (“EIA”), two of the largest importers of Venezuelan oil are China and India, making them potential targets of further tariffs.

As of the date of this blog post, none of the U.S. Department’s of Commerce, State, and Justice have publicly identified any countries that import Venezuelan oil.

Russia: On March 30, President Trump threatened to impose secondary tariffs on Russian oil, specifically noting that it would be a 25-50% tariff on goods from countries that buy oil from Russia. President Trump explained that he would impose such a tariff within a month, if (a) Russia is unable to agree to a ceasefire in Ukraine and (b) the White House believes that failure is attributable to Russian action (or inaction). No further details were shared.

A 2024 brief published by EIA explains that the largest importers of Russian oil are China, India, Turkey, and a handful of Eastern EU members (i.e., Hungary, Slovakia, and Czech Republic). Importers of petroleum products from Russia are much more diversified to include locations such as Singapore, Brazil, and the United Arab Emirates.

Iran: Also on March 30, President Trump threatened to impose secondary tariffs on Iranian oil, by imposing tariffs on goods from countries that buy oil from Iran. He provided even fewer details on these potential tariffs, other than the decision to impose them would depend on whether the Iranian government would negotiate a nuclear agreement with the United States.

The 2024 EIA brief on Iran explains that China is the largest importer of Iranian oil by significant margins (89% of all sales), with the remaining purchases from Syria, the UAE, and Venezuela.

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Photo of Daniel Cannistra Daniel Cannistra

Dan Cannistra is a partner in the firm’s Washington, D.C. office. His practice focuses on legislative, executive and regulatory representation of domestic and international clients on a broad spectrum of international trade matters. Dan has represented domestic and foreign companies in over 75

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Dan Cannistra is a partner in the firm’s Washington, D.C. office. His practice focuses on legislative, executive and regulatory representation of domestic and international clients on a broad spectrum of international trade matters. Dan has represented domestic and foreign companies in over 75 U.S. antidumping and countervailing duty cases before the U.S. Department of Commerce and the U.S. International Trade Commission under the Tariff Act of 1930. Many of these matters involved appeals to the U.S. Court of International Trade, the U.S. Court of Appeals for the Federal Circuit, binational panels under the North American Free Trade Agreement (NAFTA), and dispute settlement proceedings before the World Trade Organization (WTO). Dan has also represented clients in antidumping proceedings in the European Union, Canada, Mexico, Brazil, India, Thailand, Singapore, Guatemala and Taiwan.

Prior to joining Crowell & Moring, Dan was a director in a national accounting firm providing customs and international trade guidance to multinational clients related to the supply and distribution of goods and services across international borders. Areas of specialization included antidumping and countervailing duties and policy, trade remedies and litigation, free trade agreements and negotiations, classification and valuation, and international trade and development.

Dan’s government appointments include service to U.S. Trade Representative on the roster of international trade practitioners to resolve antidumping disputes involving NAFTA members. For the European Commission, Dan provided advice and training on international trade and antidumping methodology and practice. In addition, Dan has served as an international trade consultant to the governments of Guatemala and Singapore, providing technical advice to these governments on the application of international trade regulations consistent with international law and World Trade Organization agreements and the General Agreement on Tariffs and Trade, Agreement on Antidumping.

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Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice

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David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).

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Photo of Jeremy Iloulian Jeremy Iloulian

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to

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Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. He regularly advocates on behalf of such clients before the U.S. Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls (DDTC), Office of Foreign Assets Control (OFAC), Bureau of Economic Affairs (BEA), Census Bureau, Department of Energy, and Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

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Photo of Ivy Xun Ivy Xun

Ivy Xun is an international trade analyst in Crowell & Moring’s Washington, D.C. office. She provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative and U.S. Customs and Border Protection. She…

Ivy Xun is an international trade analyst in Crowell & Moring’s Washington, D.C. office. She provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative and U.S. Customs and Border Protection. She works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. Ivy also supports unfair trade investigations, including antidumping and countervailing duty investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission.

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