IEEPA

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Yesterday, the Supreme Court of the United States heard oral argument in the consolidated case challenging the use of the International Emergency Economic Powers Act (“IEEPA”) to justify sweeping import tariffs. At issue is whether IEEPA authorizes the President, upon declaring a national emergency, to impose tariffs and, if so, whether that delegation is constitutionally…

Modifications to Scope

On Friday, September 5th, 2025, President Trump announced via Executive Order a large number of modifications to the scope of the reciprocal tariffs, which were initially announced on April 2, 2025, under the International Emergency Economic Powers Act (IEEPA). The Executive Order released on September 5th modified the scope of the…

The Court of International Trade (“CIT”) and the District Court for the District of Columbia (“DDC”) both issued decisions enjoining the Trump IEEPA tariffs.  In both venues, the government appealed the courts’ decisions, and both orders are currently stayed. The DDC stayed its own preliminary injunction pending appeal; the U.S. Court…

On May 29, a day after the U.S. Court of International Trade (“CIT”) issued summary judgment in V.O.S. v. Trump blocking the IEEPA tariffs, the District Court for the District of Columbia (“DDC”) exercised jurisdiction in Learning Resources, Inc., et. al., v. Donald J. Trump, et. al. (25-cv-1248), denying the government’s motion to transfer the…

On May 28, 2025, the Court of International Trade granted summary judgment in V.O.S. Selections, Inc. et al v. Donald J. Trump Case No. 25-cv-66, ordering that all the executive orders imposing tariffs on the basis of IEEPA (Executive Order 14193, Executive Order 14194, Executive Order 14195, Executive Order 14257), were declared to be invalid…

On July 22, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released guidance (“Guidance”) on how it will implement the new authority it was granted in the April 24, 2024 National Security Supplemental (“the Act”).  The Act extended the statute of limitations for civil, criminal, and forfeiture violations of sanctions…

On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and…