BIS “Affiliates Rule” Suspended One Year, But No Time to Rest
On November 10, 2025, the U.S. Bureau of Industry and Security (“BIS”) delayed the effective date of its new Affiliates Rule for a one-year period, until November 9, 2026, after U.S. and China trade talks. The Affiliates Rule, announced on September 29, 2025, expands export controls under the Export Administration Regulations (“EAR”) to extend to non-listed “affiliates” owned or controlled by listed entities (on the Entity List, the Military End User List “MEU”, or certain sanctioned parties) 50% or more in the aggregate.
Section 232 Steel & Aluminum Derivative Products Inclusion Process Expands Scope of the National Security Purpose of Section 232 Investigations
On February 10, 2025, the President issued Presidential Proclamations Under Section 232 of the U.S. Code adjusting imports of steel and aluminum into the United States. These Proclamations provided an expanded listing of steel and aluminum derivative articles but also instructed the Secretary of Commerce (Secretary) to establish a process for including additional derivative aluminum and steel articles within the scope of the ad valorem duties.
The Automotive Industry, China’s Semi Grip on Supply Chains, and General Motors 2027 Exit Strategy for Suppliers (Is a clean break even possible?)
General Motors (GM) has instructed thousands of its suppliers to phase out sourcing parts and materials from China by 2027. The exit strategy began in early 2024, with the directive gaining momentum in spring of this year, 2025. This directive is part of GM’s broader strategy to enhance supply chain resiliency and reduce exposure to geopolitical risks, particularly amid escalating, or let’s just say, continuously fluctuating, U.S.–China trade tensions.
Can BRICS Break the Dollar’s Grip?
For decades, the U.S. dollar has ruled the world. Whether a Brazilian farmer sells soybeans to China or an Indian company buys oil from the Middle East, chances are the transaction runs through greenbacks. Nearly 80 percent of global trade is still denominated in dollars—even when neither the buyer nor the seller is American.
Importing Steel into Mexico A Pillar of Compliance for Suppliers Trading with Mexico
The steel trade with Mexico is particularly strategic at this moment. Companies are shifting supply chains to North America, and Mexico which has been an attractive manufacturing hub for various industries, such as automotive, aerospace, construction, electronics, household appliances, and more. This trend is driving strong demand for imported steel while simultaneously creating new export opportunities for Mexican producers. Much of this advantage stems from the USMCA, because steel originating within the USCMA region can qualify for preferential tariff treatment when traded within the United States and Canada, provided that the applicable rules of origin are fully met.
China’s Global Port Investments – It’s About Control and the Reshaping of Trade Flows
China owns outright or has majority control in 17 overseas ports globally, according to recent estimates. However, its broader footprint is much larger with 129 port projects worldwide that involve Chinese investment, construction, or operational control. 115 of these are active, spanning every continent except Antarctica, which is next.
Rare Earth Minerals-Part 2 – Enter Greenland’s Global Significance
It’s been more than a little concerning to the Trump Administration as these deposits have everything to do with international security as they are needed in the production of the very high-end microchips. So, now that it has been discovered that Greenland apparently has one of the largest deposits on the planet, Trump has stated that we will have Greenland, one way or another. While he hasn’t explicitly committed to military action, he’s made it clear that he won’t rule it out.
Wyoming Laws More Crypto-Friendly with Issuance of State Stablecoin
On August 29, 2025, Wyoming made history becoming the first state in the United States to issue its own stablecoin, the Frontier (FRNT) token, marking a groundbreaking moment in state-level cryptocurrency adoption. Wyoming’s pioneering move represents more than just technological innovation. It signals a fundamental shift in how states can leverage blockchain technology with robust legal frameworks to modernize their financial infrastructure and maintain competitive advantages in the evolving digital economy.
Preserving Refund Rights for IEEPA-Based Tariffs
Importers who have paid tariffs imposed under the International Emergency Economic Powers Act (IEEPA) should take immediate steps to preserve their eligibility for potential refunds. Multiple lawsuits are currently challenging the legality of these tariffs, and the Supreme Court is set to decide the issue in November. If the Court ultimately invalidates the tariffs, importers may be entitled to recover duties paid. However, securing refunds depends on preserving jurisdictional options—especially given the uncertainty about whether these tariffs constitute a protestable decision under customs law. There are three potential refund mechanisms at play.
Unconstitutionality of IEEPA Tariffs Upheld – Supreme Court to Review
On May 28, 2025, a three-judge panel at the Court of International Trade (CIT) ruled in two cases (VOS Selections, Inc. v. Trump and the State of Oregon v. Trump) that the Presidential actions taken under the International Emergency Economic Powers Act (IEEPA) (50 U.S.C. §§ 1701–1707) to impose tariffs on Canada, Mexico and China for illegal immigration and fentanyl smuggling are unconstitutional. The CIT said that the tariff actions did not directly address the declared emergency and were not delegated by Congress to the Executive Branch and therefore exceed the President’s tariff setting authority under the Constitution.