The Month in International Trade – April 2025

Crowell Files Amicus Brief Opposing IEEPA Tariffs

Crowell Obtains Ruling in Client’s Favor at CIT

Top Trade Developments

• New UK Sanctions on Russia Targeting Technology, Software and Additional Strategic Goods
• BIS Adds and Removes Persons from the Unverified List
• A New Sheriff in Town: State Attorneys General Take Action to Enforce Violations of the Foreign Corrupt Practices Act
• President Trump Signs Executive Order Regarding U.S. Defense Trade

Crowell Podcasts

Crowell Speaks

This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Anand Sithian or Simeon Yerokun or any member of the International Trade Group.

Crowell Files Amicus Brief Opposing IEEPA Tariffs

Attorneys from Crowell’s International Trade Group filed an amicus brief at both the U.S. Court of International Trade (CIT) (V.O.S. Selections v. Donald J. Trump, CIT, No. 25-00066) and the U.S. District Court for the District of Columbia (Learning Resources, Inc. v. Trump, D.D.C., No. 25-cv-01248) on behalf of a group of academics and former politicians in support of plaintiffs (importers) challenging the legality of President Trump’s tariffs imposed under the International Emergency Economic Powers Act (IEEPA).

Crowell Obtains Ruling in Client’s Favor at CIT

The Court of International Trade ruled in Crowell’s favor in Solar Energy Industries Association v. United States, CIT, No. 20-3941. Crowell, along with co-counsel, argued that the Court should deny the government’s request for reliquidation of entries inadvertently liquidated in violation of the CIT’s Dec. 2021 order enjoining liquidation. The Court agreed, finding that the government was not entitled to such equitable relief.

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Top Trade Developments

New UK Sanctions on Russia Targeting Technology, Software and Additional Strategic Goods

In a move to strengthen its sanctions regime against Russia, the UK introduced additional sanctions through the publication of The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. The new sanctions came into force on April 24, 2025.

Click here to continue reading the full version of this article.

For more information, contact: Dj Wolff, Nicola Phillips, Sophie Davis

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BIS Adds and Removes Persons from the Unverified List

On April 25, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule that added 18 new persons and removed five persons from the Unverified List (UVL).

Click here to continue reading the full version of this article.

For more information, contact: Dilan Wickrema

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A New Sheriff in Town: State Attorneys General Take Action to Enforce Violations of the Foreign Corrupt Practices Act

Foreign Corrupt Practices Act (“FCPA”) enforcement has been fairly predictable for many years as the Fraud Section of the Department of Justice (“DOJ”) has maintained exclusive authority over investigating claims and bringing enforcement actions in federal courts across the country. President Trump’s recent pause on FCPA enforcement, the first of its kind since the statute was passed in 1977, has created significant uncertainty for individuals and businesses operating internationally regarding the future of FCPA enforcement. While DOJ is in the process of assessing the future of FCPA enforcement, state attorneys general are stepping in. On April 2, California Attorney General Rob Bonta issued a Legal Advisory (the “Advisory) to California businesses explaining that violations of the FCPA are actionable under California’s Unfair Competition Law (UCL). The announcement signals a shift in FCPA enforcement where states may take the lead and pursue FCPA enforcement through their state unfair competition laws.

Click here to continue reading the full version of this alert.

For more information, contact: Toni Michelle Jackson, Agustin D. Orozco, Alexander J. Kramer, Derick D. Dailey, Lauren Arquette

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President Trump Signs Executive Order Regarding U.S. Defense Trade

On April 9, 2025, President Trump signed and released an Executive Order (EO) to “improve speed and accountability” in the U.S. defense trade system and published an accompanying fact sheet.  The EO identifies specific actions for executive branch agencies to take including: (i) reverting back to the Conventional Arms Transfer Policy that President Trump implemented in 2018 (which was amended under the Biden Administration); (ii) reevaluating restrictions imposed by the Missile Technology Control Regime on Category I items; (iii) requesting Congress to update statutory congressional notification thresholds; and (iv) updating the Foreign Military Sales (FMS)-Only List.

Click here to continue reading the full version of this article.

For more information, contact: Dilan Wickrema

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Crowell Podcasts

Global Trade Talks: Tariffs Overview and Update

Crowell hosts Nicole Simonian and Dj Wolff speak with Crowell Partner Daniel Cannistra as he helps our listeners understand the current tariff landscape and discusses some best practices for how to navigate. Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives.

Click below to listen:
PodBean | SoundCloud | Apple Podcasts

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Crowell Speaks

“Trump 2.0’s Sanctions Policy in Practice: Former U.S. Government Officials and Industry Leaders Discuss the New Compliance Realities,” European Forum on Global Economic Sanctions, Berlin (June 5, 2025). Speaker: Erik Woodhouse 

“Navigating Tariffs and Ensuring Compliance Through Proper Classification and Origin Determinations: HTS Classification and Country of Origin Essentials and Grey Areas,” ACI’s Virtual Passport to Proficiency on U.S. Customs Compliance, Online (June 4, 2025). Speaker: John Brew

“Trade Risk to US Digital Infrastructure and AI Development,” Digital Infrastructure Policy & Investment Leadership Summit, Gaylord National Resort Convention Center, National Harbor, Maryland (May 5, 2025). Speaker: Nigel Cory

19^th Annual Flagship Economic Sanctions Enforcement and Compliance, The National Press Club, Washington, DC (May 1, 2025). Speaker: Erik Woodhouse

“What’s New and Brewing at OFAC: New Designations, Longer Longback Period and More,” 19^th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance, The National Press Club, Washington, DC (April 30, 2025). Speaker: Carlton Greene

“Adapting to Today’s International Legal Challenges: A New Era?”, 2025 ILS Annual Conference, New York (April 28 - May 1, 2025). Speakers: David Stepp, Jackson Pai, and Jeremy Iloulian

IPBA Chicago: Annual Meeting and Conference, Chicago (April 23 – April 26, 2025). Speakers: Evan Chuck and Jeremy Iloulian

Bridging the Gap between Sanctions & Export Controls: Tips & Best Practices, ACSS New York Chapter, New York (April 10, 2025). Panelist: Jeremy Iloulian 

The Legal Arguments Challenging Trump’s Tariffs: Explained
April 17, 2025 – Bloomberg Law
Related Professionals: Daniel Cannistra 

Will Legal Challenges From Small Businesses Actually End Trump’s Tariffs?
April 15, 2025 – Forbes News Room
Related Professionals: Daniel Wolff 

US seeking superyacht maintenance expenses from Russian oil magnate
April 11, 2025 – Global Investigations Review
Related Professionals: Anand Sithian

Are Trump’s Tariffs Unconstitutional? President Slapped With a Lawsuit Over China LeviesApril 10, 2025 – Forbes
Related Professionals: Daniel Wolff 

News Interview on the Impact of Tariffs on US relationship with China, Canada, Other Countries
April 8, 2025 – CTV Canada
Related Professionals: Monica Gorman 

Trump's tariff 'punch up' with China will not help Americans
April 7, 2025 – Times Radio (London)
Related Professionals: Monica Gorman

5 key details in Trump’s global tariffs order
April 4, 2025 – Supply Chain Drive
Related Professionals: Alexander Schaefer

Answering Listener Questions on Tariff Impacts
April 4, 2025 – BBC Radio 4
Related Professionals: Monica Gorman 

Trump’s tariff formula “astonishing”: Former White House official
April 2, 2025 – Singapore’s Channel News Asia
Related Professionals: Monica Gorman 

Under Trump’s tariffs, your shopping at retailers like T.J. Maxx, Temu, and Wayfair could see a shakeup
April 1, 2025 – Boston Globe
Related Professionals: Monica Gorman