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The Month in International Trade – August 2025

Client Alert | 12 min read | 09.09.25

The Best Lawyers in America 2026 Recognizes 43 Crowell & Moring Attorneys, One Selected as Lawyer of the Year

Latinvex Names Crowell & Moring to List of Latin America's Top Law Firms of 2025

New York Law Journal Names Anand Sithian to 2025 Rising Star List

Top Trade Developments

Crowell Webinars

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.

The Best Lawyers in America 2026 Recognizes Two Crowell & Moring International Trade Attorneys

The 2026 edition of The Best Lawyers in America® has recognized 43 Crowell & Moring lawyers as Best Lawyers, including International Trade partners John Brew and Jeff Snyder.

Latinvex Names Crowell & Moring to List of Latin America's Top Law Firms of 2025

Latinvex has named Crowell & Moring as one of Latin America’s Top International Law Firms of 2025. The firm is listed among the top 50 global firms ranked for their legal work in Latin America.

For the individual categories, the firm is ranked in the first band for Trade & Sanctions, the third band for Aviation & Arbitration, and the fourth band for Banking & Finance.

Latinvex, a leading publisher of business and legal news about the region, made its selections based on a combination of factors, including value, prominence and scope of work, and client and peer references.

Crowell represents clients in Latin America and the Caribbean, as well as others with business interests in the region, on a variety of trade and investment issues and international policy and regulatory concerns. The firm regularly represents multinational companies on international employment and compliance issues, also advising clients on issues under international and regional trade conventions, such as the United States-Mexico-Canada Agreement, the Central America-Dominican Republic-U.S. Free Trade Agreement, and bilateral free trade agreements between the United States and Colombia, Panama, and other countries. Crowell & Moring has advised clients on sanctions, export controls, anti-money laundering, anti-corruption/anti-bribery and customs/import issues in many Latin American countries, including Brazil, Colombia, Cuba, Mexico, Peru, and Venezuela. 

The firm works closely with its international policy and regulatory affairs affiliate, Crowell Global Advisors, to represent clients whose interests require the cooperation of government agencies and international organizations, including the United Nations, the World Bank, the International Monetary Fund, the U.S. Department of State, the U.S. Department of Justice, and national governments throughout the region. The firm works with clients on prospects for trade with and investment in Cuba, helping clients adhere to the laws of the U.S. and Cuba, build the right relationships, and gain market entry by providing practical, solutions-oriented legal guidance and advisory services.

New York Law Journal Names Anand Sithian to 2025 Rising Star List

The New York Law Journal has recognized Crowell & Moring partner Anand Sithian as a 2025 “Rising Star.” The award recognizes the region’s most promising lawyers, age 40 and younger, who “represent the pinnacle of legal achievement in New York” and whose “dedication, innovation, and leadership have profoundly impacted the legal profession.”

Sithian is a member of Crowell’s Financial Services, International Trade, and White Collar and Regulatory Enforcement groups, where he advises U.S. and foreign clients on a variety of regulatory, compliance, and government investigations relating to anti-money laundering, the Bank Secrecy Act, U.S. economic sanctions, and related matters, with a particular focus on digital assets issues. He routinely counsels clients on the novel application of these laws and regulations involving financial institutions, technology companies, FinTech platforms, and digital assets participants. A former federal prosecutor, Sithian guides individuals and companies through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations.

A list of all finalists is available on the New York Law Journal’s website. The awardees will be honored at a ceremony on September 4, 2025, in Manhattan. To view Sithian’s article in the New York Law Journal, please visit here.

Top Trade Developments

U.S. - EU Trade Deal: EU Proposes Tariff Reductions

The EU has published a legislative proposal ito implement its commitments to reduce tariffs on U.S. industrial goods and certain seafood and agricultural goods. Tariffs on lobster imports are addressed in a separate proposal.

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

For more information, contact: Dan Cannistra, Oleksii Yuzko

U.S. and EU Agree on a Wide Trade Framework

Last month, the U.S. and the EU concluded a framework agreement that covers trade-related areas, as well as broader discussions on regulatory and economic policies.

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

For more information, contact: Vassilis Akritidis, Dan Cannistra, Oleksii Yuzko

President Trump Signs Amendment to Export Control Reform Act

On August 19, President Trump signed the Maintaining American Superiority by Improving Export Control Transparency Act (H.R. 1316) after the House passed it by voice vote, and the Senate unanimously voted in favor.

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

For more information, contact: Scott Wise, Jeremy Iloulian, Edward Goetz

DHS 2025 UFLPA Update Targets New Industries and Expands Entity List

On August 19, 2025, the Forced Labor Enforcement Task Force, chaired by the Department of Homeland Security and including agencies such as the Department of Labor, released its annual update to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China. This update, required by the Uyghur Forced Labor Prevention Act (UFLPA), outlines expanded enforcement measures to prevent goods made with forced labor—especially in the Xinjiang Uyghur Autonomous Region—from entering the U.S. market.

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

For more information, contact: John Brew, Pierfilippo Natta, Andrew Schlegel

BIS Adds to Section 232 Steel, Aluminum Derivatives List

The Bureau of Industry and Security (BIS) will include multiple additional items as steel and aluminum derivative products, which will be subject to the Section 232 measures on their steel and aluminum content.

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For more information, contact: Vassilis Akritidis, Dan Cannistra, Oleksii Yuzko

Joint Criminal and Civil Export Controls Enforcement: Lessons from the Cadence Case

On July 28, 2025, Cadence Design Systems Inc., a global electronic design automation technology company based in San Jose, California, agreed to plead guilty to export violations in a settlement with the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the Northern District of California, and resolved a civil enforcement action brought by the U.S. Department of Commerce, Bureau of Industry and Security related to the same underlying conduct.

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

For more information, contact: Michael Atkinson, Caroline Brown, Anand Sithian, Scott Wise, Jeremy Iloulian, Kelsey Clinton, Andrew Schlegel

Crowell Webinars

Supply Chain Mapping in the Era of National Security: Strategies for Trade Compliance, Tariff Mitigation, and Human Rights Risk
 
Register Here

September 18, 2025, 12:00 p.m. EDT – 1:00 p.m. EDT

In today’s geopolitical climate, national security has emerged as a central driver of global trade policy, reshaping how governments scrutinize supply chains and enforce trade compliance. From the Uyghur Forced Labor Prevention Act and Section 301/232 tariffs to escalating government inquiries, companies must now treat supply chain transparency as a core legal and operational imperative.

Join experts from Crowell & Moring and CGA for a timely and practical discussion on the critical role of supply chain mapping in navigating today’s trade landscape. This webinar will provide concrete guidance on:

  • How mapping supports tariff mitigation strategies and Country of Origin determinations
  • The role of mapping in forced labor investigations, UFLPA detentions and Withhold Release Orders (WROs) and findings
  • Best practices for compliance with U.S. national security-driven trade restrictions
  • How understanding your supply chain is necessary to mitigate sustainability/ESG concerns
  • Leveraging mapping tools to proactively identify and manage supply chain risks

Whether you are responding to government inquiries, structuring resilient supply chains, identifying tariff mitigation avenues or preparing for increased enforcement, this session will equip you with the tools and knowledge to stay ahead.

Speakers: Juge Gregg, Monica Gorman, David Stepp, Pierfilippo Natta

Crowell Speaks

“The Cross-Industry Aftermath of the de minimis Changes: How Companies Are Transitioning E-Commerce Fulfillment to Maintain Efficiency and Cost Control,” ACI’s 14thAdvanced Forum on U.S. Customs Compliance and Enforcement, Arlington, VA (October 8, 2025). Speaker: John Brew

“Fraud, Fakes, and Foreign Threats: Identity Verification and Secure Comms in the Age of DPRK Remote Worker Schemes,” Armor Text Webinar (September 25, 2025). Speaker: Caroline Brown

Attorneys Speculate on Timing of SCOTUS Review of IEEPA Cases
August 28, 2025 – Trade Law Daily
Related Professional: Dan Wolff 

“Transshipment Tariffs, UFLPA Enforcement, & Supply Chain Exposure,” Webinar (August 21, 2025). Speaker: David Stepp

Trump Pondering Executive Order Implementing ‘Transshipment’ Tariffs, Defining Non-Local Content Rules, as Soon as Next Week, Sources Say
August 21, 2025 – The Capital Forum
Related Professional: David Stepp

Customs lawsuits under False Claims Act likely to surge, industry experts say
August 13, 2025 – Global Trade Review
Related Professional: Jason Crawford

“Trade Under Pressure: Navigating the Business Impact of Rising U.S. Tariffs,” Los Angeles Area Chamber of Commerce Global Initiatives Council (August 12, 2025). Moderator: Nicole Simonian

“Navigating U.S. country of origin rules: substantial transformation & essential character explained,” CustomsClear’s Non-Preferential Origin: Theory and Practice Webinar (August 7, 2025). Speaker: Heather Sanborn

“Navigating Remote Worker Deception,” The Lock & Key Lounge Podcast (June 28, 2025). Guest: Caroline Brown

Contacts

Insights

Client Alert | 8 min read | 09.09.25

FTC Stops Defending Rule Banning Noncompete Agreements, Opting Instead for “Aggressive” Case-by-Case Enforcement

On September 5, 2025, the Federal Trade Commission (“FTC”) withdrew its appeals of decisions issued by Texas and Florida federal district courts, which enjoined the FTC from enforcing a nationwide rule banning almost all noncompete employment agreements. Companies, however, should not read this decision to mean that their noncompete agreements will no longer be subjected to antitrust scrutiny by federal enforcers. In a statement joined by Commissioner Melissa Holyoak, Chairman Andrew Ferguson stressed that the FTC “will continue to enforce the antitrust laws aggressively against noncompete agreements” and warned that “firms in industries plagued by thickets of noncompete agreements will receive [in the coming days] warning letters from me, urging them to consider abandoning those agreements as the Commission prepares investigations and enforcement actions.”...

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