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The Month in International Trade – June 2025

Client Alert | 9 min read | 07.07.25

Former Microsoft Assistant General Counsel Scott Wise Joins Crowell & Moring

Top Trade Developments

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.

Former Microsoft Assistant General Counsel Scott Wise Joins Crowell & Moring

Scott Wise, most recently assistant general counsel for global trade at Microsoft, has joined Crowell & Moring as a partner in the firm’s International Trade Group.

During his time at Microsoft, Wise led a consolidated team focusing on export controls, economic sanctions, and outbound investment. He was the lead export controls and economic sanctions attorney for key business groups ranging from emerging technologies including artificial intelligence and quantum computing to aerospace and defense contracts, to commercial software and gaming. In that role, Wise developed Microsoft’s compliance approach to new regulations governing the export of a range of new technologies, including AI, integrated circuits and chips, and quantum computing, which involved coordination between senior government officials and business leaders.

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Top Trade Developments

Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System

Reflecting the administration’s continued focus on transnational cartels, on June 25, 2025, FinCEN identified three Mexican financial institutions as “primary money laundering concerns,” and imposed restrictions on U.S. financial institutions from engaging in transactions with these entities.

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For more information, contact: Erik Woodhouse, Carlton Greene, Anand Sithian, Alexander J. Kramer, Caroline Brown, Kelsey Clinton, Rachel Bogin

Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers

On June 23, 2025, the Ninth Circuit issued a long-awaited decision in Island Industries Inc. v. Sigma Corp. affirming a $26M False Claims Act (“FCA”) judgment against the defendant importer. Sigma had appealed the judgment after a jury found the company violated the FCA by failing to pay customs duties owed to U.S. Customs and Border Protection (“CBP”). The Ninth Circuit’s decision addresses an important jurisdictional issue and illustrates the significant financial exposure importers can face under the FCA at a time of increased tariffs and enforcement by the government.

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For more information, contact: Jason Crawford, John Brew, Derek Hahn, Brian Tully McLaughlin, Maria Vanikiotis, Simeon Yerokun

CBP Issues First Comprehensive Guide to Modifying a Withhold Release Order (WRO)

An update on Anti-Forced Labor guidance issued by US Customs in the context of Withhold Release Orders (WROs).

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For more information, contact: David Stepp, Simeon Yerokun, Pierfilippo Natta, Sibilla Grenon, Andrew Schlegel

CBP Announces Forced Labor Allegations Portal Rollout

On June 20, 2025, U.S. Customs and Border Protection (“CBP”) deployed its new Forced Labor Allegations Portal, which allows users to submit allegations of forced labor. The new portal replaces CBP’s Trade Violations Reporting (“TVR”) system for submitting forced labor allegations, and complaints can be submitted anonymously by trade users.

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For more information, contact: Simeon Yerokun, Pierfilippo Natta, and Andrew Schlegel

Steel Tariffs Doubled: How the Hike Could Reshape Construction Projects at Home and Aboard

To date the Trump Administration has issued multiple proclamations imposing varying rates of import duties on steel and aluminum and certain derivatives, including construction materials. These measures have added volatility and financial pressures to the construction sector both in the United States and abroad. Most recently, on June 3, 2025, President Donald Trump issued a proclamation under Section 232 of the Trade Expansion Act of 1962, doubling tariffs on imported steel and aluminum from 25% to 50%, effective June 4, 2025. This action aims to counteract the continued influx of lower-priced, excess steel and aluminum imports that, according to the administration, threaten U.S. national security by undermining domestic production capacity. The proclamation notes that while prior tariffs provided some price support, they were insufficient to achieve the necessary capacity utilization rates for sustained industry health and defense readiness. The United Kingdom remains temporarily exempt at the 25% rate until July 9, per the U.S.-U.K. Economic Prosperity Deal.

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For more information, contact: T. Michael Guiffre, Dan Cannistra, Edmund Northcott, Taylor Wilson Whitaker

Crowell Podcasts

Global Trade Talks: Tariffs-IEEPA Litigation Update

June 6, 2025

Continuing to focus on the Trump Administration tariffs, in this session, Crowell hosts Nicole Simonian and Dj Wolff, Co-Chairs of the International Trade Group, talk with Daniel Wolff, Crowell’s Litigation and Trial partner, as they review and consider the impact of the Court of International Trade's recent decision on the tariffs imposed pursuant to the International Emergency Economic Powers Act (IEEPA). 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.

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PodBean | SoundCloud | Apple Podcasts

Crowell Speaks

“Legal Fallout and Lessons Learned—Navigating Liability, Disclosure, and Compliance After Remote Worker Deception,” Clear/Armor Text Insiders, Imposters & Incident Response, New York (June 26, 2025). Speaker: Caroline Brown

“Navigating the Implications of New Tariffs on Global Ingredient Sourcing and Supply Chain Operations for Dietary Supplement Companies,” ACI’s 13th Annual Legal, Regulatory and Compliance Forum on Dietary Supplements, New York (June 25, 2025). Speaker: Maria Vanikiotis

The Intersection of Transportation, Trade, and Supply Chain Policies
June 24, 2025 – NASDAQ Trade Talks
Related Professional: Dan Cannistra, Monica Gorman

“The Weakest Link: Navigating Third-Party and Supply Chain Risk,” ACSS New York Chapter, New York (June 12, 2025). Speaker: Anand Sithian

“The Rise of Digital Sovereignty Models,” Coalition of Service Industries “2025 Global Services Summit,” Washington D.C. (June 10). Speaker: Nigel Cory

Industry Input Is Key As EU Weighs New Tariffs on US Trade
June 9, 2025 – Law360
Related Professional: Vassilis Akritidis, Jean-Baptiste Blancardi

“Supply Chains & Geography,” Industry Studies Association Annual Conference, Massachusetts Institute of Technology, Cambridge, MA (June 6, 2025). Speaker: Monica Gorman

Written and Oral Testimony, Hearing on "Dominance by Design: China Shock 2.0 and the Supply Chain Chokepoints Eroding U.S. Security," U.S.-China Economic and Security Review Commission, Washington DC (June 5, 2025) Speaker: Monica Gorman

“The New Face of AML & Sanctions,” New York City Global AML & Sanctions Symposium, New York (June 5, 2025). Speaker: Dj Wolff

“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, Webinar (June 4, 2025). Speaker: John Brew

“Navigating Tariffs,” Giga USA 2025, Washington DC (June 4, 2025). Speaker: Zhiwei Chen

Antitrust Risks in A Trade War, Webinar (June 4, 2025). Speakers: Stefan M. Meisner, Luke van Houwelingen, and Eric Fanchiang

Roundtable - Navigating U.S. & EU Sanctions and De-mystifying U.S. Tariffs for European Companies, Brussels (June 2, 2025). Speakers: Erik Woodhouse and Vassilis Akritidis

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Insights

Client Alert | 4 min read | 07.25.25

EU Adopts the Largest Ever Trade Countermeasures Against the U.S. to Apply if EU-U.S. Trade Negotiations Fail

On July 24, the European Commission announced the imposition of new EU countermeasures in response to U.S. tariffs further to an agreement reached among EU Member States. These measures are adopted through Commission Implementing Regulation (EU) 2025/1564 and take the form of additional customs duties on U.S. products as well as export restrictions for certain EU products. In total, these measures concern about EUR 93 billion ($109 billion) worth of customs duties, the highest volume of bilateral trade caught by the EU so far. The EU countermeasures are set to enter into force as of August 7....

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