Insights

On August 28, 2025, France, Germany, and the UK (the E3) initiated the process to reinstate (or snapback) UN sanctions on Iran. The snapback mechanism (which was set to expire on October 18, 2025) is outlined in UN Security Council Resolution 2231 (UNSCR 2231).

On August 29, 2025, the Department of Justice (DOJ) and the Department of Homeland Security (DHS) launched a cross-agency Trade Fraud Task Force to expand efforts to target importers and other parties committing trade-related fraud. As stated in a press release issued on August 29, the Task Force will augment the existing coordination mechanisms within the DOJ and DHS, for instance through partnerships with CBP and Homeland Security Investigations, to “aggressively” take enforcement measures against parties that commit tariff evasion or attempt to smuggle prohibited goods into the U.S.

On his first day in office, President Trump rolled out a sprawling set of directives to the heads of numerous government agencies charged with shaping U.S. trade policy.  While stopping short of enacting new tariffs, the Presidential Memorandum defining an “America First Trade Policy” lays the investigative groundwork for potentially sweeping changes to tariffs and the existing trade environment.   The Memorandum requires various agencies—including, e.g., the Department of Commerce, the Department of the Treasury, and the Office of the U.S. Trade Representative (“USTR”)—to issue upward of twenty reports by April 1, 2025, each one covering a unique trade-related issue pertaining to certain key themes, including unfair and unbalanced trade with all U.S. trading partners, the relationship and impact of trade relations with the People’s Republic of China, and the state of economic security matters relevant for goods entering and exiting the United States.