Category:United States

1
Implications of New “Secondary Tariff” Executive Order Targeting Importers of Venezuelan Oil
2
Trump Administration Directs CFIUS to Tighten Restrictions on Investment From Certain Countries While Easing National Security Reviews of Investments From Allies and Partners
3
New Executive Order Bolsters the Nation’s Cyber Defenses
4
New US Sanctions Target Russia’s Energy Sector
5
Preparing for New Trump Tariffs: 10 Approaches
6
Final Rule on Outbound Investments: Implications for Limited Partner Investments
7
Trump Signals First-Day Tariff Hikes Targeting China, Canada, and Mexico
8
AI National Security Memorandum Scopes Key Priorities
9
Understanding the Cybersecurity Maturity Model Certification (CMMC) Program: Essential Steps for Defense Contractors

Implications of New “Secondary Tariff” Executive Order Targeting Importers of Venezuelan Oil

By: Steven F. Hill, Guillermo S. Christensen, Jeff Orenstein, and Brian J. Hopkins

On 24 March 2025, the White House issued an Executive Order threatening to impose a 25% tariff on all goods imported into the United States from any country that imports Venezuelan oil directly or indirectly through third parties. Effective on or after 2 April 2025, the tariff is in response to alleged actions of Venezuela’s Maduro government, in particular sending members of the Tren de Aragua gang (designated a foreign terrorist organization) and other criminals into the United States and its involvement in kidnapping and violent attacks including the assassination of a Venezuelan opposition figure.

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Trump Administration Directs CFIUS to Tighten Restrictions on Investment From Certain Countries While Easing National Security Reviews of Investments From Allies and Partners

By: Guillermo S. Christensen, Steven F. Hill, Brian J. Hopkins, Dave R. Allman, Nate B. Bolin, and Jeffrey Orenstein

On 21 February 2025, President Donald J. Trump issued the America First Investment Policy, directing the Committee on Foreign Investment in the United States (CFIUS) to adjust its approach to foreign investments. This policy aims to facilitate investments from allied nations while imposing stricter reviews on investments from adversarial countries, particularly China.

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New Executive Order Bolsters the Nation’s Cyber Defenses

By: Sheila Armstrong, Corey Bieber, Guillermo Christensen, Brian Hopkins, and J.D. Koesters

In a significant move to bolster the United States’ cybersecurity framework, President Biden issued an executive order (EO) on 16 January 2025 titled “Strengthening and Promoting Innovation in the Nation’s Cybersecurity” days before leaving the White House. This comprehensive directive outlines measures designed to enhance the security of federal systems, improve transparency in third-party software supply chains, and leverage emerging technologies to fortify cyber defenses.

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New US Sanctions Target Russia’s Energy Sector

By: Nate Bolin, Jeffrey Orenstein, Myeong Park, and Brian Hopkins

On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of new sanctions targeting Russia’s energy sector. In an effort to curtail Russia’s oil revenue and ability to evade US sanctions, OFAC issued: (1) a Determination authorizing sanctions on parties operating in Russia’s energy sector; (2) a Determination banning US petroleum services to Russia; and (3) blocking sanctions against oil and gas majors, vessels in the so-called “shadow fleet,” certain traders of Russian oil, Russian maritime insurers, and Russian oilfield service providers.

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Final Rule on Outbound Investments: Implications for Limited Partner Investments

By: Steven F. Hill, Nathaniel B. Bolin, and Myeong S. Park

Introduction

On 28 October 2024, the US Treasury Department issued a Final Rule implementing the Outbound Investment Program (OIP) under Executive Order 14105, which safeguards US national security by limiting investments by US persons in key technologies in “countries of concern,” specifically China including Hong Kong and Macau. Effective 2 January 2025, the OIP targets outbound investments in Semiconductors and Microelectronics, Quantum Information Technologies, and Artificial Intelligence by prohibiting certain transactions and permitting other transactions subject to a notification requirement (together, “covered transactions”).

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Trump Signals First-Day Tariff Hikes Targeting China, Canada, and Mexico

By: Nate Bolin, Dave Allman, and Brian Hopkins

On 25 November, President-Elect Donald Trump announced plans to impose substantial tariffs on goods from China, Mexico, and Canada through executive action, signaling a return to his aggressive trade policies. If implemented, these measures could have significant implications for businesses reliant on international supply chains.

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AI National Security Memorandum Scopes Key Priorities

By: Corey Bieber, Guillermo Christensen, Brian Hopkins

On 24 October 2024, the Biden Administration issued a National Security Memorandum on Advancing the United States’ Leadership in Artificial Intelligence; Harnessing Artificial Intelligence to Fulfill National Security Objectives; and Fostering the Safety, Security, and Trustworthiness of Artificial Intelligence (NSM), underscoring the United States’ commitment to leading globally in the responsible development, application, and regulation of artificial intelligence (AI). The Administration’s 30 October 2023 Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence led to the creation of the NSM, which was a key deliverable.

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Understanding the Cybersecurity Maturity Model Certification (CMMC) Program: Essential Steps for Defense Contractors

By: Sheila Armstrong, Corey Bieber, Guillermo Christensen, J.D. Koesters

The Department of Defense (DoD) published the updated Cybersecurity Maturity Model Certification (CMMC) Program to enforce existing cybersecurity standards across the defense industrial base. This program is designed to ensure the protection of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) from growing cyber threats. CMMC requirements will be phased into contracts starting in 2025, marking a shift in accountability for safeguarding non-public information throughout the Defense Industrial Base (DIB).

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