IEEPA Tariffs on China, Mexico, and Canada

We previously covered President Trump’s IEEPA tariffs and the various retaliatory tariff and nontariff countermeasures announced by each country in separate posts. Currently, the Mexico and Canada tariffs have been paused until March 10, and only the 10% tariffs on China are in effect.

Read also: Week Two in Trade – First 100 Days of the New Administration

Removal and Reinstatement of De Minimis Exemption for Low-Value Imports

Following President Trump’s removal of the de minimis exemption last week, on Friday, February 7, 2025, President Trump issued an amendment to his original Executive Order and temporarily reinstated the exemption until “notification by the Secretary of Commerce to the President that adequate systems are in place to fully and expediently process and collect tariff revenue for all Chinese products.”

It is unclear how long this pause will last. Once removal of the exemption resumes, such requests for de minimis entry and clearance will likely be rejected. U.S. Customs and Border Protection’s CSMS #63992482 previously provided guidance on how the duties would be enforced in the Automated Commercial Environment (“ACE”) system by mode of transportation and clearance type.

Export Controls & Sanctions

Russia

On February 5, 2025, Attorney General Pam Bondi issued a memorandum disbanding the inter-agency Task Force KleptoCapture—along with the Kleptocracy Team, and Kleptocracy Asset Recovery Initiative—which was created following Russia’s invasion of Ukraine to enforce the vast sanctions, export controls, and economic countermeasures imposed on Russia. The Task Force included prosecutors, agents, analysts, and professional staff from a variety of law enforcement agencies, and although it remains to be seen, its unwinding may signal a more relaxed approach to Russian sanctions enforcement or the prioritization of other foreign policy objectives.

Iran

In contrast, earlier in the week President Trump issued a National Security Memorandum (“NSM”) directing multiple U.S. departments and agencies—including the Commerce, Treasury, and Justice Departments—to escalate enforcement of the sanctions and related enforcement remedies against Iran. The NSM specifically directs the Treasury Department (through its Office of Foreign Assets Control) to conduct a “review for modification or rescission any general license, frequently asked question, or other guidance that provides Iran or any of its terror proxies any degree of economic or financial relief.”

Congressional Nominations

The Senate Commerce Committee voted 16-12 to move forward with President Trump’s nominee to head the Commerce Department, Howard Lutnick. While Lutnick stated he will make export control enforcement a top priority, he also indicated a review of controls on current items, including firearms and curtained advanced artificial intelligence semiconductors. Lutnick also plans to review whether the Bureau of Industry and Security is adequately funded. Lutnick’s nomination now moves to the full Senate.