Global Trade & Foreign Policy Insights

The U.S. Department of Commerce, through its Bureau of Industry and Security (BIS), continues to actively pursue investigations under Section 232 of the Trade Expansion Act of 1962. These investigations aim to determine whether specific imports threaten to impair U.S. national security. In recent months, BIS has significantly broadened the scope of its inquiries, reflecting heightened concerns over supply chain resilience, critical infrastructure, and technological competitiveness. This alert provides an overview of the currently active investigations and offers practical guidance for stakeholders, including how to participate in the public comment process.

On May 28, 2025, the U.S. Court of International Trade (CIT) ruled as unlawful two types of tariffs imposed by President Trump through executive orders implemented under the International Emergency Economic Powers Act (IEEPA).

Over are the days of carefree selling to and offshoring supply chains through China for leading-edge semiconductors and the technologies and equipment used to produce them. On October 7, 2022, the U.S. Department of Commerce’s (“Commerce”) Bureau of Industry and Security (BIS) announced surgically precise and novel export controls targeting China’s[1] semiconductor and advanced computing industries. According to the BIS Press Release, the new controls will restrict China’s ability “to produce advanced military systems including weapons of mass destruction; improve the speed and accuracy of its military decision making, planning, and logistics, as well as of its autonomous military systems; and commit human rights abuses.”

On January 14, 2020 the Trump administration issued an interim rule identifying several countries and one individual as “foreign adversaries” under E.O. 13873, “Securing the Information and Communications Technology and Services (ICTS) Supply Chain.”