On October 21, 2025, the US Department of Commerce’s International Trade Administration (“ITA”) announced the implementation of the July 23, 2025 Executive Order (“EO”) Promoting the Export of the American AI Technology Stack (the “American AI Exports Program”). Following our earlier post addressing the White House’s AI Action Plan and the EO, this update focuses on the implementation of the EO and the ITA’s request for public feedback. As a reminder, the EO directs the Secretary…
On August 26, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule removing the Syrian Sanctions Regulations (31 CFR Part 542) from the Code of Federal Regulations (“OFAC Final Rule”). This action follows the issuance of Executive Order (“EO”) 14312 on June 30, 2025, which terminated the national emergency declared in EO 13338 and revoked multiple Syria-related sanctions authorities. Our blog post on the issuance of EO…
On August 25, 2025, the US Department of Defense (“DoD”) issued a Final Rule amending the Defense Federal Acquisition Regulation Supplement (“DFARS”) to prohibit DoD contracting officers from awarding certain consulting services contracts to contractors where they or their subsidiaries or affiliates hold contracts and subcontracts that involve providing “consulting services” to “covered foreign entities” (“CFEs”) unless they implement a conflict-of-interest mitigation plan. The prohibition applies specifically to contracts assigned a North American Industry Classification…
On August 25, U.S. Customs and Border Protection (“CBP”) issued a draft Federal Register notice to effectuate the President’s Executive Order (“EO”) on “Addressing Threats to the United States by the Government of the Russian Federation,” which imposed additional tariffs on imports of Indian origin due to India directly or indirectly importing Russian oil. Under these new tariffs, imports of most goods of Indian origin will be subject to an additional 25% duty, effective August 27, which will stack…