Top Story

Modern Slavery Enforcement

April has seen enforcement actions on Chinese work gloves, South Korean Sea Salt, and most recently a petition based on evidence of modern slavery in the Brazilian coffee industry.

Welcome to your new Export Practitioner

The Export Practitioner introduces a web-based format for easier review, research and sharing.

In addition to your monthly print or e-edition, we can furnish mid-month updates for our readers.

We seek your input as we make this transition. Please send your suggestions to fruffing@traderegs.com or call 703.283.5220.

– Frank Ruffing, Editor

April 2025 Export Practitioner

View this issue

Browse other issues

CFIUS and America First: Faulkender Speech

Deputy Secretary of the Treasury Michael Faulkender emphasized the Trump Administration’s commitment to balancing foreign investment with national security at the American Conference Institute’s CFIUS Conference Thursday April 24, , detailing the Administration’s initiatives under the newly issued “America First Investment Policy.”

IMF Slashes Growth Forecast

The International Monetary Fund (IMF) on Tuesday slashed its global growth forecast for 2025 to 2.8%, down from 3.3% in January, citing a sharp rise in tariffs and growing policy uncertainty. The United States faces one of the steepest revisions, with growth now projected at 1.8%, compared to a previous estimate of 2.7%.

Bessent says chill, re-center

U.S. Treasury Secretary Scott Bessent told investors at a closed-door JPMorgan Chase summit Tuesday that the ongoing trade conflict between the United States and China is “unsustainable,” and indicated that both sides would need to find ways to de-escalate. In a speech the next day Bessent called for a "recentering" of the missions of the IMF and World Bank.

IEEPA Tariff FAQs Published

US Customs & Border Protection has published an FAQ page on the International Emergency Economic Powers Act (IEEPA) as it relates to tariffs.

Legal Challenges to IEEPA Tariffs Stack Up

As of April 25, 2025, seven lawsuits have been filed challenging President Trump’s imposition of tariffs under the International Emergency Economic Powers Act (IEEPA), a 1977 statute traditionally used for targeted economic sanctions.

Trucks and Minerals Trade Investigations

The U.S. Department of Commerce announced the initiation of two separate national security investigations under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. § 1862). The investigations will evaluate the impact of (1) processed critical minerals and their derivative products, and (2) imports of medium- and heavy-duty trucks and related parts, on the national security of the United States.

Syria Sanctions: UK Moves Forward with Relief

The United Kingdom announced substantial amendments to its Syria sanctions regime, signaling a strategic shift in support of Syria’s post-Assad reconstruction. The updated regulations lift sanctions on 12 Syrian entities and remove restrictions in select sectors, including financial services and energy production.

Read more of our coverage of Sanctions

Policy Briefs

China Committee Targets PRC Telecoms

The House Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party has issued subpoenas to China Mobile, China Telecom, and China Unicom—three state-owned Chinese telecommunications firms—for failing to respond to a bipartisan request for information dated March 4. The subpoenas, which require compliance by May 7, 2025, are part of an ongoing congressional investigation into whether the companies continue to operate within the United States in ways that may endanger national security or compromise the privacy of U.S. citizens.

State Dept. Warns of Using Chinese Networks

A confidential State Department memo obtained by Nextgov/FCW and Defense One advises U.S. diplomats to warn international partners against doing business with Chinese satellite communications providers, citing risks of espionage and military exploitation by Beijing. The memo also addresses the geopolitical implications of relying on U.S.-based satellite services, notably SpaceX’s Starlink.

America First Trade Policy Reports In

On April 3, 2025, the Trump Administration announced the America First Trade Policy Report, a 24-chapter document addressing U.S. trade imbalances, non-reciprocal practices, and national security concerns. The reports themselves were not made public, rather the White House released a brief summary of the report, noting that chapters include reviews of unfair foreign trade practices, renegotiation of the U.S.-Mexico-Canada Agreement (USMCA), and assessments of foreign currency manipulation and existing trade agreements.

Supply Chain

Critical Minerals 232 Investigation

President Trump has signed an Executive Order directing the Secretary of Commerce to initiate a Section 232 investigation under the Trade Expansion Act of 1962 into the national security implications of U.S. reliance on imported processed critical minerals and their derivative products.

Senator Shaheen Presses Pentagon on Trade War’s Impact on Military Readiness

Senator Jeanne Shaheen (D-NH), a senior member of the Senate Armed Services Committee and Ranking Member of the Senate Foreign Relations Committee, sent a letter to Defense Secretary Pete Hegseth raising concerns over the national security implications of President Trump’s sweeping tariffs. Shaheen warned that tariffs imposed on imports from nearly every country risk undermining the Department of Defense’s purchasing power, weakening industrial supply chains, and driving up costs for defense contractors—particularly small businesses.

USMCA Action in Mexican Parts Plant

The Office of the United States Trade Representative has invoked the Rapid Response Labor Mechanism (RRM) in the United States-Mexico-Canada Agreement (USMCA) to review whether workers at Modern Metal Alloys, S.A. de C.V. (MMA), located in Querétaro, Mexico, are being denied the right to freedom of association and collective bargaining.

GOP Senators Call to Scrap AI Diffusion Rule

Seven Republican senators have sent a letter to Secretary of Commerce Howard Lutnick urging the Trump administration to withdraw the Biden-era Artificial Intelligence Diffusion Rule (AIDR). The senators argue that the rule, which imposes tiered restrictions on global access to U.S. AI technology, threatens American innovation and global competitiveness while failing to adequately counter China’s ambitions.

Warren Presses Commerce to Block Nvidia China Exports

Senator Elizabeth Warren (D-Mass.), Ranking Member of the Senate Banking Committee, has called on the Department of Commerce to immediately block exports of Nvidia’s H20 and other advanced AI chips to the People’s Republic of China (PRC), citing national security concerns and reports of undue influence in the administration’s export control decisions.

White House Orders Arms Sales Reform

President Trump Wednesday signed a sweeping executive order aimed at overhauling the U.S. foreign defense sales system, seeking to reduce delays and regulatory barriers in the sale of military equipment to international partners. The directive—“Reforming Foreign Defense Sales to Improve Speed and Accountability”—initiates a broad set of reforms to the Foreign Military Sales (FMS) and Direct Commercial Sales (DCS) processes, with the stated aim of improving delivery predictability, enhancing allied burden-sharing, and invigorating the domestic defense industrial base.

Read more of our Export Control coverage

Licensing

DDTC Arms Sales Report Released

The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) has released its Annual Report to Congress on Direct Commercial Sales (DCS) Authorizations to Foreign Countries and International Organizations for Fiscal Year (FY) 2024.

Advisory Committees Under New Regime

The Bureau of Industry and Security (BIS) appears to be planning to keep at least some of the Technical Advisory Committees (TACs) which have long defined the collaborative nature of export enforcement and trade security. The candor and efficacy of the new regime may be different though.

Missile Tech Rules in New World Order

As the Trump administration adopts a unilateral approach to arms control and regional defense, customary avenues of discussion are being reassessed, including multilateral export controls.