Trump’s Policy Playbook

President Trump’s Executive Order (EO) 14187, “Protecting Children from Chemical and Surgical Mutilation,” represents a significant shift in federal policy regarding gender-affirming care (GAC) for minors.

Welcome to the April 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

Health Care Practice Leader Douglas A. Grimm was quoted by Relias Media, urging hospitals and health care providers to prepare for potential Immigration and Customs Enforcement raids at their locations, following the Trump administration’s revocation of policies that previously made hospitals off-limits for immigration enforcement.

On March 26, the Trump Administration announced a sweeping new trade action: a 25% tariff on imported automobiles and certain automobile parts from all countries, under Section 232 of the Trade Expansion Act of 1962.

On March 27, the US Department of Health and Human Services (HHS) announced a significant restructuring initiative in accordance with President Trump’s Executive Order, “Implementing the President’s Department of Government Efficiency Workforce Optimization Initiative.”

The electric mobility industry faces significant challenges, to be sure. With the Inflation Reduction Act (IRA) of 2022 in peril, leaner times may be ahead.

On January 20, the US Department of Homeland Security (DHS) rescinded 2021 guidelines that previously designated hospitals, clinics, and other health care facilities as “protected areas” and limited immigration enforcement actions in or near such locations.

The new Administration under President Trump is now over a month old, but there remains some uncertainty as to how the Administration will approach agricultural policy. The Administration’s first wave of environmental pronouncements have focused mainly on energy and climate initiatives, while some of the messaging challenging agricultural tools like pesticides have signaled a possible departure from the deregulatory approach of the prior Trump Administration.

Foreign nationals and employers should plan all international travel more carefully and further in advance. This is not a travel ban but has opened the path to create a travel ban in the future, as he did in his earlier Administration.

On March 1, President Trump issued an Executive Order (EO) requiring the US Department of Commerce (Commerce) to investigate the national security implications in connection with imports of timber, lumber, and their derivative products.

On February 25, President Trump issued an executive order (EO) requiring the US Department of Commerce (Commerce) to investigate the national security implications of the copper supply chain. The investigation will be based on section 232 of the Trade Expansion Act of 1962.

On January 20, the US Department of Homeland Security (DHS) rescinded 2021 guidelines that prohibited immigration enforcement actions in or near medical and health care facilities and other protected areas. Hospitals and other health care facilities should consider the impact this policy change may have on their workforces and patient populations and develop appropriate protocols for responding to an immigration enforcement action on their premises.

With 2025 underway, the AFS Health Care team highlights some of the most pressing legal issues facing the health care industry this year.

The Trump Administration is beginning to roll out its policy plans to “dominate” the global energy space. These plans tackle energy transition issues in a dramatically different manner than did the Biden Administration, particularly by leaning into fostering the development of resources, including fossil fuels, nuclear, and hydroelectric power that provide reliable “baseload” supply. This comes as no surprise given President Trump’s promise to “drill, baby, drill” at the inauguration.

In 2025, the retail and fashion industries are bracing for a transformative year, heavily influenced by the policies of the new Trump Administration. These policies promise rapid and significant changes, particularly in areas such as trade, tariffs, and immigration, which will profoundly affect global supply chains and labor dynamics.

In an unprecedented and highly fluid series of US trade announcements emanating from Washington, DC, the latest Executive Orders (EOs) announced this past Friday and this week’s EO on steel imports did little to calm c-suite jitters.

As of this writing on February 3, the president’s long awaited new tariffs have been officially announced via Executive Orders (EOs) from the White House for Canada, Mexico, and China. They confirm media reports of new 25% tariffs for imports from Canada (except energy resources) and Mexico and 10% for imports from China entered on and after February 4. Canadian energy resources will be subject to a 10% tariff. The rates of duty are in addition to any other duties, fees, exactions, or charges applicable to such imported articles.

The Trump Administration has issued a memo directing a temporary freeze on all environmental litigation to allow for review and potential reconsideration by the new Administration of its position in these matters.

At the Oval Office signing ceremony on January 20, President Trump announced plans to impose 25% tariffs on imports from Mexico and Canada. The following day, President Trump extended this tariff threat to include additional 10% tariffs on goods from China, further escalating trade tensions with these key trading partners. According to Trump, the tariffs on China, Canada, and Mexico will take effect on February 1. However, there is still uncertainty about whether this deadline will be met or if it is being used as a negotiation tactic.

Many parties are rightly concerned about the impact of yesterday’s announcement that nearly all federal funds will be frozen for an indeterminate period. Minutes before it was intended to go into effect today, a federal judge in Washington, DC, temporarily ordered the freeze to be lifted until at least Monday February 3, when a full hearing will occur as to whether the freeze is permissible under federal administrative procedure laws and the First Amendment.

Health Care Practice Leader Douglas A. Grimm was quoted by Law360, urging hospital leaders and lawyers across the country to start implementing new strategies after the Trump Administration pulled back a Biden Administration 2021 directive to avoid immigration enforcement at certain locations, including hospitals.

The US Customs Agency, established in 1789 under the US Department of the Treasury, has undergone significant transformations throughout its history. Initially focused on revenue collection and trade regulation, the agency’s role expanded to include national security functions following its integration into the US Department of Homeland Security (DHS) in 2003 pursuant to the Homeland Security Act of 2022 (HSA).

President Trump has been explicit in his focus on immigration compliance and enforcement. Employers should expect increased workplace enforcement actions, including US Immigration and Customs Enforcement (ICE) raids and unannounced workplace enforcement actions.

Every president since George Washington has used the power of the executive order to achieve policy goals, set uniform standards for managing the executive branch of government, or influence the behavior of private citizens. In Washington’s case, orders were issued requiring executive departments to prepare reports for his inspection, and a proclamation was issued for the Thanksgiving holiday.

Following his inauguration on January 20, President Trump signed a slew of executive orders, including a handful related to Diversity, Equity, and Inclusion (DEI) initiatives.