Insights on International Trade & Investment

It’s hard not to experience whiplash with export controls recently. A little over a month ago, the Bureau of Industry and Security (BIS) announced the new Affiliates Rule, which took effect immediately on September 29.

On October 29, the US Citizenship and Immigration Services (USCIS) announced that, effective October 30, timely filed Employment Authorization Document (EAD) extensions will no longer be automatically extended 540 days while the EAD extension application is pending.

Lucas A. Rock was quoted on how recent labor provisions in trade agreements with Cambodia and Malaysia and frameworks for deals with Thailand and Vietnam signal increased focus on forced labor enforcement.

International Trade & Investment Partner Megan Barnhill will speak at a CLE program presented by the Virginia State Bar on October 29, 2025.

Food, Drug, Medical Device & Cosmetic Partner Emily Cowley Leongini and International Trade & Investment Associate Mario Torrico will speak at SupplySide Global 2025.

On September 19, President Trump signed a proclamation imposing an additional $100,000 fee on the entry of certain H-1B employees into the United States, effective September 21.

Welcome to the October 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.

Partner Antonio Rivera was quoted on the impact of China’s expanded rare earth export controls and the United States’ responding tariffs on global supply chains.

E-Verify is a web-based federal program where employers verify identity and work authorization of employees. E-Verify is operated by the US Citizenship & Immigration Service (USCIS), which is within the US Department of Homeland Security (DHS).

International Trade & Investment Partner and Energy & Cleantech Industry Co-Leader, Antonio Rivera will present on the evolving landscape of U.S.-China trade policy and its impact on the battery supply chain at The Battery Show Conference on October 8, 2025.

The Bureau of Industry and Security (BIS) updated its Entity List FAQs, providing some additional guidance about the “Affiliates Rule” that came into effect on September 29.

On September 26, the US Department of Commerce, through its Bureau of Industry and Security (BIS), announced the initiation of a new Section 232 investigation into “robotics and industrial machinery” and its parts and components.

International Trade & Investment Associate James Kim will be featured on a panel discussing the US manufacturing of key components needed to build a robust PV manufacturing ecosystem at the PV CellTech USA Conference on October 7, 2025.

On September 29, the Bureau of Industry and Security (BIS) issued an interim final rule that significantly expands end user controls under the Export Administration Regulations (EAR) by extending restrictions to foreign entities owned, directly or indirectly, 50% or more by one or more parties on specified lists of proscribed companies, including the Entity List.

On September 19, President Trump signed a Proclamation imposing an additional $100,000 fee on the US entry of certain H-1B employees, effective September 21.

Join International Trade & Investment Associate James Kim and Director of North American Manufacturing Birgit Matthiesen at the Canadian Transportation Equipment Association (CTEA)’s Annual Manufacturers’ Conference 2025.

On September 15, US Customs and Border Protection (CBP) updated its guidance to implement President Trump’s September 4 Executive Order (EO) laying out terms of the US-Japan trade agreement and the phased reduction of selected US tariffs on Japanese goods.

Welcome to the September 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.

The affected facilities, which are owned by companies based in South Korea and Taiwan, will have to contend with licensing requirements in order to receive exports, re-exports, and transfers of controlled items from their parent companies and suppliers.

On July 22, President Trump announced that the United States and Japan had reached a bilateral trade agreement.

After a three month wait, the US Department of Commerce’s Bureau of Industry and Security (BIS) has finally caught up with the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) in relaxing restrictions on trade with Syria, but this time in the export control world.

Customs & Import Compliance Practice Group Leader Angela Santos was quoted on the federal appeals court’s ruling that the Trump Administration could not use the International Emergency Economic Powers Act (IEEPA) to authorize sweeping worldwide tariffs.

Lucas A. Rock was quoted on how the ending of the de minimis tax exemption is impacting international retailers importing goods into the United States and their intended consumers.

ArentFox Schiff is pleased to announce that 132 attorneys have been recognized by The Best Lawyers in America 2026, with two attorneys highlighted as “Lawyers of the Year” and 66 attorneys listed as “Ones to Watch.”

Following weeks of anticipation, the US Department of Commerce has issued its formal determination expanding the list of steel and aluminum products subject to the 50% ad valorem duties imposed under Section 232.