Since his inauguration, President Trump has announced executive orders, presidential memoranda, staffing changes and other actions with far-reaching implications for companies globally. Below is a collection of S&C’s insights on how these policy shifts may affect key sectors and how businesses can adapt to the changing landscape.
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March 12, 2025
On March 12, 2025, President Donald J. Trump’s previously announced steel and aluminum tariffs went into effect. The S&C Tariffs Tracker summarizes the status of various tariffs and trade measures that the Trump administration has announced, is implementing, or is actively considering for implementation. S&C will periodically update this tracker based on further developments, and our team is available should you have questions regarding the tariffs’ applicability.
March 7, 2025
On March 6, 2025, President Donald J. Trump announced that he was partially suspending tariffs on Canada and Mexico once again after briefly permitting them to go into effect. The S&C Tariffs Tracker summarizes the status of various tariffs and trade measures that the Trump administration has announced, is implementing, or is actively considering for implementation. S&C will periodically update this tracker based on further developments.
March 4, 2025
On March 4, 2025, President Donald J. Trump permitted previously suspended tariffs on goods from Canada and Mexico to go into effect and imposed an additional 10% tariff on goods from the People’s Republic of China. The S&C Tariffs Tracker summarizes the status of various tariffs and trade measures that the Trump administration has announced, is implementing, or is actively considering for implementation. S&C will periodically update this tracker based on further developments.
February 25, 2025
On February 21, 2025, President Donald J. Trump issued a memorandum (the “Memorandum”) directing the Secretary of the Treasury, the Secretary of Commerce, and the United States Trade Representative to broadly address foreign taxes and regulations that target American companies, focusing largely on the digital economy. The Memorandum (i) instructs the United States Trade Representative to consider renewing or initiating investigations under Section 301 of the Trade Act of 1974 into foreign countries’ discriminatory digital services taxes; (ii) directs U.S. agencies to consider imposing tariffs and other measures in response to such countries’ taxes or regulations that are designed to extract funds or intellectual property from U.S. businesses; (iii) directs the Secretary of the Treasury to determine whether any foreign tax regimes violate U.S. tax treaties or warrant action under existing tax laws; (iv) calls for a permanent moratorium on customs duties for electronic transmissions; and (v) establishes a new reporting process for U.S. businesses to identify harmful foreign tax or regulatory practices.
February 24, 2025
On February 21, 2025, the U.S. District Court for the District of Maryland issued a preliminary injunction enjoining the federal government from implementing certain provisions of President Trump’s January 20 and January 21 Executive Orders related to diversity, equity, inclusion, and accessibility (“DEI” or “DEIA”), finding those provisions are unconstitutionally vague and infringe upon free speech. Significantly, the court did not enjoin the Attorney General from preparing a “strategic enforcement plan,” or engaging in investigations of DEI practices.
February 21, 2025
President Donald J. Trump announced the administration’s intent to impose a 25% tariff on steel and aluminum imports to the U.S. In response, the EU has stated and reiterated that it will not hesitate to impose countermeasures to safeguard European businesses from unjustified tariffs. Examining the EU’s previous retaliatory measures and two key legal challenges brought by affected companies in the EU Courts provides valuable insight into what businesses can expect in terms of the scope and industries targeted by such responses. The urgency behind the EU’s efforts to respond to recent U.S. trade measures could expose the EU institutions to the risk of breaching fundamental rights of companies exporting goods to the EU. Companies should, therefore, carefully evaluate the implications of EU trade measures on their businesses and, if they are adversely affected by those measures, consider whether to seek redress in the EU Courts.
February 21, 2025
On February 18, 2025, the U.S. General Services Administration (“GSA”) announced that it had issued two deviations to the Federal Acquisition Regulations (“FAR”) and procurement practices. With these deviations, federal agencies will no longer consider companies’ diversity, equity and inclusion (“DEI”) practices when awarding federal contracts for goods and services, reversing a Biden administration policy, and federal contracting officers are allowed to amend or modify current solicitations and contracts without penalty. The GSA stated that these actions were necessary to implement certain Executive Orders issued by President Trump, including the “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” Executive Order.
February 19, 2025
On February 13, 2025, President Donald J. Trump signed a Memorandum directing the U.S. Trade Representative and the Secretary of Commerce, in consultation with other agencies, to develop a plan for imposing reciprocal tariffs on each country that trades with the United States. The U.S. Trade Representative and the Secretary of Commerce are expected to deliver reports to President Trump within the coming months detailing recommended levels of reciprocal tariffs.
February 18, 2025
The NLRB under the Trump administration is expected to implement significant changes to labor policy. As expected, on February 14, 2025, the newly appointed National Labor Relations Board (“NLRB”) Acting General Counsel William Cowen rescinded a series of memoranda that had been issued by the former NLRB General Counsel, Jennifer Abruzzo. Cowen also announced his intent to issue new guidance.
February 13, 2025
On February 10 and 11, 2025, President Donald J. Trump issued two proclamations directing the Secretary of Commerce to broadly adjust duty rates on imported steel, aluminum, and certain downstream goods derived from those materials. The proclamations (i) revoke country-specific exemptions from steel import tariffs for the European Union and eight additional countries, returning to the 25% tariff rate imposed during the first Trump Administration; (ii) increase the tariff on aluminum imports from 10% to 25% while also eliminating associated alternative agreements and exclusions; and (iii) apply the tariff rates to additional downstream or “derivative” goods made of steel and aluminum. The measures are scheduled to take effect on March 12, 2025.
February 12, 2025
On February 10, 2025, President Trump issued an Executive Order directing the Attorney General to pause Foreign Corrupt Practices Act (FCPA) investigations and prosecutions pending the review of all FCPA guidelines and past and existing FCPA investigations and actions. Following this 180-day review period, the Attorney General is directed to issue revised FCPA enforcement guidance that will govern all future or existing FCPA investigations and prosecutions. These revised guidelines will require the Attorney General to “specifically authorize” future FCPA investigations and prosecutions. The Executive Order requires the Attorney General to determine if any “remedial measures” are warranted to address “inappropriate past FCPA” actions.
February 7, 2025
The Department of Justice and Office of Personnel Management recently issued internal memoranda that begin to implement President Trump’s January 2025 Executive Orders related to DEI programs. Among other things, the memoranda direct government agencies to (i) plan for potential criminal investigations of private sector DEI practices; (ii) end diverse slate hiring practices; and (iii) limit employee resource groups. Although the memoranda relate primarily to the federal workforce, they provide insight into the administration’s views and enforcement priorities and are likely to fuel private civil litigation.
February 6, 2025
On February 4, 2025, President Donald J. Trump issued a National Security Presidential Memorandum directing U.S. agencies to tighten enforcement of existing U.S. economic sanctions against the Islamic Republic of Iran and to impose new sanctions and other measures against the country. The Memorandum directs the Secretary of the Treasury and other officials to, among other things, impose a “robust and continual sanctions enforcement campaign,” to “issue updated guidance to all relevant business sectors,” and to consider requiring financial institutions to conduct additional due diligence on Iran-related transactions.
February 4, 2025
The transition of federal antitrust leadership is underway. As the new leadership assumes responsibility, they inherit a long list of new enforcement lawsuits and other regulatory actions that the prior leadership undertook shortly before the transition. We take stock of the various actions and the outlook for them moving forward.
February 3, 2025
On February 1, 2025, President Donald J. Trump issued a trio of executive orders imposing tariffs on goods imported to the United States from Canada, Mexico, and China. The orders announce (i) a 25% tariff on Mexican and Canadian imports, with the exception of Canadian energy products, which are subject to a lesser 10% tariff, and (ii) a 10% tariff on all imports from China. The measures take effect almost immediately, on February 4, 2025. Their enactment already has triggered plans for retaliatory trade measures by the affected countries.
January 30, 2025
On January 27, 2025, President Trump removed Equal Employment Opportunity Commission Commissioners Charlotte Burrows and Jocelyn Samuels and National Labor Relations Board member Gwynne Wilcox, all Democrats, in a series of unprecedented moves. The removed officials all indicated they intend to, or are considering, filing legal challenges to their removals. The removals leave both federal agencies without a quorum.
January 29, 2025
On January 20, 2025, President Donald J. Trump issued a memorandum initiating a broad-scale review of U.S. trade policy. The memorandum orders the heads of several executive agencies to (i) comprehensively review the reasons for the U.S. trade deficit, and (ii) conduct systematic reviews and submit reports recommending potential revisions to existing trade measures—including tariffs, the United States-Mexico-Canada Free Trade Agreement, antidumping and countervailing duty laws, trade regulations towards China, intellectual property protections, and export controls. The memorandum and other recent developments signal the administration’s likely expansion of trade measures that could substantially affect companies’ operations and global supply chains.
January 24, 2025
President Trump has issued two Executive Orders on artificial intelligence. On his first day in office, President Trump issued an Executive Order revoking Executive Order 14110 titled “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence” issued on October 30, 2023. On January 23, President Trump issued an Executive Order titled “Removing Barriers to American Leadership in Artificial Intelligence.”
January 24, 2025
On January 20, 2025, President Trump issued a regulatory freeze memorandum “order[ing] all executive departments and agencies” to:
- refrain from proposing or issuing any “rule” in any manner, until it is reviewed and approved by a department or agency head appointed or designated by President Trump;
- “immediately” withdraw rules sent for publication, but not yet published, to ensure they can be reviewed and approved by a Trump administration official; and
- “consider” postponing for 60 days from the date of the Freeze Memo the effective dates of rules that have been issued but have not taken effect, and opening a comment period to allow the public to provide comment on “issues of fact, law, and policy” raised by such rules.
January 24, 2025
President Trump has signed an Executive Order titled “Strengthening American Leadership in Digital Financial Technology” which has the objective of “protecting and promoting fair and open access to banking services for all law-abiding individual citizens and private-sector entities alike.”
January 23, 2025
On January 20, President Donald J. Trump issued an Executive Order directing the U.S. Secretary of State to recommend within 14 days whether to designate cartels and other criminal organizations as foreign terrorists, a move with potentially significant corporate enforcement and compliance implications.
January 23, 2025
On January 23, President Donald J. Trump signed an Executive Order titled “Strengthening American Leadership in Digital Financial Technology” that establishes the President’s Working Group on Digital Assets to review all “regulations, guidance documents, orders, or other items that affect the digital asset sector” and issue a report to the President proposing a Federal regulatory framework for digital assets.
The SEC repealed SAB 121 which had presented significant challenges for regulated financial institutions (among others) seeking to provide custody or certain other services involving crypto assets.
January 22, 2025
President Trump has taken significant actions to roll back DEI programs through executive orders, including requiring the Attorney General to recommend measures to encourage the private sector to end illegal DEI practices; cancelling affirmative action requirements for federal contractors; establishing a federal policy of two genders only; and ceasing virtually all DEI-related activities in the federal workforce.