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13 October 2025

Torres Trade Trump Table

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Torres Trade Law, PLLC

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Torres Law, PLLC is an international trade and national security law firm that assists clients with the import and export of goods, technology, services, and foreign investment matters. We have extensive experience with the various regimes and agencies governing trade such as U.S. Customs and Border Protection (CBP), the Department of Commerce Bureau of Industry and Security (BIS), the Department of State Directorate of Defense Trade Controls (DDTC), the Department of Treasury Office of Foreign Assets Control (OFAC), the Department of Defense Security Service (DSS), the Committee on Foreign Investment in the United States (CFIUS), and others.
The table below presents a structured timeline of executive actions, policy directives, and trade-related decisions issued by President Trump's administration from January 2025 to the present.
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Summary:

The table below presents a structured timeline of executive actions, policy directives, and trade-related decisions issued by President Trump's administration from January 2025 to the present. It focuses on critical areas such as tariffs, economic sanctions (OFAC), the priorities of the Department of Justice, customs regulations, and broader trade and economic policies.

The table captures significant policy shifts, including the imposition and threats of tariffs on imports from Canada, Mexico, China, and other countries; sanctions targeting individuals, international organizations, and foreign entities; and efforts to align federal agencies with an "America First" economic and diplomatic agenda. As a whole, the actions summarized below illustrate the administration's approach to trade protectionism, economic nationalism, and regulatory intervention, which has far-reaching implications for global trade relationships, U.S. businesses, and international law enforcement efforts.

TRACKER

Date Source Category Summary
9/30/25

Federal Register

Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities

Export Controls The Bureau of Industry and Security (BIS) issued an interim final rule amending the Export Administration Regulations (EAR) to include new restrictions on exports to parties owned 50% or more by an entity listed on the BIS Military End-User (MEU) List or Entity List. This new rule mirrors the Office of Foreign Asset Control's (OFAC) application of economic sanctions and provides that parties ultimately owned 50% or more by an entity on the MEU or Entity List will be subject to the same export restrictions as its listed owners. In addition to the new rule, BIS has also added Red Flag #29 to Supplement No. 3 of Part 732 of the EAR directing that when an exporter has "knowledge" that a foreign entity has one or more listed owners or that are subject to other export restrictions, the exporter has an affirmative duty to determine the percentage of ownership of those entities or must obtain a license from BIS prior to export.
9/29/25

White House

Adjusting Imports of Timber, Lumber, and Their Derivative Products into The United States

Tariffs/National Security Following an investigation under Section 232 of the Trade Expansion Act of 1962, President Trump issued a Presidential Proclamation implementing tariff measures targeting imports of certain timber, lumber, and derivative products based on national security concerns. Certain imports of softwood timber and lumber identified in Annex I to the Proclamation will be subject to a 10% tariff rate. Imports of upholstered wooden products, kitchen cabinets, and vanities identified in Annex I to the Proclamation will be subject to a 25% tariff rate. These initial tariff rates become effective October 14, 2025. Afterwards, the tariff rate for upholstered wooden products will increase to 30% and the tariff rate for kitchen cabinets and vanities will increase to 50% starting January 1, 2026. The Proclamation provides separate tariff rates for certain countries that have executed trade agreement frameworks with the U.S. including the European Union (15%), Japan (15%), and the United Kingdom (10%). For more information, visit the White House Fact Sheet here.
9/25/25

U.S. Court of Appeals for the Federal Circuit

Case No. 23-1891 HMTX Industries v. United States

Tariffs The Court of Appeals for the Federal Circuit (CAFC) issued an opinion in one of the leading cases challenging the validity of Section 301 tariffs implemented under the first Trump administration. The issues on appeal related to whether the USTR exceeded its statutory authority under Section 307 of the Trade Act of 1974 in modifying tariffs on a wide range of Chinese-origin goods (i.e., the List 3 and List 4a actions) after China retaliated against initial rounds of Section 301 tariffs implemented under List 1 and List 2. In addition, the CAFC considered whether the USTR took sufficient action to consider public comments on the List 3 and 4a tariff modifications pursuant to the trial court's prior order. The validity of the List 1 and List 2 tariff actions were not challenged. The CAFC held that Section 307(a)(1)(C) of the Trade Act of 1974 independently authorized the USTR to implement the tariff modifications under List 3 and List 4a. The Court also found that the USTR's review of public comments and subsequent supply of information to the trial court "supplied the necessary clarification to meet the APA's [Administrative Procedure Act] requirements regarding notice-andcomment rulemaking." Therefore, the Court

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