Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

On June 2, 2026, USTR published final actionability findings in 60 parallel Section 301(b) investigations — the largest simultaneous Section 301 action in US history — determining that all 60 economies maintain unreasonable acts, policies, or practices by failing to impose or effectively enforce a prohibition on imports produced with forced labor. USTR proposed two additional duty rates: 10% on the 14 economies with partial forced-labor regimes (Canada, Ecuador, EU, Indonesia, Mexico, Pakistan, Argentina, Bangladesh, Cambodia, El Salvador, Guatemala, Malaysia, Taiwan, UK) and 12.5% on the remaining 46 economies. Tariff rates remain proposed pending a July 7, 2026 public hearing and subsequent finalization; the actionability determination is final.

FinCEN issued an amendment to its June 30, 2025 special-measure order (90 FR 27770) that had prohibited US covered financial institutions from transmitting funds to or from CIBanco S.A., a Mexican multiple-banking institution previously designated as of primary money-laundering concern in connection with illicit-opioid trafficking. Effective April 16, 2026, the amendment authorizes transmittals of funds ordinarily incident and necessary for the Government of Mexico to liquidate CIBanco. The carve-out is narrow: the broader §2313a prohibition on US-side correspondent activity with CIBanco remains in force outside the liquidation channel.

On 11 March 2026 USTR Ambassador Jamieson Greer initiated parallel Section 301 investigations into the acts, policies, and practices of 16 economies — China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India — relating to structural excess capacity and overproduction in manufacturing sectors. The Federal Register notice (FR doc 2026-05214; dockets USTR-2026-0067 and USTR-2026-0068) was published on 17 March 2026. Covered sectors include aluminum, automobiles, batteries, cement, chemicals, electronics, energy goods, glass, machine tools, machinery, paper, plastics, processed food and beverages, robotics, satellites, semiconductors, ships, solar modules, steel, and transportation equipment. Written comments were due by 15 April 2026; USTR held the public hearing beginning 5 May 2026. This is the most sweeping multi-economy Section 301 initiative since the 2018 China investigation and is structurally distinct from the China-only 2024-05-14 §301 tariff hikes and the 2025-07-15 Brazil §301 investigation.

FinCEN issued an expanded Geographic Targeting Order (GTO) requiring money services businesses (MSBs) located in designated counties and ZIP codes across Arizona, California, New Mexico, and Texas to file Currency Transaction Reports (CTRs) on cash transactions between $1,000 and $10,000 — well below the standard $10,000 CTR threshold. The order took effect March 7, 2026 and runs through September 2, 2026; the FR notice (FR Doc. 2026-04641) was published March 10, 2026. The expansion adds Bernalillo, Doña Ana, and San Juan Counties in New Mexico and Maricopa and Pima Counties in Arizona to the geography covered by the prior September 10, 2025 GTO. Compliance date for newly-covered MSBs is April 6, 2026; reports must be filed within 30 days (extended from the standard 15-day CTR deadline). The instrument is part of the post-2024 US enforcement architecture targeting fentanyl-related illicit-finance flows through the US-Mexico border MSB channel.

President Trump signed Executive Order "Ending Certain Tariff Actions" on 20 February 2026 (Federal Register doc 2026-03832, published 25 February 2026), terminating the additional ad-valorem duties imposed under nine prior IEEPA-based executive orders. The order followed within hours of the US Supreme Court's 6-3 decision the same day in Learning Resources, Inc. v. Trump, 607 U.S. ___ (2026), holding that the International Emergency Economic Powers Act does not authorize the President to impose tariffs and vacating the Trump 2.0 IEEPA tariff regime. The EO directs CBP to cease collection "as soon as practicable"; CSMS guidance set the collection-end date at 12:00 a.m. eastern on 24 February 2026. The order explicitly preserves all underlying national-emergency declarations and all non-IEEPA trade actions — Section 232 of the Trade Expansion Act, Section 301 of the Trade Act, Section 122 of the Trade Act, and Section 201 — so the Section 232 cascade and the paired Section 122 10% temporary surcharge (effective 24 Feb 2026) remain in force. This is the first SCOTUS-driven repeal of a presidential tariff regime in the modern era and recalibrates the entire post-2024 US tariff architecture by removing IEEPA as a legal pillar.

On 4 February 2026 USTR Ambassador Jamieson Greer and Mexican Secretary of Economy Marcelo Ebrard announced a U.S.-Mexico Action Plan on Critical Minerals — a first-of-its-kind 60-day bilateral work programme to develop coordinated trade policies and supply-chain mechanisms for critical minerals. The Action Plan tasks both governments with identifying a priority mineral list, exploring border-adjusted price floors as a candidate trade instrument, and consulting on how price floors could be incorporated into a binding plurilateral agreement on trade in critical minerals. It is framed as a confidence- building measure ahead of the USMCA Joint Review (statutory deadline 1 July 2026) and as the Mexico-side template that parallels concurrent USTR engagements with the EU and Japan.

On 2026-01-26 the US Department of Commerce initiated antidumping (LTFV) and countervailing duty investigations covering van-type trailers and subassemblies thereof from Canada, China, and Mexico, following a petition filed 2025-11-20 by the American Trailer Manufacturers Coalition (Great Dane, Stoughton Trailers, Wabash National). On 2026-06-15 Commerce issued its preliminary affirmative LTFV determination for China, setting a preliminary antidumping duty rate of 130.76% on Chinese van-type trailer imports, effective on publication and triggering CBP duty collection at the border. Companion countervailing-duty and Canada/Mexico proceedings are tracked separately.

On 2026-01-26 the US Department of Commerce initiated countervailing duty (anti-subsidy) investigations covering van-type trailers and subassemblies thereof from Canada, China, and Mexico, companion to the antidumping investigation covering the same product and countries. On 2026-06-05 Commerce published preliminary affirmative CVD determinations: China received an 82.37% subsidy rate for CIMC Baowell Industries/Qingdao CIMC Reefer Trailer and all other exporters, and a 128.78% adverse-inference rate for non-responsive companies; Mexico received rates of 1.90-1.95% for cooperating respondents (Hyundai de Mexico, Utility Trailer Manufacturing de México) and a 62.67% adverse-inference rate for five non-responsive companies. The Canada CVD investigation was terminated on 2026-05-27 after the petitioner withdrew that portion of the petition. Cash deposits at the preliminary rates began on Federal Register publication; final CVD determinations are scheduled for 2026-08-24 (China) and 2026-10-13 (Mexico).

The U.S. Treasury's Office of Foreign Assets Control (OFAC) designated the Bhardwaj Human Smuggling Organization (Bhardwaj HSO), a Cancun, Mexico-based transnational criminal organization run by dual Indian-Mexican national Vikrant Bhardwaj, under Executive Order 13581 (as amended by EO 13863). The action names 21 designees in total — the organization, 4 individuals (including Bhardwaj's wife and a former Cancun airport police officer who provided access), and 16 front companies spanning Mexico, India and the UAE across real estate, construction, retail/hospitality, and tourism/transport sectors used to launder smuggling proceeds. The designation was coordinated with Homeland Security Investigations, the DEA, and Mexico's financial intelligence unit (UIF), and blocks all U.S. property and interests of the designees plus any entity 50%-or-more owned by them.

President Trump signed Proclamation 10984 "Adjusting Imports of Medium- and Heavy-Duty Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses Into the United States" on 17 October 2025, invoking Section 232 of the Trade Expansion Act of 1962 to impose a 25% ad valorem tariff on imports of Class 3 to Class 8 medium- and heavy-duty trucks (large pick-up trucks, moving trucks, cargo trucks, dump trucks, tractors) and on key MHDV parts, and a 10% ad valorem tariff on buses and other vehicles classified in HTSUS heading 8702. Duties take effect at 12:01 a.m. EDT on 1 November 2025 (Federal Register doc 2025-19639, 90 FR 48451, published 22 October 2025). USMCA-qualifying MHDVs are tariffed only on the value of non-U.S. content; the proclamation also establishes an offset programme for MHDV parts equal to 3.75% of the aggregate value of all MHDVs assembled in the United States from 2025 through 2030, mirroring the Proclamation 10925 light-vehicle offset architecture.

On 6 October 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated 8 Mexican individuals and 12 Mexico-based companies under Executive Order 14059 for supplying fentanyl precursor chemicals and laboratory equipment to the Sinaloa Cartel's "Los Chapitos" faction, led by fugitive brothers Archivaldo Ivan and Jesus Alfredo Guzman Salazar (sons of Joaquin "El Chapo" Guzman Loera). The network is centred on Sumilab, a chemical and lab-equipment supplier previously sanctioned by OFAC in May 2023, which restructured through affiliated pharmaceutical, laboratory, chemical, cleaning-supply and real-estate front companies to continue operating after the earlier designation. All property and interests in property of the designated persons within US jurisdiction or held by US persons are blocked, and US persons are generally prohibited from transacting with them.

On September 10, 2025 FinCEN issued a Geographic Targeting Order (GTO) under 31 USC 5326 requiring money services businesses (MSBs) in designated southwest-border counties and ZIP codes across California, Texas, and (newly added) Arizona to file Currency Transaction Reports (CTRs) on cash transactions between $1,000 and $10,000 — well below the BSA's standard $10,000 CTR threshold. The order ran through March 6, 2026 (180 days, the GTO statutory maximum) and was subsequently extended via the March 10, 2026 expanded GTO (FR Doc. 2026-04641) which retained the $1,000 floor and added inland transit hubs (Bernalillo, Doña Ana, San Juan in NM; Maricopa, Pima in AZ). The September 2025 order modified an earlier March 14, 2025 GTO that had used a $200 threshold and covered a narrower TX/CA strip; the September 2025 modification raised the threshold to $1,000 in response to MSB-industry feedback on operational burden, while extending the geography to include Arizona. Filing deadline is extended from the standard 15 days to 30 days.

FinCEN published an order amending the three June 25, 2025 special-measure orders (as previously amended by the July 11, 2025 order, FR doc 2025-12973) prohibiting US covered financial institutions from transmitting funds to or from CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. — three Mexican institutions designated of primary money-laundering concern in connection with illicit-opioid trafficking under Section 2313a of the Fiscal Year 2024 NDAA. The amendment extends the effective date of all three prohibitions from September 4, 2025 to October 20, 2025, granting US covered institutions an additional ~46 days to wind down correspondent exposures. The underlying primary-money-laundering-concern findings remain intact — only the implementation deadline shifts.

FinCEN published an order amending the three June 25, 2025 special-measure orders (FR docs 2025-11991, 2025-11993, 2025-11990; 90 FR 27770 et seq.) prohibiting US covered financial institutions from transmitting funds to or from CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. — three Mexican institutions designated of primary money-laundering concern in connection with illicit-opioid trafficking under Section 2313a of the Fiscal Year 2024 NDAA. This first extension shifts the effective date of all three prohibitions from July 21, 2025 to September 4, 2025 (a 45-day delay), giving US covered institutions additional time to wind down correspondent exposures. The underlying primary-money-laundering- concern findings remain unchanged — only the implementation deadline shifts.

On 25 June 2025, FinCEN issued three coordinated orders identifying CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. as foreign financial institutions of primary money-laundering concern in connection with illicit opioid trafficking, and prohibiting US covered financial institutions from engaging in certain transmittals of funds (including convertible virtual currency transmittals) to or from those three institutions or any account or CVC address administered on their behalf. The orders were published in the Federal Register on 30 June 2025 (FR docs 2025-11991 Vector, 2025-11993 CIBanco, 2025-11990 Intercam) with an original effective date of 21 July 2025. These are the first-ever orders issued under Section 2313a of the Fiscal Year 2024 NDAA (added by the FEND Off Fentanyl Act and Fentanyl Sanctions Act), and target Mexican counterparties tied by FinCEN to the Beltran-Leyva Cartel, Jalisco New Generation Cartel (CJNG), and the Gulf Cartel.

On 1 May 2025 the US Treasury's Office of Foreign Assets Control (OFAC), jointly with FinCEN, designated two Mexican nationals — Oscar Guillermo Juraidini Silva and J. Refugio Ruiz Villagomez — and nine entities they own or control, pursuant to Executive Order 14059 (illicit drug trade) and E.O. 13224 (as amended), for facilitating a Cartel Jalisco Nueva Generacion (CJNG) fuel-theft and cross-border smuggling scheme ("huachicol fiscal") that falsifies customs documentation to evade Mexico's IEPS fuel-import tax. FinCEN concurrently issued a supplemental alert on fuel-smuggling and fiscal fuel-theft red flags. All property and interests in property of the designees within US jurisdiction are blocked, and US persons are generally barred from transacting with them.

Executive Order 14289 of 29 April 2025 provides that certain overlapping US tariffs should not have a cumulative effect. Where an article is subject to the Section 232 automobile and parts tariffs (Proclamation 10908), it is not subject to the northern- or southern-border duties (EO 14193 / 14194) or to the steel and aluminium Section 232 tariffs; border duties in turn take priority over the metals tariffs, while steel and aluminium tariffs may still stack with each other. The order applies retroactively to entries made on or after 4 March 2025.

President Trump signed Executive Order 14257 on 2 April 2025 declaring a national emergency over US trade deficits and imposing a baseline 10% ad-valorem tariff on imports from nearly all trading partners effective 5 April, with higher country-specific "reciprocal" rates effective 9 April. The rate schedule was constructed from a formula tied to bilateral goods-trade deficits and ranged from 10% (UK, Singapore, Brazil, Australia, others) through 20% (EU), 24% (Japan), 25% (Korea), 32% (Taiwan, Indonesia, Switzerland), 34% (China, later raised to 84% then 125% during the April escalation), 46% (Vietnam), 49% (Cambodia). Multiple subsequent EOs paused the country-specific rates for 90 days for non-China destinations on 9 April while keeping the 10% baseline, pending bilateral negotiations.

President Trump signed Proclamation 10908 "Adjusting Imports of Automobiles and Automobile Parts Into the United States" on 26 March 2025, invoking Section 232 of the Trade Expansion Act of 1962 to impose a 25% ad valorem tariff on imports of finished passenger vehicles and light trucks effective 12:01 a.m. EDT on 3 April 2025, with the duty extended to key automobile parts (engines and engine parts, transmissions and powertrain components, electrical components) effective 12:01 a.m. EDT on 3 May 2025. USMCA-origin automobiles receive an interim deduction equal to the value of US-origin content; USMCA-origin parts that satisfy the agreement's rules of origin are temporarily exempt from the parts duty pending a Commerce-administered process. The proclamation is the first Section 232 instrument applied to finished automobiles in US history and the largest-by-trade-volume Section 232 measure of the second Trump administration, covering roughly USD 460 billion of annual auto and auto-parts imports.

On March 11, 2025 FinCEN issued a Geographic Targeting Order (GTO) under 31 USC 5326 — published in the Federal Register on March 14, 2025 (FR Doc. 2025-04099) and effective April 14, 2025 — requiring every money services business (MSB) located in 30 designated ZIP codes across seven counties in California (Imperial, San Diego) and Texas (Cameron, El Paso, Hidalgo, Maverick, Webb) to file a Currency Transaction Report (CTR) on cash transactions of more than $200 but not more than $10,000, far below the Bank Secrecy Act's standard $10,000 CTR floor. The order also imposed customer-identification recordkeeping and, per the FinCEN order text, gave covered MSBs thirty (30) days to file CTRs (vs. the standard fifteen). It was framed by Treasury as part of the post-January-2025 cartel-targeting policy stack (Trump Executive Order 14157 designating Mexican drug cartels as Foreign Terrorist Organizations / SDGTs) and was intended to surface low-value cash flows used by Mexico-based cartels and related criminal actors. The GTO was a 180-day order set to expire September 9, 2025; it was subsequently superseded on September 10, 2025 by a modified GTO that raised the threshold to $1,000 in response to MSB-industry feedback on burden, expanded geography to Arizona, and was itself replaced/expanded again on March 10, 2026.

President Trump signed two Presidential Proclamations on 11 February 2025 reinstating a universal 25% ad-valorem tariff on all steel-mill products and raising the aluminum tariff from 10% to 25% on all imports into the United States, effective 12 March 2025. The proclamations revoked every bilateral exclusion and quota arrangement negotiated by the Biden administration with the EU, UK, Japan, Korea, Australia, and others under the 2021-2022 "alternative measures" frameworks, returning all trading partners to the baseline Section 232 rate without product-level or country-level carve-outs.

President Trump signed three Executive Orders on 1 February 2025 (EO 14193, 14194, 14195) declaring national emergencies under IEEPA over the cross-border flow of fentanyl + illegal migration, and using that authority to impose new tariffs: 25% on imports from Canada (with a reduced 10% rate on Canadian energy products), 25% on imports from Mexico, and an additional 10% on imports from China (separate from pre-existing Section 301 + Section 232 tariffs). The tariffs took effect 4 February 2025. On 3 February 2025 the administration announced a 30-day pause for both Canada and Mexico following bilateral border-enforcement commitments; the China tariff was not paused. China responded 4 February with retaliatory tariffs of 15% on US LNG/coal/farm equipment and additional measures. The package set the precedent for the broader 2 April 2025 "Liberation Day" reciprocal-tariff regime (filed: 2025-04-02-us-trump-reciprocal-tariff-regime).

The U.S. Department of Commerce, through the International Trade Administration's Enforcement and Compliance unit, published a technical correction to its 31 January 2024 final rule ("Procedures and Rules for Article 10.12 of the United States-Mexico-Canada Agreement", 89 FR 6011) that established the binational-panel and extraordinary-challenge-committee procedures replacing the legacy NAFTA Article 1904 framework. The correction removes erroneously duplicated regulatory text in 19 CFR § 356.8(b)(2) — language that had been inadvertently copied from § 356.8(b)(1) in the prior rulemaking — and is effective on publication. The fix is non-substantive and does not alter any rights, obligations, or procedural requirements for parties to USMCA Chapter 10 binational-panel reviews of US antidumping and countervailing duty determinations involving Canadian or Mexican merchandise.

On 8 December 2023 the Bureau of Industry and Security (BIS) published a direct final rule (88 FR 85479; FR Doc 2023-26532) making two export-liberalisation amendments to the Export Administration Regulations (EAR). First, BIS removes Chemical and Biological Weapons (CB) proliferation column controls from the Commerce Country Chart for exports of certain pathogens and toxins (ECCNs 1C351, 1C353, and 1C354) when destined to Australia Group (AG) member countries, on the basis that AG members operate equivalent domestic CBW-export controls. Second, the rule revises the Crime Control and Detection (CC) column entries for Austria, Finland, Ireland, Liechtenstein, South Korea, Sweden, and Switzerland, reflecting the updated US assessment of those countries' law-enforcement export-control standards. Both changes are effective on publication and reduce US export-licensing burdens for allied-country destinations without altering controls for non-allied markets.

The Bureau of Industry and Security (BIS) removed three persons from the Unverified List (UVL) effective January 11, 2021 after completing successful end-use checks that verified their bona fides under §744.15(c)(2) of the Export Administration Regulations (EAR). The three removed parties are DMA Logistics GmbH (Germany), Halm Elektronik GmbH (Germany), and Integrated Production and Test Engineering / IPTE (Mexico). Removal restores eligibility for EAR license exceptions and eliminates the requirement for US exporters to obtain a signed UVL Statement before shipping items subject to the EAR to these parties.

BIS amended the Export Administration Regulations (EAR) to revise Country Group designations for Ukraine, Mexico, and Cyprus, effective immediately on publication (85 FR 83756, FR Doc 2020-26552). Ukraine was elevated from Country Group D to Country Group B, making it newly eligible for eight EAR license exceptions (LVS, TMP, RPL, GFT, BAG, AVS, APR, ENC) and shifting dual-use export licensing to a standard national-security basis. Mexico and Cyprus were simultaneously added to Country Group A:6, granting both countries access to Strategic Trade Authorization (STA) exceptions for less-sensitive CCL-controlled items. The changes reflect each country's multilateral export-control regime membership and policy alignment with U.S. national security interests.