International

This client alert provides updates on our previous guidance related to the September 19, 2025, Presidential Proclamation (the “Proclamation”), Restriction on Entry of Certain Nonimmigrant Workers. On October 20, 2025, U.S. Citizenship and Immigration Services (“USCIS”) published updated guidance on the applicability of the Proclamation. The update clarifies:

  • Who is subject to the $100,000 payment;
  • Who is NOT subject to the payment;
  • How to pay the new fee; and
  • How to request an exception in the National Interest.

  • Continue Reading USCIS Clarification on Restriction on Entry of Certain Nonimmigrants

    Strategic cargo theft—fraudulent schemes where criminals pose as legitimate carriers or brokers to gain possession of freight—has surged across the U.S. freight market. Since the first quarter of 2021, strategic cargo theft has risen more than 1500 percent, with the average loss per shipment now exceeding $200,000. Although this creates mounting challenges for shippers, carriers, brokers, and their insurers, the right safeguards in contracts and protocols can help minimize the risk of a catastrophic uninsured loss.
    Disputes Over


    Continue Reading Fighting Strategic Cargo Theft: Risk Management for Rising Claims Disputesand Liability Challenges

    Over the past several months since the flurries of tariffs implemented by the Trump administration went into effect, we have noticed an uptick in questions regarding products used in agriculture. Specifically, on compliance strategies to mitigate the impact of these tariffs on business. Through the special provisions of the Harmonized Tariff Code of United States (HTSUS), 9817.00.50 and 9817.00.60, U.S. law provides a duty-free mechanism that allows eligible machinery, tools, and equipment that are genuinely used for farming


    Continue Reading Duty-Free Entry for Products Used in Agriculture and Horticulture

    Late last week, the White House issued a Proclamation which added a payment requirement of $100,000 to new H-1B petitions. The Proclamation provides a narrow exception for persons whose employment is determined in the Secretary of Homeland Security’s discretion to be in the national interest of the United States. This new requirement went into effect on September 21, 2025, and expires after 12 months absent extension.

    A memorandum issued by USCIS later clarified that the proclamation only applies to
    Continue Reading Presidential Proclamation Creates $100,000 Payment Requirement for New H-1B Petitions

    On June 9, 2025, the Trump Administration’s sweeping travel ban took effect, suspending entry for citizens of twelve countries and imposing partial restrictions on nationals from seven more.[1] The measure was introduced as part of a broader effort to address national security and vetting concerns, signaling that the restrictions were only the beginning of a broader enforcement approach.
    Escalation of U.S. Travel Restrictions
    Since the initial ban, the Administration has escalated its efforts. In late June, the White
    Continue Reading Travel Restrictions on the Rise: Why Employers Should Advise Caution

    September 2, 2025

    On May 28, 2025, the United States Court of International Trade (“CIT”) determined that the Trump administration’s use of the International Emergency Economic Powers Act (“IEEPA”) to impose (1) overly broad worldwide reciprocal tariffs and (2) fentanyl/immigration-related tariffs on China, Mexico, and Canada was unlawful. Following that ruling, the U.S. government filed a prompt appeal with the U.S. Court of Appeals for the Federal Circuit (“CAFC”) and asked the court to put the order on hold


    Continue Reading Federal Appeals Court Strikes Down Trump Tariffs: Implications for U.S. Businesses

    Once viewed as a leading contender for an early trade “deal” as part of President Trump’s effort to conclude bilateral trade deals with trade partners, U.S.-India trade relations have strained. This tension culminated in Trump imposing an additional 25 percent “penalty” tariff on imports from India for its alleged purchase of Russian oil and military equipment. This additional tariff became effective on August 27, 2025.

    The Tariff Is Imposed Under IEEPA
    Like the reciprocal tariffs, the “penalty” tariff


    Continue Reading What Businesses Need to Know About Trump’s New Penalty Tariffs on India

    U.S. sanctions are a powerful tool used to influence the behavior of foreign governments, individuals, and entities. Placement on any sanctions watchlist maintained by a regulatory agency can have devastating financial, commercial, and legal consequences, including freezing U.S. assets, restricting travel to the U.S., blocking U.S. financial transactions, and enduring a damaged reputation worldwide. Given the substantial penalties levied against international banks and foreign and domestic businesses that violate U.S. primary and secondary sanctions laws, complying with regulations is


    Continue Reading How to Be Removed From a U.S. Sanctions Watchlist List

    This article first appeared in On Balance, the membership magazine of the Wisconsin Institute of CPAs, and is used with their permission.

    In early January, the incoming U.S. presidential administration loudly signaled that businesses should expect changes in trade policies in 2025. Although no specific policies had yet been promulgated, then President-elect Trump stated in social media outlets that broad sweeping import tariffs may be imposed on goods from Mexico, Canada and China. As of May 15, many new
    Continue Reading Taking Stock of Trade Issues

    We previously reported on the reciprocal tariffs on ALL countries issued by President Trump in early April. Over the weekend, the U.S. and China agreed to temporarily reduce tariffs amid a looming recession triggered by an effective embargo.

    The reciprocal tariffs, previously set at 125 percent, will be lowered to 10 percent for a 90-day period to allow room for negotiations. Both sides will take these actions by May 14, 2025. It is important to note that this


    Continue Reading U.S. and China Agree to Reduce Reciprocal Tariffs for 90 Days

    If you are a compliance professional for a U.S.-based company, you have probably been told at some point that you have to worry about the General Data Protection Regulation (GDPR).

    Have you encountered one of these situations?

    • A vendor or customer tells you to sign a lengthy and very technical GDPR data processing agreement (“DPA”) as part of your contract.
    • You are told to be prepared to respond to a data subject access request (“DSAR”), a burdensome GDPR information


    Continue Reading Is My U.S.-Based Company Subject to the GDPR?

    Tariffs are increasingly becoming a critical issue for businesses large and small, driving up costs and creating new challenges across supply chains.

    Although addressing these challenges requires a strategic approach, one simple solution is implementing a Foreign Trade Zone (“FTZ”) that provides tax savings and other benefits programs.
    Benefits of FTZs
    FTZs are secured areas under U.S. Customs and Border Protection (“CBP”) supervision that are generally considered outside U.S. Customs territory for purposes of customs duty payments. Therefore, goods


    Continue Reading How to Implement a Foreign Trade Zone to Mitigate Tariffs

    On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN) released an interim final rule that removes the requirement for U.S. domestic companies and persons to report beneficial ownership information (“BOI”) to FinCEN under the Corporate Transparency Act (“CTA”).

    Under the interim final rule, FinCEN revised the definition of a “reporting company” to include only entities formed under the law of a foreign country and registered to do business in any U.S. State or Tribal jurisdiction by filing a
    Continue Reading The Corporate Transparency Act – FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies

    The incoming U.S. Presidential administration is loudly signaling that businesses should expect changes in trade policies in 2025. Although no specific policies have yet been promulgated, the President-Elect has stated in social media outlets that broadly sweeping import tariffs may be imposed on goods from Mexico, Canada and China. Even without policy details, there are key steps many U.S. businesses should consider in advance of any specific changes.

    First, any business that exports goods, services or information, should have
    Continue Reading Taking Stock of Trade Issues in 2025

    Governments worldwide are facing growing demands for openness, transparency, and accountability.

    As part of this shift, the Open Government Partnership (OGP) stands out as a pioneering international initiative committed to fostering government transparency and citizen engagement. Established in 2011, the OGP now includes 78 countries and numerous local governments, each dedicated to advancing these principles in governance.
    What is the Open Government Partnership?
    The OGP is an initiative founded to create more transparent and accountable governments by encouraging commitments
    Continue Reading Opening the Doors to Transparent Governance

    The saying “nothing is permanent” not only applies to life in general, but also to things many people think are truly permanent – like lawful permanent residency status, commonly called “green card” status. Unfortunately, it often surprises some (and usually under less-than-ideal circumstances) that the permanent resident status that they thought they could never lose and worked so hard to obtain can, in fact, be lost either through their actions, or in many cases, inactions. It will likely come
    Continue Reading Permanent Residency Status is Not Necessarily Permanent: Travelers Beware