International Trade & National Security Law Firm

Any U.S. company that manufactures, exports, or temporarily imports items or performs defense services that are controlled under the International Traffic in Arms Regulations (ITAR) is required to register with the U.S. Department of State Directorate of Defense Trade Controls (DDTC) and keep that registration current. Current in the context of the ITAR means not only the company information that is current at the time the registration is initially submitted, but the information in the registration must accurately reflect the registered company’s current information at any point in the company’s timeline. When certain changes occur within the registered company, such as a change of control, a merger or acquisition, or a change in executive leadership, those changes must be reported to DDTC and the company’s ITAR registration must be updated. At a minimum, ITAR registration must be renewed annually.

The United States Committee on Foreign Investment in the United States ("CFIUS") issued its 2025 Annual Report to Congress, providing important guidance for companies engaged in cross-border investment involving critical technologies, sensitive data, infrastructure, and other national security considerations. The report shows where CFIUS is concentrating its enforcement and compliance resources: identifying transactions that were never filed, monitoring hundreds of mitigation agreements, investigating possible violations of mandatory filing requirements, and expanding the personnel and technical resources devoted to enforcement.

Trade enforcement is no longer limited to customs entry reviews, export license questions, or isolated sanctions screening. Recent actions coming out of the White House and key regulatory agencies including, U.S. Customs and Border Protection (“CBP”), the Department of Homeland Security (“DHS”), Homeland Security Investigations (“HSI”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the U.S. Department of Justice (“DOJ”) demonstrate that customs, export controls, economic sanctions, and related trade fraud risks are increasingly being treated as national security, economic security, and whole-of-government enforcement priorities

For the latest Trump trade executive actions, please view the below Torres Trade Trump Table for important information. This table will be monitored and updated regularly. The last update occurred August 12, 2026.

For executives and exporters, the era of treating export controls as a compliance checkbox may be coming to an end. Testifying before the House Foreign Affairs Committee on July 14 regarding the 2027 budget for the Bureau of Industry and Security (BIS), Commerce Under Secretary Jeffrey Kessler outlined BIS’s priorities, key trade initiatives, and future projects shaping U.S. trade policy. According to Kessler, BIS remains focused on protecting the “crown jewels” of the American economy: critical technologies and supply chains.¹

On July 23, 2026, the Office of the United States Trade Representative (“USTR”) announced the implementation of new tariffs on imports from 60 foreign countries under Section 301 of the Trade Act of 1974. The tariffs generally range from 10% to 12.5% and apply to nearly all products from the covered countries, subject to extensive product-specific and country-specific exemptions. The new duties are effective July 24, 2026, and arise from USTR investigations announced earlier this year concerning foreign governments’ failure to prohibit imports made with forced labor.