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On July 8th, 2025, President Trump issued an order (the “Order”) forcing divestment of U.S.-based Jupiter Systems (“Jupiter”) by its China-based parent company, Suirui Group Co., Ltd. (“Suirui”), more than five years after Suirui acquired Jupiter.

Joyce Adetutu, Jason Fleischer, and Stephen Josey emphasize that the unresolved legal status of the IEEPA tariffs creates significant uncertainty for importers. With the tariffs still being collected during appeal, businesses risk overpaying and should consider filing protests to safeguard potential refunds. To navigate this shifting landscape, importers must stay alert to liquidation deadlines and build tariff-related contingencies into their contracts.

The Texas Legislature was active this Session in proposing and passing bills that seek to restrict foreign ownership of real estate and businesses in Texas.

Read on for a brief round-up of what we expect to see from the incoming Trump administration impacting export controls, economic sanctions, and CFIUS.

On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on Tornado Cash, a software protocol that facilitates anonymous digital transactions.

Following months of delays and intense debate in Congress, President Biden signed H.R. 815 into law on April 24, 2024, which made headlines for funding $95 billion in military aid to Ukraine, Israel, and Taiwan, along with mandating the divestment of social media app TikTok.

In a provocative demonstration that it scrutinizes all types of transactions, no matter their origin, the Committee on Foreign Investment in the United States (“CFIUS”) has reportedly been vetting the proposed $1 billion sale of bankrupt crypto lender Voyager Digital’s assets to Binance.