Navigating Trump administration executive orders impacting CFIUS, national security, and trade.

By James Barker, Les Carnegie, Damara Chambers, Philip Perry, Ruchi Gill, Catherine Hein, and Kathryn Worthington

See EO: America First Trade Policy

Date Issued: January 20, 2025

Agency Impacted: State, Treasury, Defense, Commerce, Homeland Security, OMB

Summary: This EO tasks the Secretary of State and the Secretary of Commerce, in cooperation with the heads of other agencies with export control authorities, to review the United States export control system and advise on modifications in light of developments involving strategic adversaries or geopolitical rivals focusing on maintaining the US’s technical edge and eliminating loopholes in existing export controls. The EO also tasks the Secretary of Commerce to consider expanding the remit of the Office of Information and Communication Technology and Services (ICTS) beyond connected vehicles to account for additional connected products. Investigations to be conducted by Treasury, Commerce, and the Trade Representative relating to trade deficits in goods, the establishment of an External Revenue Service to collect tariffs and other foreign trade-related revenues, and the impact related to participation in US-Mexico-Canada Agreement.

Timeline: Reviews and investigations, findings, identifications, and recommendations are due April 1, 2025, with the exception of an OMB report due April 30, 2025.

Latham & Watkins has a proven track record of guiding clients through transitions in US administrations, leveraging our deep expertise and understanding of the evolving regulatory landscape. In the first week of the Trump Administration, a total of 48 executive orders were issued, marking a significant and rapid commencement of policy changes with potential impacts across business sectors. This package provides a concise analysis by Latham lawyers of 15 key executive orders that are anticipated to have the most substantial business implications.

For a comprehensive list of all executive orders issued, please visit the official White House website.

Additional details about Latham’s capabilities as well as contact information for several Latham lawyers with former government experience or who serve as key contacts in relevant practice areas, can be found at the end of this package.

We welcome the opportunity to connect with you to understand your specific needs and explore how we can assist you in navigating these changes. Please reach out to Latham for more detailed analysis and to stay informed about additional insights as they become available.