TradeLane

The European Union (EU) has implemented a series of restrictive measures as part of its sanction regimes aimed at Russia. Notwithstanding these efforts, a substantial volume of sanctioned goods continues to be diverted to Russia. To combat this, the EU introduced legislative obligations to minimize circumventions.

This blog examines the role of the Internal Compliance Program (ICP) in the EU Russian Sanctions Regulations, focusing on due diligence and circumvention.

Update as of August 1, 2025:

As U.S. trade policy continues to evolve this week, we’re closely tracking the latest developments to keep our clients informed and ready to respond strategically and tactically. Please note that the updates below reflect the trade environment at the time of posting and may be subject to change.

Update as of July 30, 2025:

President Trump signed an Executive Order that effectively ends the duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for low-value shipments from all countries, effective August 29. For these imported goods, formal entry and payment of all applicable duties and fees will soon be required.

On June 16, 2025, President Trump signed an executive order to implement the U.S.–U.K. Economic Prosperity Deal. The purpose of this landmark agreement is to expand trade, enhance supply chain security, and address national security concerns. It marks a significant step forward in strengthening economic ties between the United States and the United Kingdom.

At Tradewin, we are closely monitoring the implementation of this agreement to help our clients understand the implications and prepare for the changes ahead.

Since the end of the Biden Administration, the direction of the Trump Administration’s Department of Commerce and Bureau of Industry and Security (BIS) has been slowly materializing, giving us a glimpse of what U.S. export controls will look like for the next four years.