Executive Actions Tracker

This proclamation excludes certain products of Canada, as set forth in its Annex, from importation into the United States effective 12:01 a.m. eastern time on September 29, 2026, under section 338 of the Tariff Act of 1930, based on the President's finding that Canada has maintained the discriminatory motor vehicle tariff scheme described in Proclamation 11048 of July 20, 2026. Products imported but not yet entered for consumption before September 29, 2026 remain subject to the 50 percent ad valorem duty imposed by Proclamation 11048, which also applies as a fallback if the import ban is invalidated. The Commissioner of U.S. Customs and Border Protection, in consultation with the Secretary of the Treasury, the Secretary of Commerce, and the United States Trade Representative, is authorized to issue implementing rules and modify the Harmonized Tariff Schedule as necessary.

Clients in Transportation

This proclamation excludes certain Canadian alcoholic beverages, as set forth in its Annex, from importation into the United States effective 12:01 a.m. eastern time on September 29, 2026, under section 338 of the Tariff Act of 1930, after finding that Canada maintained or increased the discrimination against U.S. commerce described in Proclamation 11046 of July 20, 2026. Products imported but not entered for consumption before that date remain subject to the 50 percent ad valorem duty imposed by Proclamation 11046. The Commissioner of U.S. Customs and Border Protection, in consultation with the Secretary of the Treasury, the Secretary of Commerce, and the United States Trade Representative, is authorized to issue rules and administer the import ban, and if the ban is invalidated, the 50 percent duty applies in its place.

Clients in Food and Beverage · Retail, Fashion & Beauty

This proclamation, issued under section 232 of the Trade Expansion Act of 1962, establishes a minimum import price program for polysilicon and its derivatives ($21 per kilogram for polysilicon, $100 per kilogram for ingots and wafers, $0.22 per watt for solar cells, and $0.38 per watt for solar modules) and imposes an additional 15 percent ad valorem duty on polysilicon derivatives, both effective December 4, 2026, with reduced rates for certain trading partners including the United Kingdom, the European Union, Japan, and Korea. It authorizes the Secretary of Commerce to adjust the minimum import prices, alter their applicability for trading partners adopting substantially equivalent measures, and establish an onshoring incentive program allowing companies with approved plans to build U.S. production facilities to import production equipment and covered products duty-free during construction. U.S. Customs and Border Protection is directed to enforce importer certifications, with noncompliant importers permanently barred from importing these products.

Clients in Energy and Infrastructure · AI, Robotics and Quantum · Digital Infrastructure · ESG and Sustainability

This proclamation modifies the section 232 tariff regime on aluminum imports established in Proclamation 9704 (Adjusting Imports of Aluminum Into the United States) by directing the Secretary of Commerce to establish an investment incentive program for domestic primary aluminum production. Companies with approved onshoring plans committing to build, expand, or refurbish U.S. primary aluminum facilities, with construction starting by January 20, 2029, may annually import primary aluminum corresponding to the facility's anticipated annual output at half the otherwise applicable section 232 duty rate. The Secretary may monitor compliance, require audited reports, and rescind tariff benefits, retroactively in cases of fraud.

Clients in Energy and Infrastructure · Construction · Aerospace, Defense & Government Services

This memorandum directs the United States Trade Representative to impose a 25 percent tariff on all goods of Brazil, following a Section 301 investigation initiated on July 15, 2025, into Brazil's acts, policies, and practices related to digital trade and electronic payment services, preferential tariffs, anti-corruption enforcement, intellectual property protection, ethanol market access, and illegal deforestation. The Trade Representative determined on June 1, 2026, that certain of these practices are actionable under Section 301(b)(1), and consultations with Brazil failed to resolve U.S. concerns. Products identified in the Annex are exempted from the tariff, including raw materials whose taxation could lead to unavailability of domestic supply and products that cannot be produced in sufficient quantities in the United States, and the Trade Representative is directed to modify the Harmonized Tariff Schedule accordingly.

Clients in Energy and Infrastructure · Fintech · Food and Beverage

This executive order directs the Secretary of Homeland Security, within 180 days, to revise importer-of-record eligibility rules by requiring minimum domestic assets or bonding, enhanced ownership and business disclosures, maintenance of "good standing" with U.S. Customs and Border Protection, an updated IOR registry, and enhanced vetting, and to prohibit foreign IORs from filing informal entries while imposing heightened formal-entry requirements on them, including CTPAT validation or use of a CTPAT-validated broker. It also directs heightened import disclosure and certification requirements, revised penalty mitigation standards with a minimum penalty floor of 50 percent within 90 days, expedited seizure and disposal of noncompliant imports, transparency measures, legislative recommendations within 45 days, and a report to the President within one year.

Clients in Retail, Fashion & Beauty · Transportation

This proclamation further modifies the section 232 tariff regimes on aluminum, steel, and copper imports established under Proclamations 9704, 9705, and 10962 and modified by Proclamation 11021. Effective June 8, 2026, it adds agricultural equipment and certain predominantly residential HVAC systems and components to the category of derivative products subject to the temporarily-reduced 15 percent ad valorem duty, and subjects aluminum lithographic plates and steel racks to the derivative product tariffs. It temporarily sets duties for mobile industrial equipment and machinery listed in Annex I-C at 25 percent, with lower rates for products of certain jurisdictions (including Japan, the Republic of Korea, the United Kingdom, and EU member nations), for USMCA-qualifying products of Canada and Mexico (25 percent on non-U.S. content, subject to a 15 percent floor), and for products made from U.S.-smelted or -melted metal, until December 31, 2027, after which the Proclamation 11021 rates resume. It also lowers the threshold for a product's metal content to qualify as made "entirely" from American aluminum, steel, or copper from 95 percent to 85 percent, and directs the Secretary of Commerce, the U.S. Trade Representative, and the Secretary of Homeland Security to implement and monitor the modified regimes.

Clients in Energy and Infrastructure · Construction · Transportation · Food and Beverage

This executive order directs the heads of the Federal financial regulators (the CFPB, SEC, NCUA, CFTC, FDIC, and OCC) to review, within 90 days, regulations, guidance, supervisory practices, and application processes that impede fintech firms from partnering with federally regulated institutions or obtaining charters, insurance, and other Federal authorizations, and to take steps within 180 days to encourage innovation based on that review. It also requests the Federal Reserve Board to evaluate access to Reserve Bank payment accounts and services for uninsured depository institutions and non-bank financial companies, submit a report to the President within 120 days, and, where permitted by law, establish application procedures with determinations within 90 days of application.

Clients in Fintech · Blockchain Technology and Digital Assets · Consumer Financial Services

This executive order takes additional steps with respect to the national emergency declared in EO 14380 (Addressing Threats to the United States by the Government of Cuba) by blocking the U.S. property of foreign persons determined by the Secretary of State or the Secretary of the Treasury to operate in the energy, defense and related materiel, metals and mining, financial services, or security sectors of the Cuban economy, to act for or be part of the Government of Cuba, to engage in serious human rights abuse or corruption related to Cuba, or to be adult family members of designated persons. It prohibits U.S. persons from transacting with or donating to blocked persons, suspends the immigrant and nonimmigrant entry of designated aliens absent a national interest determination by the Secretary of State, and authorizes the Secretary of the Treasury to impose correspondent or payable-through account restrictions or blocking sanctions on foreign financial institutions that conduct significant transactions for blocked persons. The Secretary of the Treasury is also directed to submit recurring and final reports to Congress on the national emergency.

Clients in Energy and Infrastructure · Aerospace, Defense & Government Services · Insurance · Fintech

This proclamation, issued under section 232 of the Trade Expansion Act, imposes a 100 percent ad valorem tariff on imports of patented pharmaceuticals and associated pharmaceutical ingredients, with a 20 percent rate for companies with onshoring plans approved by the Secretary of Commerce (rising to 100 percent on April 2, 2030), a 15 percent rate for products of Japan, the European Union, the Republic of Korea, and Switzerland and Liechtenstein jointly, a 10 percent rate for the United Kingdom, and a zero rate for orphan drugs, certain specialty products, and companies with Most-Favored-Nation pricing agreements (until January 20, 2029). Generic pharmaceuticals are excluded at this time. Tariffs take effect July 31, 2026 for companies listed in Annex III and September 29, 2026 for others. The Secretary of Commerce and the Secretary of Health and Human Services are directed to pursue negotiations of agreements addressing the national security threat and update the President within 90 days.

Clients in Life Sciences · Healthcare

This proclamation announces the "Ratepayer Protection Pledge" and declares that its commitments effectuate national policy. Under the pledge, accepted by seven leading technology companies on March 4, 2026, hyperscalers and AI companies commit to building, bringing, or buying the new generation resources needed to meet their data centers' electricity demand, paying for all new power delivery infrastructure upgrades, negotiating separate rate structures with utilities and state governments, investing in local communities, and coordinating with grid operators so that data center energy needs do not increase household electricity costs.

Clients in Energy and Infrastructure · Digital Infrastructure · AI, Robotics and Quantum

This proclamation imposes, under section 122 of the Trade Act of 1974, a temporary 10 percent ad valorem import surcharge on articles imported into the United States for 150 days, effective 12:01 a.m. February 24, 2026 through July 24, 2026, unless suspended, modified, terminated, or extended by Congress. Exceptions cover certain critical minerals, currency metals, energy products, certain agricultural products, pharmaceuticals, certain electronics, vehicles and parts, aerospace products, articles subject to section 232 tariffs, USMCA-qualifying goods of Canada or Mexico, certain CAFTA-DR textiles, and goods in transit meeting specified entry deadlines. The surcharge is treated as a regular customs duty, and covered goods admitted into foreign trade zones must be admitted as "privileged foreign status". The United States Trade Representative is directed to monitor conditions and advise the President on suspension, modification, or further action, and the Commissioner of CBP is authorized to administer the surcharge.

Clients in Energy and Infrastructure · Life Sciences · Transportation · Food and Beverage · Aerospace, Defense & Government Services

This EO takes additional steps with respect to the national emergency regarding Iran declared in EO 12957 (Prohibiting Certain Transactions With Respect to the Development of Iranian Petroleum Resources) by establishing a framework for imposing an additional ad valorem duty, such as 25 percent, on imports from any country that directly or indirectly purchases, imports, or otherwise acquires goods or services from Iran. The Secretary of Commerce is directed to determine whether a foreign country acquires goods or services from Iran, after which the Secretary of State, in consultation with the Secretaries of the Treasury, Commerce, and Homeland Security and the United States Trade Representative, determines whether and to what extent a duty should be imposed and recommends action to the President, who makes the final determination. The President retains authority to modify the order in response to retaliation or if affected countries align sufficiently with the United States. The order is effective at 12:01 a.m. eastern standard time on February 7, 2026.

Clients in Energy and Infrastructure

This EO sets a policy that large institutional investors should not buy single-family homes that could otherwise be purchased by families. It directs Treasury to define key terms, requires major housing-related agencies to issue guidance limiting federal facilitation or disposition of homes to such investors (with narrow build-to-rent exceptions), increases antitrust and disclosure scrutiny of investor acquisitions and rental practices, and calls for legislation to codify the policy.

Clients in Consumer Financial Services

This proclamation finds, based on a section 232 investigation by the Secretary of Commerce, that imports of semiconductors, semiconductor manufacturing equipment, and their derivative products threaten to impair U.S. national security. It imposes a 25 percent ad valorem tariff on certain advanced computing chips and derivative products ("Covered Products") effective January 15, 2026, exempting imports for uses including U.S. data centers, repairs, research and development, startups, and public sector applications. It also directs the Secretary of Commerce and the United States Trade Representative to pursue negotiations with foreign jurisdictions and update the President within 90 days, and requires the Secretary to provide a market update by July 1, 2026.

Clients in AI, Robotics and Quantum · Digital Infrastructure · Media and Technology · Aerospace, Defense & Government Services

This proclamation concurs with the Secretary of Commerce's finding under section 232 of the Trade Expansion Act that imports of processed critical minerals and their derivative products threaten to impair U.S. national security. It directs the Secretary of Commerce and the United States Trade Representative to jointly negotiate agreements with trading partners, considering price floors and other trade-restricting measures, and to provide the President a status update within 180 days. The Secretaries of Commerce and Homeland Security and the Trade Representative are authorized to issue implementing regulations, and the Secretary of Commerce must continue monitoring imports and advise on any need for further action, including possible future tariffs or minimum import prices.

Clients in Energy and Infrastructure · Aerospace, Defense & Government Services · AI, Robotics and Quantum · Digital Infrastructure · Environmental · Telecom

This EO declares a policy to accelerate defense procurement by curbing major defense contractors’ stock buybacks and dividends when they are underperforming, failing to invest in production capacity, or not prioritizing U.S. Government contracts. It directs the Secretary of War to identify such contractors, require remediation plans, and—if issues persist—use available legal and contractual enforcement tools and add future contract clauses restricting buybacks/dividends and tying executive compensation to on-time delivery and increased production rather than short-term financial metrics.

Clients in Aerospace, Defense & Government Services

This EO finds credible evidence that HieFo Corporation—controlled by a citizen of the People’s Republic of China—may threaten U.S. national security through its completed April 30, 2024 acquisition of EMCORE’s digital chip and related wafer design/fabrication/processing assets, and asserts other laws are insufficient to address the risk. It therefore prohibits the transaction and any ongoing HieFo ownership, requires divestment within 180 days (subject to CFIUS extension), and imposes interim access, transfer, reporting, and audit/verification controls enforced and overseen by CFIUS.

Clients in AI, Robotics and Quantum · Digital Infrastructure · Media and Technology

This EO directs increased federal oversight and regulation of proxy advisory firms, citing concerns that their guidance to shareholders is politicized and may compromise investor returns. The order instructs the SEC, FTC, and DOL to consider revising related regulations, enhance transparency, investigate anticompetitive and deceptive practices, and strengthen fiduciary standards to ensure proxy advisors act solely in clients' financial interests. Its aim is to restore public confidence in the industry by prioritizing investor protection, accountability, and competition.

Clients in Consumer Financial Services · ESG and Sustainability

This proclamation imposes, under section 232 of the Trade Expansion Act, a 25 percent ad valorem duty on imports of medium- and heavy-duty vehicles and specified parts and a 10 percent duty on buses, effective November 1, 2025. It directs the Secretary of Commerce to administer an import adjustment offset equal to 3.75 percent of the aggregate value of U.S.-assembled vehicles, available from November 1, 2025 through October 31, 2030, and to establish USMCA content-based duty reductions and a process for adding parts to the tariffs' scope. It also amends Proclamation 10925 and authorizes reductions of steel and aluminum tariffs under Proclamations 9704 and 9705 for Canadian or Mexican producers supplying U.S. vehicle manufacturers.

Clients in Transportation · Aerospace, Defense & Government Services · Energy and Infrastructure

This EO determines that TikTok’s proposed divestiture of its U.S. operations meets the requirements to resolve national security concerns under the Protecting Americans from Foreign Adversary Controlled Applications Act. It also directs the Attorney General to pause enforcement of the Act for 120 days to allow the divestiture to be completed, and establishes ongoing federal oversight to ensure compliance and security safeguards.

Clients in Media and Technology

The EO revises tariff exemptions for certain goods in response to ongoing national security and trade deficit concerns, authorizing modifications to tariff schedules and the implementation of trade agreements with aligned foreign partners. It empowers relevant agencies to update duties, monitor trade practices, and negotiate future tariff adjustments to advance U.S. national economic and security interests.

Clients in Energy and Infrastructure · Life Sciences · Aerospace, Defense & Government Services · Food and Beverage · Transportation

This EO implements a new United States–Japan trade agreement by establishing a baseline 15 percent tariff on nearly all Japanese imports, with sector-specific exceptions and significant market access openings for American producers, alongside Japan’s commitment to invest $550 billion in the United States. It authorizes the Secretary of Commerce and other relevant officials to adjust, monitor, and enforce these tariff measures and related regulations.

Clients in Aerospace, Defense & Government Services · Transportation · Life Sciences · Energy and Infrastructure · Food and Beverage

This EO states that it is necessary and appropriate to continue the suspension effectuated by Executive Order 14298 until 12:01 a.m. on November 10, 2025.

This EO directs the Department of Labor and other federal regulators to reevaluate and clarify guidance to allow fiduciaries of 401(k) and other defined-contribution retirement plans to prudently include alternative assets—such as private equity, real estate, and digital assets—in participant investment options.

Clients in Insurance · Fintech · Blockchain Technology and Digital Assets · Energy and Infrastructure