Law Firm Examines Trump's Possible Russia Sanctions Moves, Export Control Approach
Former President Joe Biden's administration made the most “aggressive and far-reaching use” of trade tools of any U.S. administration in history, and the new Trump administration is on track to “wield these tools in an even more aggressive manner,” Gibson Dunn said in a 2024 international trade recap released this month. Although the Treasury Department under Biden imposed sanctions at a faster rate than any of his predecessors, the law firm noted that President Donald Trump favors tariffs, which could cause the targets of those tariffs, including U.S. trading partners in Europe and Asia, to deploy similar tools “either in retaliation against U.S. measures or in pursuit of their own strategic interests.”
Sign up for a free preview to unlock the rest of this article
Export Compliance Daily combines U.S. export control news, foreign border import regulation and policy developments into a single daily information service that reliably informs its trade professional readers about important current issues affecting their operations.
After several years of closely coordinated trade measures, Gibson Dunn said it’s expecting a “reshaped international trade landscape marked by friction among traditional allies and heightened uncertainty for the business community.”
The law firm’s recap provides an overview of last year’s new sanctions, export controls and foreign investment restrictions. It also previews possible future U.S. sanctions moves. As Trump looks to help negotiate an end to the Russian-Ukraine war, Gibson Dunn said, the U.S. could “tighten trade restrictions in an attempt to push Moscow to the negotiating table,” including by imposing blocking sanctions on all remaining Russian banks and oil majors such as Rosneft and Lukoil. Trump could also threaten to impose secondary sanctions on foreign financial institutions, including those in China and India, that process payments involving Russian energy.
But the law firm also said it could envision Trump easing sanctions against Russia if negotiations to end the war “show signs of progress.” It said nearly all Biden-era sanctions can be “rescinded with the stroke of a pen,” but doing so could create tension between the U.S., the EU and other allies that the Biden administration worked with to pressure Moscow. The firm said those nations “to date have shown little appetite for easing their own considerable restrictions on Russia.”
Gibson Dunn also said it’s unclear how Trump may tweak the Biden administration’s most recent semiconductor and artificial intelligence-related export controls (see 2501130026 and [2501150040]). Although the restrictions are “likely aligned” with Trump’s China policies, they could still be “subject to delay or reconsideration in light of the rules’ shifting legal foundation,” the firm said, noting that multiple rules were issued under Biden’s 2023 executive order on AI, which Trump has rescinded.
“While the Trump administration’s export control priorities remain opaque, the compliance complexities associated with these efforts are unlikely to abate,” the firm said.