February 2026

Trade policy has always been political. What has changed is the speed. A new executive order. A tariff announcement. A sanctions update. A court decision. A sudden enforcement priority shift. Importers can wake up on Tuesday operating under assumptions that were perfectly reasonable on Monday. The risk is not the rule change itself, but rather

In this part two of our three-part article on Section 338, we explore the “imported in a vessel of…” clause. Now that the SCOTUS has struck down the IEEPA tariffs, what can we expect as a reaction from the Administration?  Two words: section 338 (OK, one word and one number.  Sue me.) Section 338 of the Tariff Act of 1930 contains