The BR International Trade Report: December 2025

The BR International Trade Report December 2025

Welcome to this month’s issue of The BR International Trade Report, Blank Rome’s monthly digital newsletter highlighting international trade, cross-border investment, and geopolitical risk issues impacting businesses domestically and abroad. We invite you to share this resource with your colleagues and visit Blank Rome’s International Trade webpage for more information about our team.

Recent Developments

As U.S. importers await the Supreme Court’s decision on IEEPA tariffs, Trump Administration officials hint at backup plans. While the U.S. Supreme Court continues to deliberate the legality of the “reciprocal” and “fentanyl” tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”), the Trump Administration has hinted at alternative tariffing methods should the Court rule the existing tariffs unlawful. At an event in New York, Secretary of the Treasury Scott Bessent emphasized that the Administration “can recreate the exact tariff structure with [Sections] 301, with 232, with 122.” During a separate interview, National Economic Council Director Kevin Hassett confirmed that the Administration has “a backup plan that will get these things in place right away…[s]o we’re going to win either way.” Notably, an adverse ruling for the government could result in refunds for those who have already paid tariffs, spurring lawsuits by importers.

Trump Administration publishes 2025 National Security Strategy. On December 4, the White House released the 2025 National Security Strategy (“NSS”), which aims to synthesize trade policy, immigration, and other issues into a larger foreign affairs framework. Notably, the document presents the “Trump Corollary” to the Monroe Doctrine, which advocates for partnerships with Latin American governments in both anti-drug trafficking efforts and the pushback against certain non-hemispheric actors. In addition, the NSS emphasizes that the Administration will prioritize “[e]nding the perception, and preventing the reality, of NATO as a perpetually expanding alliance.”

U.S. seizes oil tanker near Venezuelan coast. On December 10, U.S. forces boarded and seized a sanctioned oil tanker, allegedly sailing under a falsely flown Guyanese flag. Following the seizure, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on three family members of Venezuelan president Nicolas Maduro and six vessels allegedly transporting sanctioned oil. Venezuelan and Cuban leaders denounced the U.S. action, with Yván Gil Pinto—the Minister of Foreign Affairs of Venezuela—calling the seizure an “act of international piracy.” On December 16, President Trump stated that he is ordering a “total and complete blockade of all sanctioned oil tankers” entering and exiting Venezuelan ports.

U.S. and allies join AI and supply chain security coalition. On December 12, the State Department announced the “Pax Silica,” an organization of seven countries—the United States, Australia, Israel, Japan, Singapore, South Korea, the United Kingdom—which will cooperate on critical minerals and the tech sector. In particular, Undersecretary for Economic Affairs Jacob Helberg stated that Pax Silica countries will “cooperate on aligning our export controls, screening of foreign investments, addressing anti-dumping but with a very proactive agenda on securing choke points in the global supply chain system.” The Pax Silica held its initial summit on the same day, which was also attended by the Netherlands and the United Arab Emirates.

President Trump launches the Genesis Mission. Aimed at securing U.S. leadership in artificial intelligence (“AI”), the Genesis Mission is a national effort to build an integrated AI platform by utilizing federal scientific databases to train AI models to maximize the nation’s research and development capabilities. The Genesis Mission will focus on three key areas of national importance: rapidly improving scientific discovery, strengthening national security, and ensuring energy dominance. The effort aligns with the Trump Administration’s recent actions focused on the development of AI, such as America's AI Action Plan and Executive Order (“EO”) 14179 on Removing Barriers to American Leadership in Artificial Intelligence.

Netherlands suspends move to take control of Nexperia. The Dutch government has suspended its contentious takeover of the Dutch-headquartered, Chinese-owned chipmaker Nexperia, after weeks of “constructive” talks with Beijing. Nexperia is a critical source of supply of foundation chips—transistors, diodes, and power management components—for the auto industry.

Tensions between China and Japan persist as Chinese military aircraft locks radar onto Japanese fighter jet. In the midst of China-Japan tensions following Japanese Prime Minister Sanae Takaichi’s suggestion that Japan may respond with force should China invade Taiwan, Chinese J-15 fighter aircraft reportedly latched their radar onto Japanese F-15 fighters near Okinawa on December 7. The Chinese Ministry of Defense later remarked, “We are extremely dissatisfied with and firmly oppose the provocative actions and misleading remarks of the Japanese side.”

The Trump Administration focuses on new trade agreements as the year draws to a close.

U.S. secures trade deals with four Latin American countries. On November 13, the Trump Administration announced a set of trade deals with Argentina, Ecuador, El Salvador, and Guatemala, with each country remaining subject to its existing reciprocal tariff rate. The additional commitments vary by country, but include, for example, addressing “non-tariff barriers,” maintaining environmental protections, and refraining from imposing digital service taxes.
U.S. reaches deal with Switzerland, reducing reciprocal tariff rate on Swiss products. The United States, Switzerland, and Lichtenstein agreed to a framework deal that will see Switzerland and Lichtenstein remove certain tariffs and non-tariff barriers while Swiss and Lichtenstein companies will invest $200 billion into the United States. In exchange, the United States will reduce the reciprocal tariff rate on products imported from the two countries to 15 percent, in line with the rate for the European Union.
United States agrees to economic and defense deal with Saudi Arabia. On November 18, President Trump and Saudi Crown Prince Mohammed bin Salman signed a series of agreements, collectively referred to as an “Economic and Defense Partnership.” Most notably, the two leaders agreed that Saudi Arabia would increase its investment into the United States to almost $1 trillion, and signed a U.S.-Saudi Strategic Defense Agreement (“SDA”) which, according to the White House, will “mak[e] it easier for U.S. defense firms to operate in Saudi Arabia.”
U.S. and UK agree to pharmaceutical tariff deal. In early December, Washington and London struck a deal granting a three-year, zero-tariff exemption on UK-origin pharmaceuticals imported into the United States. The agreement marks a shift toward negotiated, reciprocal trade frameworks in healthcare, with Washington signaling a readiness to redefine trade-policy norms on medicines. Following the announcement, U.S. Secretary of Health Robert F. Kennedy Jr. remarked that the agreement “strengthens the global environment for innovative medicines and brings long-overdue balance to U.S.-U.K. pharmaceutical trade.”
U.S. and DRC sign Strategic Partnership Agreement, deepening critical minerals cooperation. The December 5 agreement seeks to promote U.S. mining access and investment in the Democratic Republic of the Congo (“DRC”). In particular, the agreement establishes the United States-DRC Binational Economic Partnership Forum and authorizes the DRC to designate certain “Strategic Projects” in which U.S. persons may be granted preferential access and right of first offer. The U.S. Development Finance Corporation later announced two letters of interest (“LOIs”) in projects relating to Congolese mining and railway infrastructure.

Trump Administration removes tariffs on many Brazilian agricultural products. On November 20, President Trump issued EO 14361, which modified the scope of Brazilian-origin items subject to the 40 percent tariff imposed in response to Brazil’s prosecution of former president Jair Bolsonaro. Notably, following the November 14, 2025, EO 14360 (“Modifying the Scope of Reciprocal Tariffs With Respect to Certain Agricultural Products”), many of these newly exempt products no longer face any IEEPA tariffs.

U.S. threatens South Korea with Section 301 investigation if digital regulations continue. According to reports, the Trump Administration has quietly threatened a Section 301 investigation against South Korea should Seoul fail to follow through with its promise to “ensure that U.S. companies are not discriminated against and do not face unnecessary barriers in terms of laws and policies concerning digital services.”

For continuous, up-to-date information on the evolving administrative landscape, check out Blank Rome’s Trump Administration Resource Hub. Explore previous BR International Trade Reports here.

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