In short order, on November 14, 2025, President Trump again modified Executive Order 14257 (“Modified Order”) which imposed “reciprocal tariffs” on U.S. trading partners, pursuant to the International Emergency Economic Powers Act of 1977 (IEEPA) and the National Emergencies Act (NEA). Per the Administration, reciprocity was based on multiple factors, including existing tariffs and regulations imposed on the U.S. 

The New York City Council recently amended both the Earned Safe and Sick Time Act (ESSTA) and the Temporary Schedule Change Act (TSCA). Because Mayor Adams failed to sign or veto the amendments, they will become effective on February 22, 2026. Preparing to comply with the requirements resulting from these developments must be on the agenda for 2026 for all employers with employees working in the Big Apple.

Following the recent government shutdown, the SEC’s Division of Corporation Finance (the “Division”) has issued guidance in the form of Questions and Answers to help address questions from issuers with pending filings and to clarify how filings will be processed now that operations have resumed.

On November 10, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a one-year suspension of the "Affiliates Rule" it announced on September 29, 2025

The U.S. Department of Homeland Security has announced that it intends to end automatic work permit extensions for certain noncitizens beginning on October 30, 2025.

On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed further sanctions (Sanctions) as a “result of Russia’s lack of serious commitment to a peace process to end the war in Ukraine.”

Earlier in October 2025, China announced additional export controls on rare earth minerals that are critical to U.S. defense and technology industries. In response, President Donald Trump announced on Truth Social that the U.S. would impose an additional 100 percent tariff on all imported Chinese goods, as well as new export controls on critical software on November 1, 2025.