Trump Day-One Executive Actions | Page 18

• Evaluate the sufficiency of outbound investment controls under Executive Order 14105 and propose modifications if necessary .
• Propose measures to combat foreign subsidies that distort U . S . federal procurement programs .
• Address unlawful migration and fentanyl flows through trade and national security measures .
• Agencies must deliver unified reports on findings and recommendations by following deadlines :
• Commerce-led Reports : Trade deficits , AD / CVD enforcement , USMCA , and industrial base ( due April 1 , 2025 ).
• Treasury-led Reports : Tariff collection , currency manipulation , de minimis exemption , and outbound investment controls ( due April 1 , 2025 ).
• USTR-led Reports : Trade agreements , China relations , and unfair trade practices ( due April 1 , 2025 ).
• OMB-led Report : Impact of foreign financial contributions on procurement programs ( due April 30 , 2025 ). o Analysis :
• The executive order is widely seen as a " placeholder " while the Trump administration explores longer-term trade strategies and builds congressional support for proposed actions . These investigations could serve as prerequisites for invoking tariff authorities under Section 232 , Section 301 , or Section 338 of U . S . trade law .
• Tariffs , currently paid by importers , are collected by U . S . Customs and Border Protection ( CBP ) under the Department of Homeland Security . The Executive Order does not clarify whether the proposed External Revenue Service would absorb or replace CBP ’ s responsibilities .
• Trump retains the authority to impose certain tariffs more immediately through a national emergency declaration , which would activate the powers granted under the International Emergency Economic Powers Act of 1977 ( IEEPA ).
o Outlook :
• April 1 , 2025 : Unified reports from the Secretary of Commerce , Secretary of the Treasury , and U . S . Trade Representative on trade deficits , unfair trade practices , currency manipulation , and other outlined priorities .
• April 30 , 2025 : Report from the Director of the Office of Management and Budget on the impact of foreign subsidies on U . S . federal procurement . bracewell . com 18