As described in our prior client alert, President Trump threatened in July to impose tariffs of 50% on imports of products from Brazil in response to U.S. concerns regarding Brazil’s criminal prosecution of former President Jair Bolsonaro, recent judicial developments impacting social media regulation in Brazil, Brazil’s allegedly unfair trade practices, and Brazil’s support for BRICS policies that the Trump Administration has deemed to be “anti-American.”  President Trump recently followed through on these threats by issuing Executive Orders (“EOs”) imposing cumulative tariffs against Brazil under the International Emergency Economic Powers Act (“IEEPA”). Separately, the United States took additional measures against certain Brazilian Supreme Court judges, primarily targeting the judge overseeing the Bolsonaro trial. In addition, the Office of the U.S. Trade Representative (“USTR”) is conducting an investigation of Brazil’s unfair trade policies under Section 301 of the Trade Act of 1974 (“Section 301”), which may result in the imposition of additional U.S. tariffs or other trade measures against Brazil. These measures may have significant implications for U.S. and Brazilian companies reliant on bilateral trade, as well as affect U.S. companies operating in Brazil and Brazilian companies operating in the United States.

Click here to read the full alert on cov.com.

Photo of Arun Venkataraman Arun Venkataraman

Arun Venkataraman leverages 20 plus years of government and private sector experience to provide legal, policy, and strategic advice to clients on a range of international trade matters.

Arun joined the firm after serving in senior roles at the U.S. Department of Commerce.

Arun Venkataraman leverages 20 plus years of government and private sector experience to provide legal, policy, and strategic advice to clients on a range of international trade matters.

Arun joined the firm after serving in senior roles at the U.S. Department of Commerce. Most recently, he served as the Senate-confirmed Assistant Secretary of Commerce for Global Markets and Director General of the U.S. and Foreign Commercial Service at the International Trade Administration (ITA) from 2022-2025. Arun led the federal government’s efforts to expand commercial opportunities for U.S. firms overseas and foreign firms in the United States, including by facilitating deals between U.S. and foreign companies, improving commercial policy environments, resolving barriers to trade and investment, and negotiating governmental agreements to promote commercial partnerships. He also served as Counselor to the Secretary of Commerce, advising the Secretary on all aspects of foreign economic policy within the Department. In this role, Arun led negotiations with foreign governments on technology policy, as well as Section 232 steel and aluminum tariffs.

Before joining the Biden Administration, Arun was Senior Director, Global Government Engagement, at Visa. He developed and executed engagement strategy, in advocacy before the U.S. and foreign governments, as well as with trade associations, international organizations, and other stakeholder groups on a range of international policy issues including digital economy, trade, tax, and sanctions.

During the Obama Administration, Arun served as ITA’s first-ever Director of Policy, where he led efforts across the Commerce Department to remove global trade and investment barriers and strengthen the global competitiveness of U.S. industry, including in such markets as China and India. This included leading Department efforts to support Trans-Pacific Partnership (TPP) negotiations, pass Trade Promotion Authority (TPA) legislation, and secure improvements in China’s competition law and semiconductor policies.

Arun also served in the Office of the U.S. Trade Representative (USTR) as the Director for India, where he led the development and implementation of U.S.-India trade policy, for which he received the agency’s Kelly Award for outstanding performance and extraordinary leadership. He also served as USTR’s Associate General Counsel, representing the United States in litigation before the World Trade Organization (WTO) and in bilateral and multilateral negotiations on international trade agreements.

Prior to USTR, Arun was a Legal Officer in the Appellate Body Secretariat at the WTO, where he advised on appeals in litigation between countries under WTO rules. He also served as a Law Clerk for Judge Jane A. Restani at the U.S. Court of International Trade.

Photo of Kate McNulty Kate McNulty

Kate McNulty advises U.S. and international clients on a range of complex international trade issues, dynamic U.S. and global tariff matters, and related trade compliance questions, including tariff stacking. She provides legal, policy, and strategic advice to companies, trade associations, and governments on…

Kate McNulty advises U.S. and international clients on a range of complex international trade issues, dynamic U.S. and global tariff matters, and related trade compliance questions, including tariff stacking. She provides legal, policy, and strategic advice to companies, trade associations, and governments on international economic policy matters, and assists clients in navigating geopolitical risk. She advises clients on the negotiation and enforcement of international trade agreements, including enforcement proceedings arising under the facility-specific rapid response labor mechanism of the USMCA.

Kate regularly represents clients before U.S. agencies such as the Office of the U.S. Trade Representative (USTR) and the U.S. Department of Commerce, including in proceedings arising under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. She also litigates before the U.S. Court of International Trade and represents clients in antidumping and countervailing duty (AD/CVD) proceedings.

Prior to joining Covington, Kate held various positions in the U.S. government. Most recently, Kate served in the Office of Multilateral Trade Affairs at the U.S. Department of State from 2009 to 2018, where she managed trade enforcement matters for the Department—including U.S. government actions under Section 301 and Section 232—and also participated in the negotiation of international trade agreements on behalf of the U.S. government.

Photo of Daniel Erikson Daniel Erikson

Daniel P. Erikson has more than twenty years of experience in international relations, foreign policy, national security, and defense policy, primarily focused on Western Hemisphere affairs. A non-lawyer, Dan’s experience includes serving at the National Security Council, the Department of Defense, the Office…

Daniel P. Erikson has more than twenty years of experience in international relations, foreign policy, national security, and defense policy, primarily focused on Western Hemisphere affairs. A non-lawyer, Dan’s experience includes serving at the National Security Council, the Department of Defense, the Office of the Vice President, and the Department of State, as well as work for think-tanks, universities, and private sector consultancies.

Prior to joining the firm, Dan was Special Assistant to the President and Senior Director for Western Hemisphere Affairs at the National Security Council, where he served as the lead White House advisor on the hemisphere. His work covered all diplomatic, economic, and national security issues related to Mexico, Central America, the Caribbean, South America, and Canada.

Dan was previously the Deputy Assistant Secretary of Defense for the Western Hemisphere at the U.S. Department of Defense. At the Pentagon, he successfully advanced U.S. defense priorities as the Department’s senior policy official for the Western Hemisphere, with a focus on defense modernization, effective security cooperation, counter-narcotics, climate resilience, cyber, and humanitarian assistance and disaster relief. In this capacity, Dan served as a member of the Senior Executive Service and managed a team of civilian and military defense professionals to provide policy guidance to the Secretary of Defense, U.S. Northern Command, and U.S. Southern Command.

Dan also served in the White House as Special Advisor to the Vice President, where he covered foreign affairs, economic, and national security issues in the Western Hemisphere. Prior to this, Dan was Senior Advisor for Congressional and Inter-Governmental Affairs and Senior Advisor for Policy at the U.S. Department of State. His responsibilities included advising State Department leadership on complex diplomatic issues and key administration and congressional priorities.

In addition to his U.S. government experience, Dan has held senior positions in the private sector, think-tanks, and academia. He has published widely on a range of topics in international and Latin American and Caribbean affairs and testified before the U.S. Congress. He is the recipient of the Secretary of Defense Medal for Outstanding Public Service and the U.S. State Department’s Superior Honor Award.

Photo of Diego Bonomo Diego Bonomo

Diego Bonomo is a senior advisor in the firm’s London office. Diego, a non-lawyer, has more than 25 years of Brazil regulatory, trade, and foreign affairs experience at leading business associations, think tanks, companies, and academic institutions. Diego also served in the Brazilian…

Diego Bonomo is a senior advisor in the firm’s London office. Diego, a non-lawyer, has more than 25 years of Brazil regulatory, trade, and foreign affairs experience at leading business associations, think tanks, companies, and academic institutions. Diego also served in the Brazilian government.

Before joining the firm, Diego was Team Leader of the Brazil Trade Facilitation Program at Palladium and Executive Manager of International Affairs at Brazil’s National Confederation of Industry — CNI. At the U.S. Chamber of Commerce, he served as Senior Director of the International Division and Senior Director for Policy of the Brazil-U.S. Business Council. Diego also was Executive Director of the Brazil Industries Coalition — BIC, the leading Brazilian business coalition in the United States, and General Coordinator of Foreign and Trade Affairs at the Federation of Industries of the State of São Paulo — FIESP. He previously served in the Office of the President of Brazil as advisor to the Minister of Long-Term Planning.

Diego holds a bachelor’s and master’s degree in international relations from the Pontifical Catholic University of São Paulo.