In its semi-annual foreign exchange rate report, the Treasury Department again did not name any trading partners as currency manipulators but warned that future unfair currency practices could be met with tariffs.
The report finds that for the four quarters through December 2024 no major trading partner met all three criteria under the Trade Facilitation and Trade Enforcement Act of 2015 with respect to its macroeconomic and exchange rate policies: (1) a significant bilateral trade surplus with the U.S. (i.e., at least $15 billion), (2) a material current account surplus (i.e., at least three percent of the country’s gross domestic product), and (3) persistent one-sided intervention in the foreign exchange market (i.e., conducting repeatedly, in at least eight of the last twelve months, net purchases of foreign currency that total at least two percent of the country’s GDP).
In addition, under the Omnibus Trade and Competitiveness Act of 1988 Treasury has found that no major U.S. trading partner manipulated its exchange rate for purposes of preventing effective balance of payments adjustments and gaining unfair competitive advantage in international trade. At the same time, the report again cites China for its “lack of transparency around its exchange rate policies and practices.”
However, Treasury is maintaining China, Germany, Japan, Korea, Singapore, Taiwan, and Vietnam on – and adding Ireland and Switzerland to – its list of countries targeted for close scrutiny of their currency practices and macroeconomic policies.
Treasury states that future reports will strengthen its analysis of trading partners’ currency policies and practices, including greater vigilance about means beyond the criteria outlined above that may be employed to influence exchange rates. Treasury will also use all available tools to counter unfair currency practices, which may include recommending the use of existing tariff authorities following a currency manipulation determination.
Copyright © 2025 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.