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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 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.

On September 16, 2026, President Trump issued a Presidential Memorandum (the “Memorandum”) titled “Restoring Reciprocity in Government Procurement,” which aims to remove Canadian origin items from the U.S. government procurement system.  The Memorandum provides few details on how this policy goal should be effectuated, but directs the following actions:

  • The Office of Management and Budget (“OMB”) Director and U.S. Trade Representative, in coordination with the FAR Council, and in consultation with other senior officials as appropriate, shall “to the extent appropriate and consistent with law, identify and take all steps permitted by applicable law with respect to Canadian origin items in the Federal civil procurement system that can, where warranted, be removed or made non-available for purchase.”
  • The OMB Director, in consultation with other senior officials as appropriate, shall also “notify” relevant executive departments and agencies of domestic alternatives to Canadian origin items, “to the extent permitted by law.”
Continue Reading Presidential Memorandum Tasks Agencies with Removing Canadian Origin Items from Federal Procurement System