FCC Industry Analysis

Russia/Ukraine Sanctions Update - February 2026

The U.S. OFAC issued an amended General License 131C extending certain transactions related to Lukoil International GmbH through April 1, 2026, and updated related FAQs. The EU also extended its sanctions against Russia until February 24, 2027, and added eight individuals to its sanctions list.

Europe's Phaseout of Russian Gas by 2027 and Contractual Risks

Europe is mandating the phaseout of Russian gas imports by 2027, creating significant market and contractual risks for energy companies. The guidance outlines the policy shift, its impact on gas and LNG contracting, and strategies for managing increased contractual risk due to compressed timelines and geopolitical pressures.

EU Commission Publishes Foreign Subsidies Regulation Guidelines

The European Commission has published new guidelines on the application of the Foreign Subsidies Regulation (FSR). These guidelines clarify criteria for assessing distortive foreign subsidies, outline a balancing test for negative versus positive effects, and detail the Commission's power to request prior notification of below-threshold cases.

Gulf Conflict Impacts Global Oil and LNG Markets

Vinson & Elkins LLP published a notice on March 2, 2026, detailing the potential impacts of the Gulf conflict on global oil and LNG markets. The analysis highlights how the duration and intensity of hostilities could affect crude prices, contractual performance, and supply chain stability for energy companies.

Greece Enacts New Law to Combat Art Forgery and Protect Cultural Heritage

Greece has enacted Law No. 5271/2026, establishing a new legal framework to combat art forgery and protect cultural items. The law introduces autonomous criminal offenses for forgery and damage to artworks, alongside stricter penalties and a new register for certified art experts. This aims to enhance the protection of the art market and cultural heritage.

China's Cross-Border Data Transfer Regime Enforcement Trends

China's Cyberspace Administration has released two enforcement cases from 2025 concerning violations of cross-border data transfer requirements. These cases, involving hotel and property management sectors, highlight the increasing focus on compliance with the country's data export regulations.

Florida AG Creates Unit to Combat Foreign Adversary Threats

Florida Attorney General James Uthmeier announced the creation of the CHINA Prevention Unit to combat threats from foreign adversaries, particularly the Chinese Communist Party, to consumer data privacy and economic security. The unit will audit companies and pursue enforcement actions for violations.

BIS Fines Teledyne FLIR $1M for Unlicensed China Exports

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) settled with Teledyne FLIR for $1,000,000 over alleged violations of the Export Administration Regulations (EAR). The violations involved unlicensed exports of thermal imaging cameras to China and miscalculations under the de minimis rule.

OFAC Delists Altomare SA and Vessel Kallista from SDN List

The U.S. Office of Foreign Assets Control (OFAC) announced on January 21, 2026, the removal of Greek maritime company Altomare SA and its vessel, Kallista, from the Specially Designated Nationals (SDN) List. The entities were originally designated in November 2025.

UK Sanctions List Consolidation

The UK's Foreign, Commonwealth and Development Office is consolidating its sanctions designations into a single UK Sanctions List (UKSL) effective January 28, 2026. This change aims to reduce non-compliance risk by simplifying identification of sanctioned individuals and entities, without altering the scope of sanctions or business obligations.