Trade & Export

OFAC Sanctions Risks and Cartel Designations

OFAC has settled a $1.7 million case with IMG Academy for sanctions violations related to cartel-linked entities. This highlights increased compliance risks for entities with international touchpoints due to heightened cartel designations and sanctions enforcement.

Canadian Sanctions Laws Overview

Blake, Cassels & Graydon LLP has published an overview of Canada's complex sanctions laws, effective March 2026. The guidance details how these laws impact Canadian businesses and foreign states, outlining prohibitions, reporting obligations, and asset blocking requirements for entities operating in or with Canada.

UK Sanctions Nearly 300 Russian Entities

The UK has announced its largest sanctions package against Russia, designating nearly 300 entities involved in critical energy revenues, military supply chains, and financial institutions. These measures aim to disrupt Russia's war effort and access to international markets.

Vertical Conduct Violation Fines Dropped Six-Fold in 2025

A report indicates that fines for vertical conduct violations globally dropped six-fold in 2025 compared to 2024, with the number of infringement decisions halved. Despite this overall decrease, the European Commission remained the most active enforcer, focusing on the consumer and retail sectors, and resale price maintenance continued to be a key area of scrutiny.

Global Cartel Fines Surge to $3.3 Billion in 2025

Global cartel fines reached $3.3 billion in 2025, the highest total since 2021, driven primarily by enforcement actions in the European Union. The report highlights significant increases in fines from the European Commission and EU member states, while the US saw its lowest fine total in recent memory.

Global Antitrust Fines Rose to $7.7B in 2025

Global antitrust fines reached $7.7 billion in 2025, the highest since 2021, driven by a few major cases, while the total number of infringement decisions fell. Enforcement is increasingly shaped by geopolitical and national security priorities, with a focus on sectors impacting the cost of living.

EBA Final Guidelines on Third-Country Branch Capital Endowment

The European Banking Authority (EBA) has published final guidelines on instruments that third-country branches can use to meet their capital endowment requirements under CRD IV. These guidelines clarify which debt securities and other instruments are acceptable and set operational conditions for their use.

Germany Updates Product Liability Law

Germany's Bundestag has begun reviewing a draft act to modernize its Product Liability Act, transposing an EU directive. The reform aims to update the law for digital products, AI, and global supply chains, with an expected entry into force by December 9, 2026.

CIT and CBP Outline IEEPA Tariffs Recovery Process

The Court of International Trade (CIT) and U.S. Customs and Border Protection (CBP) are outlining a process for importers to recover unlawful IEEPA tariffs. This guidance suggests importers may not need to file protests on all entries immediately, potentially reducing recovery costs. Importers are advised to update their ACE accounts and prepare for potential protest filings.

Litigation Challenges Legality of Section 122 Duties

Twenty-four states and two private companies have filed lawsuits challenging the legality of Section 122 duties imposed on February 20, 2026. The complaints argue that the President lacks the authority to impose these duties, citing violations of separation of powers and nondelegation doctrines.