Trade & Sanctions

Treasury Seeks Input on CFIUS Investor Program and Streamlining Reviews

The U.S. Department of the Treasury's Office of Investment Security has published a request for information seeking public comments on streamlining the Committee on Foreign Investment in the United States (CFIUS) review process. Feedback is requested on a proposed Known Investor Program and other streamlining measures, with comments due March 18, 2026.

US Imposes Export Controls on AI Chips to China, Tariffs

The US Department of Commerce's Bureau of Industry and Security (BIS) issued a final rule on January 15, 2026, revising its export licensing review policy for advanced computing items to China. This change shifts from a presumption of denial to a case-by-case review for certain AI chips, while also imposing a 25% fee on such sales. Concurrently, a Section 232 Proclamation targets semiconductor imports with tariffs, offering exceptions for domestic use.

OFAC Issues Venezuela Oil Trade General Licenses

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued General License (GL) 46, authorizing certain transactions related to Venezuelan oil and petroleum products for established U.S. entities. This action aims to expand trade and investment opportunities, though broader sanctions remain in place.

Treasury RFI on CFIUS Known Investor Program

The U.S. Department of the Treasury has issued a Request for Information (RFI) regarding the implementation of the CFIUS Known Investor Program (KIP). The RFI seeks public input on formalizing this voluntary program, which aims to streamline foreign investment reviews. The comment period closes on March 18, 2026.

Supreme Court Invalidates IEEPA Tariffs

The U.S. Supreme Court, in a 6-3 decision in Learning Resources v. Trump, ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. This decision invalidates previously imposed IEEPA tariffs and forecloses their future use as a statutory basis for tariffs.

OFAC Authorizes Expanded Oil Activities in Venezuela

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued new General Licenses (GLs) expanding authorizations for U.S. persons involved in Venezuela's oil and gas sector. These licenses permit a wider range of transactions related to oil extraction, export, and services, aligning with a broader U.S. strategy to relax sanctions.

Responsible Business Insights for 2026

Morrison & Foerster LLP and BSR released Episode 25 of their conversation series, discussing key themes in responsible business from 2025 and offering insights for businesses in 2026. The discussion covers driving measurable impacts amid regulatory complexity and emerging risks and opportunities.

USDA Reverses Cotton Import Fee Decrease

The USDA's Agricultural Marketing Service has withdrawn a direct final rule that would have decreased cotton import fees. Due to significant adverse comments, the fees will remain unchanged, continuing the previous assessment rate.

UK Consults on Securitisation Framework Changes

The UK's FCA and PRA have published consultation papers proposing significant changes to the securitisation framework. The proposals aim to replace prescriptive due diligence requirements with a more principles-based approach, potentially impacting how investors assess credit risk, risk retention, and information availability. The consultation period is open for feedback.

Trade Report: Regulatory Dates and Deadlines

This trade report highlights upcoming regulatory deadlines and events for the week of March 2, 2026. Key dates include comment deadlines for AD/CVD investigations on citric acid, citrate salts, and fresh winter strawberries, as well as the effective date for electronic refunds from CBP. Additionally, new CITES documentation requirements for animal and plant shipments take effect.