Recent changes
FinCEN and OFAC Intensify Efforts Targeting Mexican Cartel Money Laundering
FinCEN and OFAC are intensifying efforts against Mexican cartel money laundering, targeting over 100 US Money Services Businesses (MSBs) along the southwest border. Recent actions include sanctions against individuals and entities linked to the Hysa Organized Crime Group and proposed rulemaking to identify certain Mexican gambling transactions as primary money laundering concerns.
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.
DOJ Announces New Trade Fraud Enforcement Initiative
The US Department of Justice has announced a new Trade Fraud Task Force and initiative, elevating trade fraud enforcement to a national and economic security priority. This signals increased scrutiny and criminal enforcement actions against companies involved in customs violations, tariff evasion, and forced labor.
China's 2025 Arbitration Law Effective
China's amended Arbitration Law, effective March 1, 2026, introduces significant reforms to its arbitration framework. Key changes include codifying the arbitration seat, expanding foreign-related arbitration access, strengthening court support for interim relief, and allowing limited ad hoc arbitration. International companies doing business with China should review their dispute resolution clauses.
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.
Trump Ends IEEPA Tariffs, Imposes New Trade Act Tariffs
President Trump ended tariffs imposed under IEEPA and initiated new tariffs under Section 122 of the Trade Act of 1974, set at 15% and lasting 150 days. The USTR also announced new Section 301 investigations targeting major trading partners. These changes took effect February 20, 2026.
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.
UK Securitisation Proposals Diverge from EU Position
The UK's Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) have released consultation papers proposing reforms to the UK securitisation framework. These proposals aim to liberalise due diligence obligations and align with international, particularly US, market practices, diverging from the EU's approach.
IRS Guidance on Prohibited Foreign Entity Safe Harbors for Clean Energy Tax Credits
The IRS and Treasury released Notice 2026-15 providing interim guidance on calculating material assistance from prohibited foreign entities for clean energy tax credits under Sections 45Y, 48E, and 45X. The notice outlines a four-step process for determining the Material Assistance Cost Ratio (MACR) and offers certain safe harbors.
In-Transit Freight Financing for Working Capital
This article discusses in-transit freight financing, a method for businesses to convert goods in transit into financeable assets to unlock working capital. It highlights how this strategy can help companies manage cash flow disruptions caused by unpredictable global supply chains and recommends partnering with experienced lenders.
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