United States

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.

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.

SEC Adopts Final Rules for Holding Foreign Insiders Accountable Act

The SEC has adopted final rules implementing the Holding Foreign Insiders Accountable Act. These rules require directors and officers of foreign private issuers to electronically disclose their equity holdings and transactions in their company's securities starting March 18, 2026.

Supreme Court Invalidates IEEPA Tariffs; President Rescinds

The Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. Following this decision, President Trump issued an Executive Order rescinding existing IEEPA tariffs and directing agencies to terminate their collection. Businesses are advised to review contracts and plan for potential future tariffs.

EU Scales Back ESG Reporting and Due Diligence Rules

The EU has published amendments to the Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CS3D) via the Omnibus Directive EU 2026/470. These changes significantly reduce the scope of reporting and due diligence requirements for companies operating in the EU, including higher thresholds and adjusted compliance timelines.

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.

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.

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.

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.