United States

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.

USTR Seeks Input on Critical Minerals Trade Agreement

The Office of the United States Trade Representative (USTR) has opened a public docket to gather stakeholder input for a proposed "Plurilateral Agreement on Trade in Critical Minerals." This initiative aims to establish multinational policies for critical minerals supply chains, potentially including pricing mechanisms and investment incentives, following President Trump's Section 232 Proclamation.

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.

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.

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.

State and Education Depts. Partner on Foreign Gift Reporting

The U.S. Department of Education and the U.S. Department of State have formed a partnership to jointly oversee Section 117 foreign gift and contract reporting requirements for higher education institutions. This collaboration aims to streamline oversight and enhance transparency regarding foreign influence in academia.

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.