Trade Compliance

Office of Trade Sanctions Implementation (OTSI) Annual Report

The Office of Trade Sanctions Implementation (OTSI) has published its first-year operational report, detailing activities from 2024 to 2025. The report outlines OTSI's powers, capabilities, operational functions, and engagement efforts, while also looking ahead to future priorities such as enhanced business support and proactive enforcement.

Court Orders Customs to Refund IEEPA Duties to Importers

The Court of International Trade has ordered U.S. Customs and Border Protection (CBP) to refund International Emergency Economic Powers Act (IEEPA) duties to all importers. CBP must liquidate unliquidated entries and reliquidate final entries without these duties.

Supreme Court Rules IEEPA Lacks Authority for Reciprocal Tariffs

The Supreme Court ruled in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act (IEEPA) does not grant the President authority to impose reciprocal tariffs. This decision impacts an estimated $175 billion in collected tariff revenues, raising questions about potential refunds.

Supreme Court Invalidates Tariffs Imposed Under IEEPA

The U.S. Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs, invalidating recent "reciprocal" tariffs and fentanyl-related country measures. The decision will reshape the tariff landscape, with the Court of International Trade and U.S. Customs and Border Protection expected to establish refund procedures for duties paid.

COINS Act Codifies Outbound Investment Security Program

The 2025 COINS Act, signed into law on December 18, 2025, codifies the Outbound Investment Security Program (OISP). While it does not immediately alter existing regulations, it mandates substantive changes to the OISP's scope, with new Treasury Department regulations due by March 2027.

ESMA Final Draft RTS on Clearing Thresholds Under EMIR 3

The European Securities and Markets Authority (ESMA) has published its final report with draft regulatory technical standards (RTS) amending the clearing threshold regime under EMIR 3. The changes shift the focus from ETD vs OTC to uncleared OTC transactions, with revised thresholds for various derivative classes.

Horizon Sustainability Law News Bulletin - February 2026

DLA Piper's February 2026 sustainability law bulletin covers legislative and policy developments. Key updates include California's CARB hearing on SB 253 and SB 261 regulations, discussing proposed fees, penalties, and potential exemptions for insurers.

OFAC Fines Executive $3.77M for Syria Sanctions Violations

The Office of Foreign Assets Control (OFAC) has settled with a real estate executive for $3.77 million for violating U.S. sanctions against Syria. The executive provided managerial services to Syrian real estate companies, which OFAC deemed an 'egregious' violation.

UK ICO Guidance on Agentic AI and UK GDPR Compliance

The UK ICO has released a Tech Futures report analyzing agentic AI systems and their compliance with UK GDPR. The report emphasizes that developers and deployers of these systems must adhere to existing UK GDPR requirements, including those related to automated decision-making, data minimization, and accuracy.

Ninth Circuit Expands Personal Jurisdiction Over Foreign Tech Platforms

The Ninth Circuit expanded personal jurisdiction over foreign tech companies in data breach cases in Freeman v. 3Commas Technologies OÜ. The ruling allows foreign companies with significant digital activities and knowledge of California customers to be sued in California courts, reversing a lower court's dismissal.