Trade Compliance

OCC GENIUS Act Proposal on Stablecoins

The Office of the Comptroller of the Currency (OCC) has issued a Notice of Proposed Rulemaking (NPR) to implement the GENIUS Act concerning stablecoins. The proposal seeks public comment on regulatory frameworks for permitted payment stablecoin issuers, including rules on yield-bearing features and opt-out provisions for state-approved issuers. Comments are due May 1, 2026.

Germany NIS2 Cybersecurity Law Implementation Deadline

Germany's implementation law for the NIS2 Directive, effective December 2025, expands cybersecurity requirements to new sectors including digital services and manufacturing. Covered entities must register with the BSI by March 6, 2026, and comply with new security and incident reporting obligations.

EU-UK Competition Cooperation Agreement Signed

The European Commission and the UK have signed a competition cooperation agreement establishing a formal post-Brexit framework for antitrust and merger enforcement coordination. The agreement institutionalizes notification, coordination, and information-sharing mechanisms but requires ratification by both parties and is not yet in force.

Texas Court Requires US Domicile for Chapter 15 Recognition

The US Bankruptcy Court for the Southern District of Texas ruled in In re Siu-Fung Ceramics Holdings that foreign debtors must have a US domicile, place of business, or property to qualify for Chapter 15 recognition. This decision aligns with the Second Circuit and diverges from the Eleventh Circuit's precedent.

CRD VI Consequences for M&A Transactions

CRD VI introduces a new harmonized regime for M&A transactions in the banking sector across the EU, requiring prior notification and, in some cases, approval from competent authorities. While national transposition is incomplete, the M&A provisions are set to apply from January 11, 2026.

USITC Launches Investigations into China Trade Relations and Biotech Support

The US International Trade Commission (ITC) has launched two Section 332 investigations: one examining the economic effects of revoking China's permanent normal trade relations status, and another reviewing China's state support and pricing practices in the biotechnology sector. These investigations will provide an analytical record for Congress and the administration regarding future trade and industrial policy measures targeting China.

OFAC Fines IMG Academy for Sanctions Violations

The Office of Foreign Assets Control (OFAC) has fined IMG Academy $XXX,XXX for accepting tuition payments from parents designated under sanctions. The enforcement action highlights the pervasive nature of sanctions risk across various sectors, including educational institutions.

Mideast War Disrupts LNG Contracts and Raises Supply Security Questions

The escalating conflict in the Middle East has disrupted LNG contracts, particularly due to the de facto closure of the Strait of Hormuz and attacks on Qatari facilities. This has led to record-high spot prices and is raising urgent questions about supply security and contractual performance for energy companies.

CIT Orders Refunds of IEEPA Tariffs on Unliquidated Entries

The Court of International Trade (CIT) has ordered U.S. Customs and Border Protection (CBP) to refund tariffs collected under the International Emergency Economic Powers Act (IEEPA) on unliquidated and not finally liquidated entries. This ruling benefits all importers who paid these tariffs.

Importers Can Preserve Rights for IEEPA Tariff Refunds

Following a Supreme Court ruling that the International Emergency Economic Powers Act (IEEPA) does not authorize presidential tariffs, importers can take steps to preserve their rights for refunds of paid duties. The US Court of International Trade is expected to address remedies soon, and importers have options including post summary corrections, protests, or lawsuits.