Trade Compliance

China's Cross-Border Data Transfer Regime Enforcement Trends

China's Cyberspace Administration has released two enforcement cases from 2025 concerning violations of cross-border data transfer requirements. These cases, involving hotel and property management sectors, highlight the increasing focus on compliance with the country's data export regulations.

Greece Enacts New Law to Combat Art Forgery and Protect Cultural Heritage

Greece has enacted Law No. 5271/2026, establishing a new legal framework to combat art forgery and protect cultural items. The law introduces autonomous criminal offenses for forgery and damage to artworks, alongside stricter penalties and a new register for certified art experts. This aims to enhance the protection of the art market and cultural heritage.

EU Commission Publishes Foreign Subsidies Regulation Guidelines

The European Commission has published new guidelines on the application of the Foreign Subsidies Regulation (FSR). These guidelines clarify criteria for assessing distortive foreign subsidies, outline a balancing test for negative versus positive effects, and detail the Commission's power to request prior notification of below-threshold cases.

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.

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.

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.

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.

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.

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.