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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.

DOJ Announces New Trade Fraud Enforcement Initiative

The US Department of Justice has announced a new Trade Fraud Task Force and initiative, elevating trade fraud enforcement to a national and economic security priority. This signals increased scrutiny and criminal enforcement actions against companies involved in customs violations, tariff evasion, and forced labor.

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.

OFAC Designates Rwanda Defence Force and Officials; Issues General License

The US Treasury's OFAC has designated the Rwanda Defence Force and four Rwandan officials under its Specially Designated Nationals (SDN) List for actions related to the Democratic Republic of the Congo. OFAC also issued DRC-related General License 1 to authorize the wind-down of transactions involving the Rwanda Defence Force.

BIS Fines Teledyne FLIR $1M for Unlicensed China Exports

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) settled with Teledyne FLIR for $1,000,000 over alleged violations of the Export Administration Regulations (EAR). The violations involved unlicensed exports of thermal imaging cameras to China and miscalculations under the de minimis rule.

Switzerland Updates ISIL and Al-Qaida Sanctions List

Switzerland's State Secretariat for Economic Affairs (SECO) announced an update to its sanctions list concerning individuals, groups, undertakings, and entities associated with ISIL (Da'esh) and Al-Qaida. The update reflects amendments made by the UN sanctions committee, entering into force in Switzerland without delay.

OFAC Delists Altomare SA and Vessel Kallista from SDN List

The U.S. Office of Foreign Assets Control (OFAC) announced on January 21, 2026, the removal of Greek maritime company Altomare SA and its vessel, Kallista, from the Specially Designated Nationals (SDN) List. The entities were originally designated in November 2025.

UK Sanctions List Consolidation

The UK's Foreign, Commonwealth and Development Office is consolidating its sanctions designations into a single UK Sanctions List (UKSL) effective January 28, 2026. This change aims to reduce non-compliance risk by simplifying identification of sanctioned individuals and entities, without altering the scope of sanctions or business obligations.

CBP Launches Mandatory Forced Labor Portal for Importers

U.S. Customs and Border Protection (CBP) has launched a new, mandatory online Forced Labor Portal for importers to submit requests challenging shipment detentions or exclusions related to forced labor enforcement. This centralized platform replaces previous submission methods and is effective immediately.

OFAC Launches New Online Voluntary Self-Disclosure Portal

The U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) has launched a new online Voluntary Self-Disclosure (VSD) Portal to streamline reporting of potential sanctions violations. The portal aims to improve process visibility and communication for disclosing parties, and OFAC strongly encourages its use.

Treasury Seeks Input on CFIUS Investor Program and Streamlining Reviews

The U.S. Department of the Treasury's Office of Investment Security has published a request for information seeking public comments on streamlining the Committee on Foreign Investment in the United States (CFIUS) review process. Feedback is requested on a proposed Known Investor Program and other streamlining measures, with comments due March 18, 2026.

US Imposes Export Controls on AI Chips to China, Tariffs

The US Department of Commerce's Bureau of Industry and Security (BIS) issued a final rule on January 15, 2026, revising its export licensing review policy for advanced computing items to China. This change shifts from a presumption of denial to a case-by-case review for certain AI chips, while also imposing a 25% fee on such sales. Concurrently, a Section 232 Proclamation targets semiconductor imports with tariffs, offering exceptions for domestic use.

OFAC Issues Venezuela Oil Trade General Licenses

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued General License (GL) 46, authorizing certain transactions related to Venezuelan oil and petroleum products for established U.S. entities. This action aims to expand trade and investment opportunities, though broader sanctions remain in place.

Treasury RFI on CFIUS Known Investor Program

The U.S. Department of the Treasury has issued a Request for Information (RFI) regarding the implementation of the CFIUS Known Investor Program (KIP). The RFI seeks public input on formalizing this voluntary program, which aims to streamline foreign investment reviews. The comment period closes on March 18, 2026.

Supreme Court Invalidates IEEPA Tariffs

The U.S. Supreme Court, in a 6-3 decision in Learning Resources v. Trump, ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. This decision invalidates previously imposed IEEPA tariffs and forecloses their future use as a statutory basis for tariffs.

OFAC Authorizes Expanded Oil Activities in Venezuela

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued new General Licenses (GLs) expanding authorizations for U.S. persons involved in Venezuela's oil and gas sector. These licenses permit a wider range of transactions related to oil extraction, export, and services, aligning with a broader U.S. strategy to relax sanctions.

Responsible Business Insights for 2026

Morrison & Foerster LLP and BSR released Episode 25 of their conversation series, discussing key themes in responsible business from 2025 and offering insights for businesses in 2026. The discussion covers driving measurable impacts amid regulatory complexity and emerging risks and opportunities.

UK Consults on Securitisation Framework Changes

The UK's FCA and PRA have published consultation papers proposing significant changes to the securitisation framework. The proposals aim to replace prescriptive due diligence requirements with a more principles-based approach, potentially impacting how investors assess credit risk, risk retention, and information availability. The consultation period is open for feedback.

Supreme Court Rules Trump Administration Lacked Authority to Impose Tariffs Under IEEPA

The U.S. Supreme Court ruled that the Trump administration did not have the authority under the International Emergency Economic Powers Act (IEEPA) to impose tariffs. This decision impacts importers and exporters who may be entitled to refunds for tariffs previously paid under this authority.

Supreme Court Tariff Decision Impacts Construction Costs

A Supreme Court decision striking down some tariffs has been followed by new 15% tariffs, creating ongoing uncertainty for construction costs and material pricing. The article discusses the impact on the construction industry and legal tools for managing payment disputes.

Supreme Court Invalidates IEEPA Tariffs

The Supreme Court has ruled that the President lacks the constitutional authority under the International Emergency Economic Powers Act (IEEPA) to impose tariffs. The decision, in cases involving Learning Resources, Inc. and V.O.S. Selections, Inc., invalidates previously levied tariffs. Businesses that paid these duties are advised to consult legal counsel regarding potential refund options.

Swiss Sanctions Amended for Sudan

On February 18, 2026, Switzerland's Federal Department of Economic Affairs, Education and Research amended its ordinance on measures against Sudan. Seven individuals have been added to the sanctions list, with the measures taking effect immediately.

SECO Amends Ukraine Sanctions Ordinance

The Swiss State Secretariat for Economic Affairs (SECO) has amended Annex 8 of the Ordinance on Measures Relating to the Situation in Ukraine. The amendment modifies entries for 88 individuals and 92 organizations, with measures taking effect on February 24, 2026.

Swiss Ordinance on Sudan Sanctions Updated

Switzerland has updated its ordinance on Sudan sanctions following amendments by the UN sanctions committee. The SESAM database has been updated to reflect these changes, which enter into force in Switzerland without delay.

Ukraine Sanctions Measures Ordinance Update

On February 26, 2026, the Swiss Federal Department of Economic Affairs (EAER) updated its interpretative aid for sanctions measures related to the situation in Ukraine. The modifications are visible in track changes mode within the updated document.

EU Sanctions Against Russia and Belarus Updated

The European Commission has updated its guidance and FAQs regarding sanctions against Russia and Belarus. These updates address specific measures such as the Nord Stream infrastructure ban, provision of services, and the oil price cap, impacting entities under EU jurisdiction.

EU Sanctions Iran: Individuals, Entities, Asset Freeze, Drone/Missile Tech

The European Commission announced new EU sanctions against Iran, adding 15 individuals and 6 entities subject to asset freezes and travel bans. The measures also extend prohibitions on drone and missile technology exports to Iran, impacting its support for Russia's war in Ukraine.

EU Lifts Most Economic Sanctions on Syria

The EU has lifted most economic sanctions on Syria, including those related to banking, finance, energy, and transport, effective May 28, 2025. This decision supports Syria's transition and economic recovery, though certain restrictions like arms embargoes and individual listings remain. EU operators can now engage in previously restricted activities.

EU Sanctions FAQs on Provision of Services

The European Commission's Directorate-General for Financial Stability, Financial Services and Capital Markets Union has published Frequently Asked Questions (FAQs) regarding the provision of services in the context of sanctions adopted following Russia's military aggression against Ukraine. These FAQs clarify specific sector-related questions for businesses operating within the EU.

FAQs on Nord Stream Infrastructure Ban and Russia Sanctions

The European Commission has published Frequently Asked Questions (FAQs) clarifying restrictions on Nord Stream infrastructure as part of sanctions against Russia. These FAQs address specific queries related to the ban and its implications.

Security Council Removes Syria Officials from ISIL/Al-Qaida Sanctions List

The UN Security Council adopted Resolution 2799 (2025) to remove Syria's transitional President Ahmed al-Sharaa and transitional Minister for Interior Anas Hasan Khattab from the ISIL/Al-Qaida sanctions list. This decision, passed with 14 votes in favour and 1 abstention, is intended to support Syria's economic recovery and political transition.

Security Council Adds Four to Sudan Sanctions List

The UN Security Council Committee established pursuant to resolution 1591 (2005) concerning the Sudan has added four individuals to its sanctions list. These individuals are associated with the Rapid Support Forces and have been designated under Chapter VII of the UN Charter.

Security Council Press Release on ISIL and Al-Qaida Sanctions

The UN Security Council issued a press release on February 27, 2026, concerning sanctions against ISIL (Da'esh) and Al-Qaida. The release details updates and decisions made by the Security Council regarding these sanctions regimes.

EU Accepts Price Undertaking from Chinese Electric Car Producer

The European Commission has accepted a price undertaking from Volkswagen (Anhui) Automotive Company Ltd. regarding its CUPRA Tavascan model. This acceptance exempts the company from countervailing duties, provided it adheres to minimum import prices, volume limits, and EU investment commitments.

EU Requests WTO Panel on China Royalties for High-Tech

The EU has requested the establishment of a WTO panel to rule on China's practice of empowering its courts to fix worldwide licensing conditions for standard essential patents. This action follows unsuccessful consultations and aims to protect EU high-tech companies and their investments in innovation.

EU Imposes Anti-Dumping Duties on ABS from Korea and Taiwan

The European Commission has imposed definitive anti-dumping duties on imports of Acrylonitrile Butadiene Styrene (ABS) from South Korea and Taiwan. Duties range from 5.2% to 7.5% for Korea and 10.9% to 21.7% for Taiwan, following an investigation that found dumped imports were injuring EU manufacturers.

EU Imposes Anti-Dumping Duties on Valine from China

The European Commission has imposed definitive anti-dumping duties ranging from 31.3% to 53.8% on imports of valine from China. The investigation found that dumped imports were causing injury to the EU's valine industry. The EU market for valine is valued at €100 million, with imports from China accounting for approximately €80 million.

EU Steel Safeguard Measure Negotiations

The European Commission has welcomed the start of trilogue negotiations on a new EU steel safeguard measure. The proposed regulation aims to protect the EU steel industry by reducing tariff-free import volumes, doubling out-of-quota duties, and introducing a 'melt & pour' requirement. The measure is intended to be fully in place by July 1, 2026.

CBP Uncovers Over $400 Million in Duty Evasion

U.S. Customs and Border Protection (CBP) announced two major trade enforcement actions under the Enforce and Protect Act (EAPA), uncovering over $400 million in unpaid trade duties. The largest case involved 23 U.S. importers and identified over $250 million in owed revenue from goods transshipped through third countries.

CBP Trade Fraud Probe: Two Arrested, $13.6M Gold Seized

U.S. Customs and Border Protection (CBP) announced the arrest of two individuals and the seizure of $13.6 million in gold as part of a trade fraud investigation. The probe identified an estimated $86.47 million in evaded duties through a scheme involving misrepresenting gold jewelry shipments.

CBP Collects $1 Billion in Duties After Ending De Minimis Loophole

U.S. Customs and Border Protection announced it has collected over $1 billion in duties on low-cost shipments since phasing out the de minimis loophole starting in May 2025. This action strengthens economic and national security by increasing oversight and preventing duty-free entry for goods from China and Hong Kong.

CBP Issues Withhold Release Order on Linglong International for Forced Labor

U.S. Customs and Border Protection (CBP) has issued a Withhold Release Order (WRO) against automobile tires manufactured by Linglong International Europe D.O.O. Zrenjanin in Serbia. This action, effective immediately, will detain all such tires at U.S. ports of entry due to evidence of forced labor in their production.

CBP Modifies Withhold Release Order on FGV Holdings Berhad

U.S. Customs and Border Protection (CBP) has modified a Withhold Release Order (WRO) against FGV Holdings Berhad of Malaysia, allowing its palm oil and palm oil products to enter the U.S. effective January 15, 2026. This modification follows FGV's remediation of forced labor practices in its production processes.

Antidumping Duty Investigation: Unwrought Palladium from Russia

The U.S. Department of Commerce has made a preliminary affirmative determination in the antidumping duty investigation of unwrought palladium from Russia. A weighted-average dumping margin of 132.83% was found for the Russia-wide entity. The final determination is expected around April 28, 2026.

Silicon Metal Antidumping and Countervailing Duty Investigations Final Determinations

The U.S. Department of Commerce announced final affirmative determinations in antidumping and countervailing duty investigations for silicon metal from Angola, Laos, and Thailand. The determinations establish weighted-average dumping margins and subsidy rates, impacting imports of silicon metal from these countries.

Preliminary CVD Investigations of Solar Cells from India, Indonesia, and Laos

The U.S. Department of Commerce announced preliminary affirmative determinations in countervailing duty investigations of solar cells from India, Indonesia, and Laos. Preliminary subsidy rates range from 80.67% to 143.30%. The final determination is scheduled for July 6, 2026.

Hardwood Plywood from China, Indonesia, Vietnam - Preliminary AD Determination

The U.S. Department of Commerce announced preliminary affirmative determinations in antidumping duty investigations of hardwood and decorative plywood from China, Indonesia, and Vietnam. Estimated weighted-average dumping margins range from 3.94% to 187.27% for China, 3.94% to 84.94% for Indonesia, and 196.14% for Vietnam.

Commerce Preliminary Affirmative Determination on Freight Rail Couplers from India

The U.S. Department of Commerce announced a preliminary affirmative determination in the countervailing duty investigation of freight rail couplers from India. Preliminary subsidy rates range from 5.90% to 64.27%, with specific rates assigned to individual exporters. The final determination is scheduled for July 13, 2026.

Commerce Revises Semiconductor Export Policy to China

The Department of Commerce's Bureau of Industry and Security (BIS) has revised its licensing policy for semiconductor exports to China. Applications for specific advanced chips will now be reviewed on a case-by-case basis, provided certain national security and compliance requirements are met.