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February 2026 Sanctions Developments

Hughes Hubbard & Reed LLP published an update on February 2026 sanctions developments, highlighting the largest individual civil monetary penalty, a penalty against an academic institution, and designations signaling pressure on Nicaragua. The update provides insights into recent enforcement actions and potential future sanctions targets.

DOJ Names Chicago U.S. Attorney's Office Lead Partner on Trade Fraud Task Force

The Department of Justice has selected the U.S. Attorney's Office for the Northern District of Illinois as a lead prosecutorial partner for its Trade Fraud Task Force. The task force aims to pursue parties evading federal customs laws and smugglers of prohibited goods, utilizing civil and criminal enforcement tools.

Supreme Court Annuls Trump Tariffs, Aiding Art Markets

The Supreme Court of the United States has invalidated Trump Administration tariffs enacted under IEEPA in Learning Resources, Inc. v. Trump. The ruling restores traditional tariff exemptions for art and cultural property and may allow businesses to seek refunds for previously paid tariffs.

IRS Guidance on Foreign Entity Material Assistance for Clean Energy Tax Credits

The IRS issued Notice 2026-15 providing interim guidance on determining material assistance from prohibited foreign entities for clean energy tax credits. The notice outlines rules for the Material Assistance Cost Ratio (MACR) and includes a request for comments.

DOJ Rules on Bulk Sensitive Personal Data Transfers

The Department of Justice has issued new regulations (28 CFR Part 202) implementing Executive Order 14117, restricting the bulk transfer of sensitive personal data, including health and genomic data, to countries of concern. These rules add a layer of compliance beyond HIPAA for organizations handling international data transfers.

Treasury and IRS Simplify Currency Rules for Businesses

The Treasury and IRS have issued Notice 2026-17, announcing proposed regulations to simplify Section 987 currency rules for businesses. Key changes include an equity and basis pool method election and modified rules for recognizing suspended losses, aiming to reduce compliance burdens.

Oil & Gas M&A Activity Influenced by Market Volatility

This article discusses how macroeconomic turbulence and volatile commodity markets influenced oil and gas M&A activity in 2025. It notes a shift towards opportunistic transactions and the increasing role of private equity and activist investors, with AI demand also driving deal activity.

UK Sanctions Update: Global Anti-Corruption and Russia Regimes

The UK Government has updated its sanctions list under the Global Anti-Corruption regime, varying an entry for Kamlesh Mansukhlal Damji Pattni to expand and clarify the grounds for his designation. Additionally, 297 new designations were made under the Russia sanctions regime, including companies, individuals, and vessels.

FAR Council Proposes Rule to Ban Semiconductor Acquisition from China

The FAR Council has proposed a rule to implement a statutory prohibition on the federal acquisition of semiconductors manufactured by China and other countries of concern. The rule, stemming from the FY2023 NDAA, includes a proposed disclosure requirement for non-federal sales and seeks public comments.

AI Patent Eligibility: UK, EPO, and U.S. Divergence

A UK Supreme Court decision has altered the standard for patent eligibility of AI inventions, bringing it closer to EPO practice but maintaining a divergence from U.S. standards. This change impacts how AI-related inventions are assessed for patentability across these jurisdictions.