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.

SEC Adopts New Insider Reporting Rules for Foreign Private Issuers

The SEC has adopted new rules requiring directors and officers of foreign private issuers (FPIs) to report their beneficial ownership and trades in the issuer's equity securities. These changes, effective March 18, 2026, align FPI reporting with that of domestic issuers and aim to increase market transparency.

SEC Adopts Final Rules for Section 16(a) Reporting by Foreign Issuers

The SEC adopted final rules requiring executive officers and directors of Foreign Private Issuers (FPIs) to report their holdings and transactions in equity securities on Forms 3, 4, and 5. These rules implement the Holding Foreign Insiders Accountable Act and become effective on March 18, 2026.

Venezuela Sanctions Eased, Legal Risk Persists

The US Department of the Treasury's OFAC has eased certain sanctions on Venezuela's oil sector through new general licenses. These licenses authorize specific transactions related to oil, investments, and port operations but come with strict conditions and reporting requirements.

FCA Insurance Sector Regulatory Priorities for 2026

The UK Financial Conduct Authority (FCA) has published its first annual Regulatory Priorities report for the insurance sector, outlining key focus areas for 2026. The report replaces previous portfolio letters and aims to provide clarity on expectations regarding claims handling, consumer understanding, access to insurance, and technology risks.

Patent Application Drafting for US and Europe

This guidance article provides tips for companies on drafting patent applications intended for filing in both the United States and Europe. It highlights key differences in European patent practice, such as stricter requirements for specification support and inventive step, and offers strategies to ensure applications are robust for international examination.

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.

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.

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.