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The Sanctions Puzzle: 10 Key Areas To Watch in 2026 and Beyond

Ongoing efforts to end the war in Ukraine, the construction and demolition of international trade barriers, the reassimilation of Syria into the global economy and other significant geopolitical events continue to dominate...more

BIS Suspends Affiliates Rule for One Year as Part of the US-China Trade Deal

On November 10, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule, announcing a one-year suspension (the Suspension) of its interim final rule, “Expansion of End-User Controls to...more

New BIS Rule Expands Export Restrictions to Entities 50% Owned by Parties on the Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) released a long-anticipated interim final rule (IFR) that will result in the most dramatic expansion of U.S. export control...more

UN Iran Sanctions at Risk of ‘Snapping Back’

Between 2006 and 2015, the UNSC adopted a series of resolutions applying economic, financial and trade-related sanctions to Iran in response to its nuclear programme. Specific jurisdictions, such as the United States and the...more

White House Releases AI Action Plan: Key Legal and Strategic Takeaways for Industry

- What is new: The Trump administration’s AI Action Plan reflects a striking shift in approach, with the federal government driving development, expansion and regulation, focusing on deregulation, permitting, procurement and...more

A New Road to Damascus: Trump Administration Lifts US Sanctions on Syria

Pursuant to a sweeping new executive order (EO) issued on June 30, 2025, the Trump administration has lifted virtually all U.S. sanctions targeting Syria, shuttered the Syria sanctions program administered by the Office of...more

Deadline Fast Approaching for Data Security Program Compliance

The Department of Justice (DOJ) implemented a new regulatory regime (Data Security Program) addressing access to, and transfer of, sensitive personal data to countries and persons of concern, including Russia, China and...more

A New Day for Syria: Trump Administration Relaxes Sanctions

On May 23, 2025, the Trump administration issued a general license (GL) significantly relaxing the patchwork of restrictions on Syria, long a jurisdiction subject to comprehensive sanctions. This regulatory action followed a...more

President Trump’s First 100 Days: Impacts and Projections

The first 100 days of a new administration sets the tone for policy direction and regulatory priorities. The following key takeaways from the Trump administration’s first three months highlight significant trends, shifts and...more

FCC Council on National Security Launches Investigation of Businesses Linked to the Chinese Communist Party

In its first major initiative, on March 21, 2025, the Federal Communications Commission’s (FCC’s) newly formed Council on National Security (Council) launched an investigation into the “ongoing U.S. operations” of businesses...more

The EU’s Response to US Tariffs: From Tariffs to ‘Response Measures’ Under the Anti-Coercion Instrument?

While the recent imposition of US tariffs on aluminium and steel imports and the EU’s subsequent response may evoke a sense of déjà vu from the first Trump administration, the European Union (EU) has more arrows in its quiver...more

‘America First Investment Policy’ Aims To Reshape CFIUS and ‘Reverse CFIUS’

On February 21, 2025, the White House released President Donald Trump’s “America First Investment Policy” memorandum (Investment Policy), which outlined several initiatives to incentivize investment from U.S. allies and...more

National Security: Trump Orders Review of Export, Supply Chain, ‘Reverse CFIUS’ Rules

Several of President Donald Trump’s initial actions — from an executive order instituting a new artificial intelligence (AI) policy framework, to those directing the use of the U.S. military to provide border security, the...more

US Commerce Dept. Rule Expands Licensing Requirements for AI-Related Materials

On January 13, 2025, the Department of Commerce, Bureau of Industry and Security (BIS) released an interim final rule establishing (i) expanded export licensing requirements for the export of advanced computing integrated...more

Russia’s Energy, Financial and Defense Sectors Are the Focus of the Last Round of Sanctions Under Biden

In the days before former President Joe Biden left office, the U.S. announced two new rounds of sanctions against Russia, including expansive new sanctions against Russia’s energy sector. According to its press release, the...more

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

In the US and Europe, Export and Import Controls May Be Expanded

Key Points - - Under the second Trump administration, the U.S. is expected to increase export control restrictions on China, particularly in the semiconductor sector, as well as to expand other China-related national...more

Decoding Tariff Threats: What Importers Can Expect on Day 1 and Beyond

Key Points - - President-elect Trump’s tariff threats have created considerable uncertainty for importers and U.S. businesses relying on imports. - The incoming president could impose 25% tariffs on Canada and Mexico, and...more

President-Elect Trump Announces Intent To Impose Tariffs on Goods Imported From Canada, Mexico and China

On November 25, 2024, President-elect Donald Trump announced that, on his first day in office, he would impose new tariffs on all imports from Canada, Mexico and China. Specifically, in posts on the social media platform...more

The Informed Board - November 2024

At what point has a director served too long? What about term limits? A mandatory retirement age? When do a director’s skills become stale? These issues are addressed in this issue of The Informed Board, as well as why proxy...more

Most AI National Security Regs Likely To Remain in Place Under the Next Administration

With the rapid commercialization of artificial intelligence (AI) technology, the Biden administration has been grappling with its implications, including its potential impact on national security. Several departments have...more

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

US Treasury Creates the ‘Reverse CFIUS’ Program, a (Limited) Great Wall on Outbound Investment

The Department of the Treasury (Treasury) has released a final rule imposing restrictions on U.S. outbound investment in Chinese companies active in developing certain national security technologies (Final Outbound Rule)....more

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