In a much-anticipated decision published on February 20, 2026, the US Supreme Court held that the president lacks specific authority under an emergency statute to impose tariffs on US imports, invalidating all tariffs under...more
In February 2026, the US government issued additional authorizations and clarifying guidance related to previously prohibited transactions in Venezuela. This follows an earlier authorization in January 2026 which licensed the...more
2/20/2026
/ Department of Energy (DOE) ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Exports ,
General Licenses ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Reporting Requirements ,
Sanctions ,
U.S. Treasury ,
Venezuela
After weeks of anticipation, the Office of Foreign Assets Control is authorizing certain transactions involving Venezuelan-origin oil by “established US entities.” Likely not the broad sanctions relief the Venezuelan...more
As 2025 came to a close, shifts in US international trade and investment policy continue to shape planning, compliance, operations, and risk management for global businesses. ...more
While the recent apprehension of Nicolás Maduro signals a potential shift in US-Venezuela relations, foundational sanctions on Venezuela remain intact. Companies should continue to prioritize compliance, as the US Treasury...more
1/9/2026
/ Blocking Sanctions ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Risk Management ,
Trump Administration ,
U.S. Treasury ,
Venezuela
On December 19, 2025, New York Governor Kathy Hochul vetoed SB S8432, a bill to amend the New York LLC Transparency Act (NYLTA), such that the NYLTA applies only to limited liability companies (LLCs) formed under the laws of...more
1/6/2026
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Doing Business ,
Filing Deadlines ,
FinCEN ,
Governor Vetoes ,
Limited Liability Company (LLC) ,
New Legislation ,
New York ,
Regulatory Requirements ,
Reporting Requirements ,
State and Local Government ,
Transparency
The New York LLC Transparency Act, which imposes new disclosure requirements on limited liability companies (LLCs) formed in New York as well as foreign LLCs authorized to do business in New York, goes into effect on January...more
11/6/2025
/ Anti-Corruption ,
Beneficial Owner ,
Corporate Transparency Act ,
Disclosure Requirements ,
Filing Deadlines ,
Financial Crimes ,
FinCEN ,
Foreign-Owned Corporations ,
Limited Liability Company (LLC) ,
New Legislation ,
New York ,
Regulatory Reform ,
Reporting Requirements ,
State and Local Government ,
Transparency
A recent US Court of International Trade ruling—now on appeal to the Federal Circuit—threatens to impose retroactive duties on importers of solar cells and modules from Cambodia, Malaysia, Thailand, and Vietnam that were...more
10/1/2025
/ Anti-Dumping Duty ,
Appeals ,
Countervailing Duties ,
Court of International Trade ,
Customs and Border Protection ,
Imports ,
Infrastructure ,
Photovoltaic ,
Presidential Proclamations ,
Retroactive Application ,
Solar Energy ,
Solar Panels ,
Tariffs ,
U.S. Commerce Department
The Affiliates Rule automatically extends the US Department of Commerce’s Entity List and Military End-User (MEU) List to entities owned 50% or more by entities on either list. On September 29, 2025, the US Department of...more
10/1/2025
/ Affiliates ,
Bureau of Industry and Security (BIS) ,
Due Diligence ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Interim Final Rules (IFR) ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
SDN List ,
U.S. Commerce Department
The California Air Resources Board (CARB) has released a set of FAQs aimed at clarifying implementation of the state’s landmark climate disclosure laws, the Climate Corporate Data Accountability Act (CCDAA, S.B. 253) and the...more
The Committee on Foreign Investment in the United States (CFIUS or the Committee) has released its Annual Report to Congress for calendar year 2024. As with earlier years, the report provides detailed statistics on CFIUS’s...more
9/3/2025
/ America First Trade Policy ,
Annual Reports ,
CFIUS ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Due Diligence ,
Enforcement Actions ,
Foreign Investment ,
National Security ,
Real Estate Transactions ,
Regulatory Oversight ,
Risk Mitigation ,
U.S. Treasury
Faced with ongoing tariff uncertainty, companies in the United States and abroad are grappling with the consequences of existing or forthcoming trade duties for their businesses. Exacerbating this uncertainty, companies’...more
Recent actions by the US Department of Commerce (Commerce) signal growing trade enforcement momentum across critical segments of the clean energy supply chain. Through a combination of new investigations and preliminary...more
Texas joins the patchwork of states enacting legislation restricting foreign investment in real property with the enactment of the 2025 Texas Senate Bill No. 17, highlighting the growing state interest in national security....more
From reciprocal tariffs and retaliatory investigations to paused agreements and looming re-escalations, the global tariff landscape remains as turbulent as ever. Morgan Lewis recently hosted a three-part webinar series...more
The president on June 6, 2025 issued a trio of executive orders (EOs) that aim to solidify the United States’ position in advancing new aviation technologies and accelerate the integration of uncrewed aircraft systems (UAS),...more
The US Court of International Trade and the US District Court for the District of Columbia have invalidated President Donald Trump’s actions imposing tariffs pursuant to the International Emergency Economic Powers Act of...more
The Russia-Ukraine ceasefire and peace negotiations remain uncertain, the European Union and United Kingdom are considering more sanctions against Russia, and the US administration’s next steps are unclear. Anticipating...more
US Customs and Border Protection (CBP) has published guidance regarding the elimination of the de minimis duty exemption on Chinese-origin merchandise and the collection of duties on those once-exempt imports....more
On April 2, 2025, President Trump signed an executive order imposing reciprocal tariffs on most trading partners. The president declared a national emergency posed by large and persistent trade deficits, relying on his...more
The Financial Crimes Enforcement Network issued an interim final rule that removes the requirement for US companies and US persons to report beneficial ownership information to FinCEN under the Corporate Transparency Act....more
Recent US government actions indicate a possible increase in US financial crimes investigations and enforcement targeting drug cartels and transnational criminal organizations in Latin America....more
Corporate Transparency Act (CTA) reporting requirements were recently reinstated, and the Financial Crimes Enforcement Network (FinCEN) established a new filing deadline of March 21, 2025. However, on February 27, 2025,...more
On her first day in office, Attorney General Pam Bondi published several memorandums laying out the reprioritization of US Department of Justice (DOJ) efforts and funding, including the memorandum General Policy Regarding...more
Corporate Transparency Act (CTA) reporting requirements were recently reinstated, and the Financial Crimes Enforcement Network (FinCEN) established a new filing deadline of March 21, 2025. However, on February 27, 2025,...more