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Supreme Court Strikes Down IEEPA Tariffs: Considerations for Importers

On February 20, 2026, in a 6-3 decision, the U.S. Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose broad tariffs. The decision in Learning Resources,...more

CFTC Energy End-User Swaps Pilot Program Reflects Renewed Reassessment of Dodd-Frank Energy Market Constraints

I. Executive Summary - On December 19, 2025, the CFTC’s Market Participants Division (“MPD”) issued Staff No-Action Letter No. 25-51, establishing a three-month pilot program under which certain energy commodity end-user...more

CFTC Opens the Door to Digital Asset Collateral: Regulatory Guidance, No-Action Relief, and Practical Implications

I.  Executive Summary - On December 8, 2025, the staff of the U.S. Commodity Futures Trading Commission (“CFTC”) launched a “digital assets pilot program” (the “Digital Assets Pilot Program”) providing greater certainty to...more

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