News & Analysis as of

International Emergency Economic Powers Act (IEEPA)

Mayer Brown

United States Targets Dealings of Foreign Companies and Financial Institutions with Cuba

Mayer Brown on

On May 1, 2026, President Donald Trump signed Executive Order 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy” (the “EO 14404” or...more

McDermott Will & Schulte

The tax treatment of tariff refunds for inventory

Following the Supreme Court of the United States’ decision invalidating most tariffs imposed under the International Emergency Economic Powers Act of 1977, many companies expect to receive tariff refunds with respect to...more

Blake, Cassels & Graydon LLP

U.S.–Canada Tariffs: Timeline of Key Dates and Documents (May 2026)

Detailed Timeline - (Most recent to oldest) - July 1, 2026 - CUSMA Review - Expected date of the Free Trade Commission’s review of the Canada-United States-Mexico Agreement (CUSMA) pursuant to Article 34.7(2) of...more

Wilson Sonsini Goodrich & Rosati

North Korea-Linked Schemes to Obtain Employment in U.S. Tech Companies: What You Need to Know and How to Respond

During the past few years, operatives associated with the Democratic People’s Republic of Korea (North Korea or the DPRK) have reportedly infiltrated hundreds of U.S. companies by fraudulently posing as legitimate remote IT...more

Braumiller Law Group, PLLC

IEEPA Refunds Update with Adrienne Braumiller

Braumiller Law Group Managing Partner Adrienne Braumiller provides an update on the IEEPA refund process....more

Akerman LLP

New Cuba Executive Order Adds Targeted Sanctions Authority While Preserving CACR Licenses

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On May 1, 2026, the President issued a new Executive Order (EO 14404 ) adding targeted sanctions authorities related to Cuba. EO 14404 is issued under several authorities, including the International Emergency Economic Powers...more

Bodman

Non-Resident Importers May Need to Take Immediate Action to Avoid Delays in Receiving Tariff Refund Payments

Bodman on

An emerging issue affecting tariff refund claims under the IEEPA Phase 1 Declaration process submitted through the CAPE system may require immediate action by non-resident importers to avoid delayed or rejected refund...more

Opportune LLP

IEA 2026 Global Energy Review: Strategic Implications for…

Opportune LLP on

Global energy demand is no longer moving in unison, as structural slowing in advanced economies clashes with resilient, feedstock-driven growth in the U.S. and emerging markets. Global energy demand grew by approximately...more

King & Spalding

New Cuba Sanctions Present Increased Sanctions Risk For Foreign Financial Institutions and Foreign Persons Operating in Targeted...

King & Spalding on

On May 1, 2026, President Trump issued an Executive Order (the “Executive Order”) under the International Emergency Economic Powers Act (“IEEPA”) authorizing new, targeted sanctions related to Cuba, including blocking...more

Paul Hastings LLP

New US Sanctions Against Cuba Expand Sanctions Risks for Global Multinationals

Paul Hastings LLP on

In a move that signals a fundamental change in the U.S. regulatory and enforcement risk calculus for multinational companies and financial institutions that operate in or facilitate transactions with the Cuban economy, the...more

Akin Gump Strauss Hauer & Feld LLP

Cuba Executive Order Exposes Non-U.S. Companies and Financial Institutions to Significant New Sanctions Risk

The May 1 Executive Order (E.O.) significantly expands the authority of the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), and the U.S. Department of State to sanction foreign companies and...more

BakerHostetler

Consumer Tariff‑Refund Class Actions Develop Following Supreme Court Ruling and Launch of Federal Refund Portal

BakerHostetler on

Recent weeks have seen a rise in consumer class‑action lawsuits seeking refunds or restitution tied to tariffs imposed on importers under the International Emergency Economic Powers Act (IEEPA) and later invalidated by the...more

The Volkov Law Group

Episode 412: New Cuba Sanctioons Expansion and Compliance

The Volkov Law Group on

In this episode, Michael Volkov analyzes the May 1 executive order signed by Donald Trump expanding U.S. sanctions targeting Cuba. The discussion highlights the order’s broad scope, including new authorities to sanction...more

Nossaman LLP

California Water Views – 2026 Outlook

Nossaman LLP on

Welcome to Nossaman’s California Water Views – 2026 Outlook. Water is simple. Water issues are complex. To provide more clarity, we asked our attorneys who are committed to the water sector to identify the pivotal issues...more

Foley & Lardner LLP

Foley Automotive Update - May 2026

Foley & Lardner LLP on

Foley & Lardner Partners Vanessa Miller and Nicholas Ellis, as well as Associate William Kalas, assessed the ramifications of the Michigan Supreme Court’s decision to dismiss the appeal of FCA US LLC v. Kamax Inc., “a case of...more

Husch Blackwell LLP

Week in Review (April 27)

Husch Blackwell LLP on

IEEPA Refund Updates: CBP Targets May 11 for First IEEPA Duty Refunds- On April 28, 2026, Judge Richard K. Eaton of the U.S. Court of International Trade issued an Order in Euro-Notions Florida, Inc. v. United States, et...more

ArentFox Schiff

Enterprise Risk: Why US Tariffs Are Now a Board-Level Governance Issue

ArentFox Schiff on

Rapid changes to US tariff policy have transformed what were once transactional import decisions into issues with enterprise-wide implications. The reliance on tariffs has had bipartisan support across Administrations, and...more

Mayer Brown

Preparing for IEEPA Tariff Reimbursement Demands a Proactive Approach

Mayer Brown on

The first phase of US Customs & Border Protection’s (“CBP”) Consolidated Administration and Processing of Entries (“CAPE”) refund system went live on April 20, 2026. This initial phase is limited to certain unliquidated...more

Gray Reed

UPDATE: A $166 Billion Refund – What Companies Need to Know About the Refund Process After the U.S. Supreme Court’s IEEPA Decision

Gray Reed on

Fallout from Learning Resources, Inc. v. Trump. Companies now have a clearer path to seek refunds following the U.S. Supreme Court’s recent decision invalidating more than $170 billion in tariffs assessed under the...more

Womble Bond Dickinson

What’s that Sound? FinCEN Proposes Long-Awaited Regulations Implementing its Whistleblower Bounty Program

Womble Bond Dickinson on

On April 1, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) titled “Whistleblower Incentives and Protections,” proposing regulations...more

Mayer Brown

FinCEN’s Proposed Whistleblower Program: A Sea Change in AML and Sanctions Enforcement

Mayer Brown on

On March 30, 2026, the Financial Crimes Enforcement Network (FinCEN) published a Notice of Proposed Rulemaking (NPRM) to operationalize its whistleblower program by creating substantial financial incentives for individuals to...more

Porter Hedges LLP

Tariffs and Construction: What Duties Still Apply, and are CAPE Refunds a Silver Lining?

Porter Hedges LLP on

For construction owners, developers, contractors, and suppliers, the past fifteen months of the International Emergency Economic Powers Act ("IEEPA") tariffs have landed hard on the materials portion of the business, creating...more

Buchalter

U.S. Customs and Border Protection Commences Processing Refund Applications for IEEPA Tariffs Starting April 20, 2026

Buchalter on

On Monday April 20, 2026, the U.S. Customs and Border Protection commences processing refund applications for IEEPA tariffs (for Reciprocal Tariffs or Fentanyl Tariffs) paid by importers but ruled unlawful by the U.S. Supreme...more

White and Williams LLP

IEEPA Tariff Refunds: CBP Launches CAPE Process

White and Williams LLP on

On April 20, 2026, U.S. Customs and Border Protection (CBP) launched the first phase of the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment (ACE) portal to administer...more

J.S. Held

IEEPA Tariff Refunds: Clarity on Eligibility, Complexity in Recovery, and a New Wave of Disputes

J.S. Held on

The US Supreme Court recently determined that tariffs imposed under the International  Emergency Economic Powers Act (IEEPA) were unlawful, triggering a refund process that could potentially total more than $150 billion. The...more

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