On September 30, 2026, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued a final rule in the Federal Register that, effective October 1, 2026, revises the International Traffic in Arms Regulations (ITAR) to remove Syria from the list of countries in ITAR § 126.1 for which there is a policy of denial for…

On September 29, 2026, Customs and Border Protection (CBP) issued two Withhold Release Orders (WROs) against palm oil and its derivative products produced by Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP) in Indonesia. Both WROs are the result of a CBP review that MAR and HIP use forced labor to produce palm oil…

On September 30, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented new sanctions on Cuba and formally amended the existing Cuban Assets Control Regulations (CACR). In May 2026, President Donald Trump issued Executive Order (EO) 14404 titled, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United…

On September 27, 2026, the White House announced a reciprocal list of U.S. and Chinese imports recommended for reduced tariff treatment (“30-for-30”) as part of the first major outcome of the U.S.-China Board of Trade. The U.S.-China Board of Trade was first announced on June 2, 2026, to manage bilateral trade and to identify specific…

On September 15, 2026, U.S. Customs and Border Protection (“CBP”) announced in a declaration filed in the U.S. Court of International Trade (“CIT”) that Phase 3 of the Consolidated Administration and Processing of Entries (“CAPE”), the system for administering refunds of tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”), will deploy on October…

On September 8 and 10, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned multiple companies and persons for supporting Iran’s aviation sector and for enabling Iran to destabilize the Middle East. The aviation-related sanctions include covert front companies, foreign intermediaries, and deceptive transshipment routes that Iran relies on to obtain…

On September 2, 2026, U.S. Customs and Border Protection (CBP) published a notice seeking comments by December 1, 2026, on its implementation of several provisions of Executive Order 14411 (“EO 14411”), which mandates the collection of foreign export documentation, the expansion of the requirements for the Customs Trade Partnership Against Terrorism (CTPAT) program, and the…

On September 8, 2026, President Donald Trump issued three proclamations imposing bans on the importation from Canada of certain goods and two other proclamations separately modifying Section 338 tariffs on other Canadian goods imported into the United States. The actions were taken on the same date that Canada implemented its retaliatory tariffs on certain U.S.

On August 20, 2026, less than a month after adding foreign-produced power inverters (an electronic device that converts direct current to alternating current) to its Covered List, the FCC, responding to a determination from the Department of War, has substantially revised the designation. As we discussed in our earlier client alert, the July 28…

On August 24, 2026, President Donald Trump and the Department of the Treasury announced implementation of “Operation Economic Outcast,” marking further efforts remove the Islamic Republic of Iran “and its enablers” from all available financial resources supporting the Iranian regime.

According to a press release, the Treasury Department “has mapped the networks, facilitators, and financial channels…