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…

On August 21, 2026, trade negotiations between the United States and Canada faltered and the parties, for now, have ceased further negotiations. As a result, the United States has implemented 50% tariffs on a broad range of Canadian products under Section 338 of the Tariff Act of 1930. First announced on July 20, 2026 (…

On August 24, 2026, the State Department announced that the United States was formally rescinding Syria’s designation as a State Sponsor of Terrorism following the conclusion of the mandatory 45-day Congressional notification period.  See SmarTrade update of July 9, 2026.  In a press statement, the State Department indicated that this action, along with…

The Bureau of Industry and Security (“BIS”) has published a temporary final rule to restrict the export of black mass and tungsten waste and scrap without a license. The agency defines black mass as shredded lithium-ion battery scrap that contains cathode material, anode material or other “residual battery cell materials.” The BIS will restrict export…

  • Effective July 28, 2026, the Federal Communications Commission’s (FCC) Covered List now includes foreign-produced power inverters and foreign-produced advanced robotic devices. These equipment categories are now prohibited from receiving new FCC equipment authorizations.
  • The term “foreign-produced” refers to any article that does not qualify as a “domestic end product,” as that term is
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