On October 26, 2026, the Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPR”) that would implement Subtitle C of the Comprehensive Outbound Investment National Security Act (“COINS Act”) to expand the coverage of the existing Outbound Investment Security Program (“OISP”) (see Update of October 8, 2026).

The OISP came…

On October 22, 2026, President Donald Trump issued a Proclamation announcing that the investigation into the effects of imports of wind turbines and their parts and components on the national security of the United States under Section 232 of the Trade Expansion Act of 1962 has concluded.  The investigation was initiated in August 2025 by…

On October 20, 2026, Gellert Global Group Corp. (Gellert) filed a complaint in in the U.S. Court of International Trade (CIT) challenging the 50% ad valorem tariffs placed on Canadian products by President Donald Trump under Section 338 of the Tariff Act of 1930, 19 U.S.C. § 1338. The complaint seeks class action status for…

On October 14, 2026, U.S. Customs and Border Protection (CBP) announced the extension of the compliance date for new informal entry procedures for international mail from October 22, 2026, to January 20, 2027. In a press release, CBP states that the 90-day extension “provides importers, brokers, and logistics providers additional time to update their…

On October 8, 2026, the U.S. Court of International Trade (CIT) granted a broad class certification for importers subject to the International Emergency Economic Powers Act (IEEPA) tariff regime, which the Supreme Court of the United States (SCOTUS) invalidated on February 20 (see Update of February 20, 2026).

CIT Senior Judge Richard K.

On October 7, 2026, U.S. Department of the Treasury (“Treasury”) announced that it imposed its first civil penalty of $200,000 against U.S. company Amidi LLC (“Amidi”) under the Outbound Investment Security Program (“OISP”). The OISP came into effect on January 2, 2025, requiring that U.S. persons notify Treasury of certain types of investments, whether made…

On October 1, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new sectoral sanctions determinations targeting Iran’s automotive and rail sectors.  These determinations authorize OFAC to sanction any entity or individual operating in these sectors. OFAC stated that Iran’s automotive sector is the country’s largest economic sector outside of oil and gas…

On September 30, 2026, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule in the Federal Register that would remove certain items from the U.S. Munitions List (USML). This proposed rule is in furtherance of President Donald Trump’s April 9, 2025, Executive Order 14268, “Reforming Foreign Defense Sales to…

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…

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…