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…

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…

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…