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
OFAC Targets Iran’s Aviation and Rail Sectors for Additional Sanctions
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
DDTC Issues Proposed Rule to Remove Certain Items from the U.S. Munitions List
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
DDTC Removes Syria from ITAR Section 126.1 Policy of Denial
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
CBP Issues Withhold Release Orders on Two Indonesian Palm Oil Producers
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
OFAC Issues New Cuba Sanctions Regulations and Amends Other Existing Sanctions
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
OFAC Increases the Scope of Sanctions on Iran
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
President Trump Imposes Import Ban on Certain Canadian Products and Increases Tariffs on Other Products
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.
FCC Substantially Revises Covered List Restrictions on Foreign-Produced Power Inverters
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
Department of the Treasury Announces Further Sanctions on Iran
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