On September 18, President Trump signed into law the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (the “Graham Act” or the “Act”), which passed both the House and Senate with substantial bipartisan majorities. The law is named in honor of the late Senator Lindsey O. Graham (R-SC)
Continue Reading President Trump Signs Legislation Authorizing Russia-Related Tariffs and Additional SanctionsInternational Trade
UK Adopts New Iran Sanctions and Announces Measures Relating to Israeli Settlements
This alert summarizes recent developments in relation to the UK sanctions.
First, the UK introduced a substantial expansion of its Iran sanctions regime, including new trade, financial and transport restrictions. These measures are scheduled to enter into force on 29 September 2026.
Second, the UK announced a new package of…
Continue Reading UK Adopts New Iran Sanctions and Announces Measures Relating to Israeli SettlementsSection 338 Tariffs on Canada Take Effect as Canada Announces Retaliatory Response
Executive Summary
On August 22, 2026, U.S. tariffs of 50 percent imposed under Section 338 of the Tariff Act of 1930 (19 U.S.C. § 1338) took effect against a range of imports from Canada, including chemicals, prepared food and beverages, plastics, metal items, machinery, cosmetics, wood and paper products, industrial…
Continue Reading Section 338 Tariffs on Canada Take Effect as Canada Announces Retaliatory ResponseDHS Expands UFLPA Entity List Amid Intensifying Enforcement Landscape
Executive Summary
Last week, the Forced Labor Enforcement Task Force (“FLETF”) added 43 entities to the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List and made technical name updates to two existing entities.[1] This is the first update to the Entity List since President Trump took office and is the…
Continue Reading DHS Expands UFLPA Entity List Amid Intensifying Enforcement LandscapeNew Executive Order Calls for Significant Customs Law Changes, Directs CBP to Crack Down on Foreign Importers and Enhance Penalties
On June 3, 2026, the President issued an Executive Order (“EO”) entitled “Strengthening Customs Enforcement,” which is likely to have far-reaching consequences for companies that act as importers in the United States. The EO is expected to have a disproportionate impact on importers that are based outside the United States…
Continue Reading New Executive Order Calls for Significant Customs Law Changes, Directs CBP to Crack Down on Foreign Importers and Enhance PenaltiesProposed Rule Issued to Implement Expanded FOCI Disclosure and Risk Mitigation Requirements for Defense Contractors
On May 7, 2026, the Department of Defense (“DoD”) issued a proposed rule that would fundamentally expand the scope of foreign ownership, control, or influence (“FOCI”) disclosure and risk mitigation requirements for a significant number of companies that serve the national defense. The proposed rule, together with DoD Instruction (“DoDI”)…
Continue Reading Proposed Rule Issued to Implement Expanded FOCI Disclosure and Risk Mitigation Requirements for Defense ContractorsEU Adopts Additional Sanctions Against Russia and Belarus & UK Adopts Sanctions End-Use Controls
On 23 April 2026, the Council of the European Union adopted a new package of economic sanctions against Russia, marking the twentieth sanctions package introduced since the start of Russia’s full scale invasion of Ukraine.
Click here to read the full alert on cov.com.
Continue Reading EU Adopts Additional Sanctions Against Russia and Belarus & UK Adopts Sanctions End-Use ControlsCurrent and Forthcoming Section 232 Actions by the Trump Administration
Section 232 of the Trade Expansion Act of 1962 (“Section 232”) authorizes the President to “adjust” imports—including through application of tariffs, quotas, tariff rate quotas, and license fees—where the Department of Commerce (“Commerce”) determines imports threaten to impair U.S. national security. Since February 2025, President Trump has invoked Section 232…
Continue Reading Current and Forthcoming Section 232 Actions by the Trump AdministrationSection 363 Sales Provide Strategic Opportunities to Acquire Assets in the U.S.
In an increasingly global economy, sophisticated foreign companies are seeking strategic and cost‑effective ways to establish or expand their presence in the United States, enter new product lines, or acquire strategic assets at attractive valuations. One frequently overlooked pathway is acquiring assets through a U.S. bankruptcy case.
Click here to…
Continue Reading Section 363 Sales Provide Strategic Opportunities to Acquire Assets in the U.S.European Commission Publishes the Proposed Industrial Accelerator Act
On 4 March 2026, the European Commission (the “Commission”) published its proposal for a regulation establishing a framework for the acceleration of its industrial capacity and decarbonisation in strategic sectors (“Proposed Industrial Accelerator Act”, or “Proposed IAA”), accompanied by four annexes. The initiative is intended to strengthen the EU’s industrial base while accelerating decarbonisation in key manufacturing sectors considered strategically important (i.e., energy-intensive industries, net-zero technology manufacturing, and the automotive manufacturing ecosystem). These sectors currently represent less than 15% of EU GDP, and the Commission’s objective is to increase this share to 20% by 2035. The Proposed IAA was delayed three times before publication and underwent significant rewriting, which reflects both internal debates within the Commission and diverging reactions from Member States. It also reflects the challenges posed by the broader geopolitical context, as the Commission aims to address economic security concerns through industrial policies whilst navigating international trade relationships and commitments.
The Proposed IAA introduces a regulatory framework combining three policy tools. First, it establishes demand-side measures designed to create “lead markets” for low-carbon and “Made in EU” industrial products through public procurement and certain public support schemes. Second, it introduces conditions for allowing certain foreign direct and indirect investments (“FDI”) in strategic sectors, aimed at maximising the industrial benefits of such investments within the EU. Third, it includes measures to streamline permitting procedures and facilitate industrial clustering, with the objective of accelerating the deployment of manufacturing projects.
This blog summarises the key aspects of each tool and their potential implications for companies active in the covered industries or looking to invest in the covered industries.
Continue Reading European Commission Publishes the Proposed Industrial Accelerator Act