Trade Controls

After passing the House the preceding week, the National Defense Authorization Act for Fiscal Year 2026 (FY 2026 NDAA) passed the Senate on December 17 by a vote of 77-20 and was signed into law by President Trump the following day. As is frequently the case, this annual “must pass”

Continue Reading New Sanctions Authorities in the FY 2026 NDAA

On 3 December 2025, the European Commission unveiled the next phase of its economic security agenda.  Building on the 2023 Economic Security Strategy and the 2024 European Economic Security Package (see our prior blog), the new communication sets out a more assertive and coordinated approach to managing risks linked to trade, investment, technology and critical infrastructure.

The EU intends to remain open to trade and investment, but that openness will increasingly be conditioned on economic security objectives.  For businesses and investors, this translates into more scrutiny, more due diligence, and a more integrated interplay between the EU and Member States.Continue Reading Strengthening EU Economic Security – More of the Same or a New Approach?

On August 29, 2025 the Department of Justice (“DOJ”) announced the launch of a cross-agency Trade Fraud Task Force (“TFTF”), a partnership between DOJ’s Civil and Criminal Divisions, as well as the Department of Homeland Security (“DHS”). On the same day, the U.S. Court of Appeals for the Federal Circuit

Continue Reading Creation of the Cross-Agency Trade Fraud Task Force and the Future of Tariffs Enforcement

Now that the Trump Administration has cleared the six-month mark, its approach to white collar enforcement is starting to come into focus through multiple policy announcements and an emerging track record. After a flurry of policy announcements from Attorney General Pam Bondi in the early weeks of the new administration

Continue Reading DOJ White Collar Enforcement Six Months into the Trump Administration