On August 7, 2026, the Committee on Foreign Investment in the United States (“CFIUS”) released its annual report to Congress for calendar year 2025. The report covers 347 covered transactions, consisting of 207 written notices and 140 declarations, that were
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Executive Order 14420 Restricts Foreign Equipment in the U.S. Bulk-Power System
Overview
On August 26, 2026, President Trump signed Executive Order 14420 (EO), declaring a national emergency to secure the U.S. bulk-power system and restrict procurement and installation of a broad array of foreign-produced equipment used in the U.S. electric power…
U.S. sanctions update – Syria SST rescission, Operation Economic Outcast, and Iran sanctions developments
Overview
On 24 August 2026, the United States took coordinated action across its Syria and Iran sanctions programmes. Secretary of State Marco Rubio rescinded Syria’s State Sponsor of Terrorism (SST) designation after the 45-day Congressional notification period, and Hay’at Tahrir…
Trump 2.0 tariff tracker
According to President Trump, “Tariff is the most beautiful word in the dictionary.” Throughout his presidential campaign, Trump promised to use tariffs as a central part of his foreign policy strategy. His America First Trade Policy memorandum also directs the…
OFAC Revokes Iran General License X: Only a Short Wind-Down Remains
On July 7, 2026, OFAC revoked Iran General License X (GL X) and replaced it with General License X1 (GL X1). The waiver, which had been due to run until August 21, lasted barely two weeks. GL X1 is not…
EU Steel Regulation published: Key features, application dates, and what to do next
Background
In our publication of 9 April 2026, we analysed the key implications of the proposed EU steel tariff-rate quota (TRQ) regime at a time when interinstitutional (trilogue) negotiations between the European Parliament, the Council, and the Commission were…
DoD proposes expanding FOCI requirements to unclassified contracts
Key takeaways:
- Subject to limited exceptions, the proposed rule would require existing or prospective DoD contractors and subcontractors, at any tier, on contracts exceeding $5 million to disclose foreign ownership, control, and influence (FOCI) and beneficial ownership information – extending
…
UK imposes new Russia sanctions – mirroring of EU position on the maritime transport of LNG and refined petroleum products derived from Russian crude
Key takeaways
- Ban on the import of CN 2710 products derived from Russian crude and refined in third countries – subject to diesel and jet fuel exceptions.
- Prohibition on the maritime transportation of Russian LNG – subject to carve-outs for:
…
UK issues General Trade Licence for import of diesel and jet fuel derived from Russian crude oil
On 19 May 2026, the Department for Business and Trade (DBT) issued General Trade Licence GBSAN0004 (the Licence), authorising the import into the United Kingdom of certain processed oil products derived from Russian crude oil. The Licence, which comes into…
National security meets the farm bill: Key provisions in the Farm, Food, and National Security Act of 2026
On April 30, 2026, the U.S. House of Representatives passed the Farm, Food, and National Security Act of 2026 (H.R. 7567). The legislation extends agricultural programs through 2031 and contains significant national security elements, beyond the headline coverage of food…