On July 7, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) revoked Iran-related General License X and issued Iran-related General License X1, for the “Revocation and Wind Down of June 21, 2026 Authorization for the
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The 401(k) Investment Revolution: What the DOL’s Proposed Alternative Assets Rule Means for Fiduciaries
Alternative assets are nothing new for retirement plans. Defined benefit plans have held private equity, real estate, and commodities for decades, and ERISA itself imposes no restriction on the types of assets a plan may hold. What is new is
CIT Issues Order Addressing China Section 301 Cases in Light of Supreme Court Denial of Certiorari
On July 6, 2026, the U.S. Court of International Trade (CIT) issued an Order announcing resolution of all pending but stayed China Section 301 cases because of the June 15, 2026 U.S. Supreme Court decision denying the petition for a
Department of Commerce Initiates Section 232 Investigation of Anthracite Coal Imports
On June 29, 2026, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of anthracite coal. For the purposes
USTR Issues Statement on Status of USMCA Review
On July 1, 2026, the U.S. Trade Representative (USTR) issued a formal statement regarding the joint review of the Agreement between the United States of America, the United Mexican States, and Canada (USMCA). The USMCA entered into force on July
Annual Blocked Property Reports Due to OFAC by September 30
All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2026. This required reporting
OFAC Launches New Portal for Requesting Removal from a Sanctions List
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has launched a Reconsideration Portal for the submission of requests by persons or entities seeking to be removed from an OFAC sanctions list. The portal provides an overview
Trump Accounts Get an ERISA Pass: Practical Implications of the DOL’s New Guidance
DOL’s guidance gives employers room to fund or facilitate Trump Account contributions without creating an ERISA plan.
When Congress created Trump accounts under the One Big Beautiful Bill Act, one of the questions employers quickly focused on is whether providing
CBP Issues Interim Final Rules Indefinitely Suspending the De Minimis Exemption for Imports
On June 24, 2026, Customs and Border Protection (CBP) issued two Interim Final Rules indefinitely suspending the $800 de minimis duty exemption for all modes of importation of goods into the United States and establish a new informal entry and
CBP Confirms June 29, 2026 IEEPA Tariff Refund Process Phase 2 Launch
On June 23, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #69035485, confirming that Phase 2 of the process for refunding duties paid by importers of record under the International Emergency Economic Powers Act