UPDATE: On July 7, 2026, this Iran-related General License X was revoked by OFAC and any activities under this general license must be wound down no later than July 17, 2026. See Thompson Hine Update of July 8, 2026 for
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USTR Launches Section 301 Investigation into Germany’s Underpayment for Pharmaceutical Products
On June 18, 2026, the Office of the U.S. Trade Representative (USTR) announced that it was launching an investigation of Germany under Section 301 of the Trade Act of 1974. The investigation will seek to determine “whether persistent underpayment for
State Regulators Step into the Breach: What Broker-Dealers and Investment Advisors Need to Know
As federal regulators scale back enforcement and staffing, state securities regulators are positioned to fill the gap. In a recent CRC Oyster Consulting webinar, titled “Navigating the Evolution of States Securities Regulations,” Bill Riley, Director at CRC Oyster and
CBP Announces Phases 2 and 3 of the IEEPA Tariff Refund Process
At a show cause hearing before the U.S. Court of International Trade (“CIT”) on June 9, 2026, U.S. Customs and Border Protection (“CBP”) confirmed that it will roll out Phases 2 and 3 of its process for refunding duties paid
U.S. Supreme Court Declines Review of China Section 301 Tariff Challenge
On June 15, 2026, the U.S. Supreme Court denied without comment the plaintiff group’s petition for certiorari in the test case for the China Section 301 tariff refund litigation (HMTX Industries LLC, et al. v. United States et al.). The
President Trump Modifies Section 232 Tariffs on Aluminum, Copper and Steel Imports
On June 1, 2026, President Donald Trump issued a Proclamation amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products. Section 232 of the Trade Expansion Act of 1962
SEC Disgorgement Powers Stay Intact After High Court Fight
Authored by: Karim Sabbidine
The Supreme Court’s unanimous decision in Sripetch v. SEC keeps a major SEC enforcement tool intact: the SEC may seek disgorgement of a securities violator’s ill-gotten gains without first proving that investors suffered out-of-pocket financial losses.
Enforcement Risk & Operational Resilience in Digital Asset Markets
Key Takeaways from Thompson Hines Investment Management Coffee Chat Featuring Nathan Lamb, Brian Lanciault, and Marc Minor.
Digital asset markets are evolving faster than the rules designed to govern them. In our latest Coffee Chat webinar, our team
The New IDR Operations Final Rule: What Employer Group Health Plan Fiduciaries Need to Know
The Departments of Health and Human Services, Labor, and the Treasury, as well as the Office of Personnel Management (Departments) recently finalized the Independent Dispute Resolution (IDR) Operations rule under the No Surprises Act (NSA). Although many self-funded group health
USTR Proposes Tariffs of 10% to 12.5% in 60 Section 301 Forced Labor Investigations
On June 2, 2026, the Office of the U.S. Trade Representative (USTR) issued its determination under Section 301 of the Trade Act of 1974 that certain acts, policies, and practices of 60 economies related to the failure to impose and