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Sanctions & Export Controls Update
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Sanctions & Export Controls Update
BIS Extends Suspension of the “Affiliates Rule” Through January 10, 2027
By Alison J. Stafford Powell (US), Lise S. Test (US)
After much anticipation, on November 5, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS“) released a final rule formally extending the suspension of the “Affiliates Rule”…
Sanctions & Export Controls Update
2026 US Midterm Election Results: How Will Democratic Control of Both Chambers Impact Trade Issues
By Bruce J. Linskens (US), Kerry B. Contini (US), Allison Murphy (US), Rod Hunter (US), Sylwia Lis (US), Chandri Navarro (US), Nat Halvorson (US), Alison J. Stafford Powell (US)
The results from the midterm elections have changed the political landscape of the U.S. House of Representatives and Senate. While some individual races remain to be called, the power shift…
Sanctions & Export Controls Update
UK Introduces New Regulations on Global Human Rights and Humanitarian Law Sanctions
By Ben Smith (UK), Sophie Armstrong (UK), Rianna Shah (UK), Melissa Terzi (UK)
On 15 October 2026, the UK introduced an expanded human rights sanctions regime, via the UK’s new Global Human Rights and International Humanitarian Law Sanctions Regulations 2026 (the “2026 Regulations”).…
Sanctions & Export Controls Update
China Proposes New Sanctions Tool in Response to Trade Secret Theft
On October 26, 2026, China’s Ministry of Commerce (“MOFCOM”) published the draft Special Provisions on the Protection of Chinese Trade Secrets, introducing a new sanctions tool targeting foreign infringement of…
Sanctions & Export Controls Update
Japan: Update on sanction measures against Russia
By Kana Itabashi 板橋 加奈 (Japan), Takumi Hasegawa (Japan), Soichiro Fujiwara (Japan), Taku Takanami (Japan)
On 2 October 2026, the Japanese government announced further sanctions against the Russian Federation under the Foreign Exchange and Foreign Trade Act in line with measures adopted by other major…
Sanctions & Export Controls Update
OFAC Designates the International Criminal Court and Issues Four Related General Licenses
By Alison J. Stafford Powell (US), Lise S. Test (US), Rob O'Brien (US)
On October 9, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) added the entire International Criminal Court (“ICC“) to the Specially Designated Nationals and Blocked…
Sanctions & Export Controls Update
US Moves Syria to Case-by-Case ITAR Licensing Review
By Janet K. Kim (US), Patrick De Lapérouse (US)
On October 1, 2026, the US Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR“) to remove Syria from the list of countries subject…
Sanctions & Export Controls Update
Canada Issues New Guidance on Deemed Ownership Under Its Economic Sanctions Regime
By Julia Webster (Canada), Jacqueline Rotondi (Canada), Jing Xu (Canada)
Global Affairs Canada (GAC) published new guidance clarifying the application of the deemed ownership provisions under Canada’s economic sanctions legislation. The guidance, updated on 13 October 2026, addresses the thresholds…
Sanctions & Export Controls Update
China Proposes Expanded Export Controls on AI, Biopharma and Solar Energy Technologies
By Zhenyu Ruan (China), Frank Pan (China), Tina Li (China), Chris Jiang (China)
Overview and key takeaways On 16 October 2026, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) and the Ministry of Science and Technology of the People’s Republic…
Sanctions & Export Controls Update
What a Closer EU-Canada Relationship Could Mean for Trade
By Julia Webster (Canada), Nat Halvorson (US)
The European Union’s recent proposal to make Canada its first associate member has sparked discussion about what a closer relationship between the two economies could look like and what it…