On 18 September 2026, President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. The Graham Act puts much of the US sanctions regime against Russia on an express statutory footing and gives the President explicit
The Trade Practitioner
The Trade Practitioner, published by Squire Patton Boggs, focuses on international trade law and policy developments affecting global commerce. It covers topics such as export controls, sanctions regimes, trade compliance, and regulatory changes impacting cross-border transactions. The blog analyzes government measures from various jurisdictions, including the US, China, Russia, and the EU, addressing issues like export licensing, sanctions enforcement, and trade restrictions on strategic materials and technologies. It also discusses geopolitical influences on trade regulations and provides guidance on compliance strategies for businesses operating in complex international environments.
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CBP requests comments on proposed import disclosure requirements
On September 2, 2026, US Customs and Border Protection (CBP) published an Advanced Notice of Proposed Rulemaking (ANPRM) titled “Heightened Import Disclosures for Supply Chain Visibility” seeking comments on new import requirements designed to ensure compliance with customs…
Airbus Operations Limited: A record UK export control settlement
On 30 July 2026 HMRC announced its largest compound settlement on record for export control offences: £6,409,388, paid by Airbus Operations Limited to settle multiple breaches of the UK’s strategic export control regime. The published notice identifies no unlicensed export…
The cancelled buy-back: Federal Law No. 319-FZ and the departing seller’s option: Compensation at the court’s discretion
On 4 August 2026, the President of the Russian Federation signed Federal Law No. 319-FZ, which inserts a new Article 20.1 into the Federal Law on Foreign Investments and allows a Russian court to cancel the buy-back option that many…
Department of Defense suspends CMMC Phase II implementation and seeks industry input on future reforms
The Department of Defense (DoD) Chief Information Officer CIO suspended implementation of the Cybersecurity Maturity Model Certification (CMMC) Phase II on July 13, 2026 and launched a CMMC Review and Reform Task Force to reassess the CMMC program, reduce compliance…
The US extends EAR enhanced favourable treatment to the UAE: Country group reclassification and the advanced-computing carve-out
On 10 July 2026, the Bureau of Industry and Security issued a final rule removing the UAE from Country Groups D:3 and D:4 of the Export Administration Regulations and adding it to Country Group A:5, the group that receives the…
Dueling lists: China’s answer to the Section 1260H expansion and the risk in the pattern – what US stakeholders should know
On June 22, 2026, the People’s Republic of China announced new restrictive measures affecting dozens of US companies, in a move coming just two weeks after the US Department of Defense’s June 8 expansion of its Section 1260H list of…
Court Affirms Crack Down on Foreign Ties in a Proposed US Government Grant Award
A US Small Business Innovation Research (SBIR) award denied due to security threat of co-owners’ foreign ties after national security review.
On June 8, the US Court of Federal Claims (USCOFC) published its opinion affirming the Air Force’s denial of…
The UK’s new consolidated Dual-Use Open General Export Licence
The UK’s Export Control Joint Unit announced on 25 June 2026 (in Notice to Exporters 2026/14) a new consolidated Dual-Use Open General Export Licence merging the existing EU member states Dual-Use OGEL and General Export Authorisation 001 into a single…
OFAC’s General License X and the easing of Iran energy sanctions
The US Treasury Department’s Office of Foreign Assets Control (OFAC) released General License X (GL X) on June 22, 2026, providing temporary easing of restrictions on Iran’s energy sector. These are the first substantive sanctions relief for Iran’s energy sector…