The EU has adopted new export controls on a range of emerging technologies (including quantum technologies, semiconductor manufacturing equipment, advanced computing, advanced materials and coatings for high temperature applications, additive manufacturing and certain life sciences tools), under the new “500-series” of EU-only controls. The update to the EU’s Dual-Use Export…
In May 2025, the UK government published the Cross-Government Review of Sanctions Implementation and Enforcement policy paper (“Cross-Government Review”). Led by the Foreign, Commonwealth and Development Office (FCDO), and supported by key sanctions departments and agencies across the UK government, the Cross-Government Review identifies steps to improve and facilitate compliance…
On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions for Russia’s energy sector, designating Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil) under Executive Order (EO) 14024 as Specially Designated Nationals (SDNs), along with dozens of directly named subsidiaries.…
On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a long-anticipated interim final rule (IFR) amending the Export Administration Regulations (EAR) to extend Entity List and Military End User (MEU) List restrictions to majority-owned affiliates. Known as the “Affiliates Rule,” the IFR establishes…
Last month, the U.S. Department of Justice (DOJ) announced the launch of a “cross-agency” Trade Fraud Task Force “to bring robust enforcement against importers and other parties who seek to defraud the United States.” According to DOJ, the Task Force will “augment the existing coordination mechanisms” within DOJ and leverage…
The Committee on Foreign Investment in the United States (CFIUS) recently published its 2024 Annual Report. Filing volume for both declarations and notices remains lower compared to their peaks in 2021 and 2022, respectively. While CFIUS continues to clear the vast majority of transactions it reviews without mitigation, compliance site…
In the past several weeks the Trump administration has taken multiple actions on tariffs, based on several different legal authorities. The landscape is shifting almost continuously, and more changes are likely coming. A number of the tariff actions are linked to the results of bilateral negotiations that involve commitments to…
Under the Trump administration, the U.S. has adopted sweeping tariffs on nearly every trading partner, with a promise of more on a range of strategic sectors including industrial metals and critical minerals, pharmaceuticals, semiconductors, and automobiles. These actions have provoked countermeasures from China and others. While these developments are rightly…
On August 6, 2025, President Trump published a new Executive Order imposing secondary tariffs on India in response to its continued importation of Russian-origin crude oil. This marks both an escalation in U.S. trade negotiations with India and the first major Russia-related enforcement action of his second term. It also…
On June 26, 2025, the UK government brought into force the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 (“2025 Amendment”), marking a notable development in the UK government’s sanctions enforcement strategy. The 2025 Amendment expands the statutory protections given to whistleblowers to cover the reporting of breaches of UK…