In recent weeks, the Trump administration has taken several actions to implement its policy toward the export of advanced AI commodities to China. These include the Department of Commerce (Commerce) Bureau of Industry’s (BIS) final rule implementing a case-by-case review policy (changed from a presumption of denial policy) of exports…
Global Trade & Sanctions Law
Taiwan Prosecutors Announce First Major Semiconductor Indictments under New National Security Framework
On December 2, 2025, the Taiwan’s High Prosecutor’s Office announced criminal indictments against a subsidiary of Japanese company Tokyo Electron (TEL) and several associated individuals for alleged theft of advanced Taiwan Semiconductor Manufacturing Company (TSMC) process technology. This case marks the first significant corporate indictment under Taiwan’s updated national-security framework,…
Early EU and UK Responses to President Trump’s Announcement of Tariffs Linked to Greenland and Potential Paths Forward
On January 17, President Trump posted on social media that the United States would impose a 10% tariff effective February 1 on eight European countries (France, Germany, UK, Netherlands, Denmark, Norway, Sweden and Finland) until those countries accept his demand that the Danish Realm sell Greenland to the United States. The social media post indicated…
Venezuelan Energy Sector: Recent Developments, Challenges and Opportunities
On January 3, 2026, the United States military conducted an operation in Caracas resulting in the extraction of Venezuelan President Nicolás Maduro and his wife, Cilia Flores. They currently remain in the U.S. facing federal charges based on indictments unsealed in 2020. Two days later, Delcy Rodríguez assumed the role…
Taking a Closer Look at the COINS Act
The Fiscal Year 2026 National Defense Authorization Act, signed into law on December 18, 2025, includes the Comprehensive Outbound Investment National Security Act of 2025 (COINS Act), which establishes a statutory framework to prohibit or require notification of certain outbound investments by U.S. persons in technology sectors deemed sensitive to…
EU Sanctions a Further 41 Vessels Thought to Be Part of Russia’s “Shadow Fleet” and Targets Hybrid Threat Actors
On 18 December 18, 2025, the European Union (EU) added 41 vessels to its sanctions list, targeting Russia’s so-called “shadow fleet,” an opaque network of tankers used to circumvent restrictions on Russian oil exports. The measure forms part of the EU’s broader effort to degrade the Kremlin’s war financing and address…
New EU and UK Export Controls on Emerging Technologies
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…
UK Government Implements New Sanctions Enforcement Recommendations
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…
OFAC Designates Rosneft and Lukoil in Significant Expansion of Sanctions Targeting Russia’s Energy Sector
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.…
Commerce Department Issues “Affiliates Rule,” Extends Entity List Restrictions to Majority-Owned Foreign Entities
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…