As Russian Energy Week concluded last week, Western governments strike to the heart of Russia’s energy sector with sanctions packages to cut of revenue that funds Russia’s continued war against Ukraine. Three significant packages were announced in October 2025: the U.S.’s sanctions targeting the Russian energy sector, the UK’s latest sanctions against the Russian oil industry, and the EU’s 19ᵗʰ package of sanctions.Continue Reading Striking Russian Oil and The Ripple Effects

On October 17, 2025, the Trump Administration released a significant proclamation imposing new Section 232 duties on medium- and heavy-duty vehicles (MHDVs) (such as trucks); MHDV parts; and buses. These changes further expand tariff coverage over sectors critical to U.S. industrial capacity and national security, and bring a few new complexities to both importers and domestic manufacturers.Continue Reading Not Only Tariffs on Trucks: Trump Administration’s Proclamation Amends the Tariff Landscape on Automobiles, Steel, and Aluminum

On September 29, the Department of Commerce, Bureau of Industry and Security (BIS) published the public inspection copy of an Interim Final Rule (IFR) amending the Export Administration Regulations (EAR) to extend Entity List, Military End-User (MEU) List, and SDN-related EAR controls under § 744.8 to foreign affiliates[1] owned 50% percent or more (directly or indirectly) by listed entities. The rule will become effective on the date of publication, which is September 29.Continue Reading Not Your Usual Monday: BIS Adopts 50 Percent Rule for Entity List, MEU List & Related EAR Controls

The pace of U.S. regulatory changes regarding Syria continues to increase. Building on our previous posts (“Syria-ous Changes for Middle East Business?” and “Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means”), we describe below the recent developments that have resulted in significant easing of export controls.Continue Reading Keeping an EAR Out for Syria: BIS Reduces Export Controls

Key Takeaways

  • On July 24, 2025, the European Commission opened infringement procedures against 18 Member States for failing to fully transpose Directive (EU) 2024/1226 by the May 20, 2025 deadline.
  • The Directive harmonizes criminal offences and penalties for violations of EU sanctions, including asset freeze breaches, arms embargo violations, and circumvention schemes.
  • Penalties include prison sentences of up to 5 years for individuals and fines up to 5% of worldwide turnover or EUR 40 million for companies, plus additional restraining measures.

Continue Reading “Lost in Transposition” – Commission Targets 18 Member States Over Sanctions Enforcement Gaps

The United States has taken a historic step by terminating the Syria Sanctions Program, marking the most significant shift in U.S. foreign policy towards Syria since the fall of the Assad regime. In our earlier post, we outlined the initial steps taken by the U.S., EU, and UK to relax longstanding sanctions on Syria. Since then, the U.S. has introduced additional measures aimed at promoting commercial re-engagement, although several restrictions remain in place. Companies interested in doing business with Syria must stay current on evolving export control, sanctions, and compliance requirements.Continue Reading Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means

In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria

On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT) unanimously struck down the extensive tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA). The CIT held that the imposition of the tariffs exceeded the authority granted to the President by Congress under IEEPA. The Court issued a permanent injunction blocking the administration from enforcing the IEEPA tariffs, and ordered the administration to issue the necessary administrative orders within 10 days to end them. In response, the government appealed the case to the U.S. Court of Appeals for the Federal Circuit.Continue Reading Federal Court Strikes Down IEEPA Tariffs

Recently, the Texas House of Representatives introduced HB 5007, along with its companion bill SB 2117. The legislation—“Relating to the establishment of the Texas Committee on Foreign Investment to review certain transactions involving certain foreign entities; creating a civil penalty”—is currently under committee review. If enacted, the Lone Star State would become the first state to establish its own interagency committee to screen foreign investments, modeled in part on the federal Committee on Foreign Investment in the United States (CFIUS).Continue Reading Big State, Big Scrutiny: Texas Steps into the Foreign Investment Review Arena