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 “Chinese Military Companies” list. These latest measures clear examples of Washington and Beijing increasingly reaching for the same instrument: targeted, list-based tools, including procurement bans, export-control designations, sanctions listings and investment restrictions.

We recently published an update on these developments. Read the full insight here.

Court Affirms Crack Down on Foreign Ties in a Proposed US Government Grant Award

By Trade Practitioner on June 30, 2026 Posted in Foreign Investment Reviews, Government Contracts, US Regulation

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 a SBIR award due to the applicant’s ties to a foreign country of concern.[1]

The UK’s new consolidated Dual-Use Open General Export Licence

By Trade Practitioner on June 29, 2026 Posted in Customs, European Regulations, Export Controls & Sanctions, Technology Transfer, Trade Policy & Market Access

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 open licence and extending open-licence coverage to five new destinations. For the trade practitioner, the significance of the measure lies not in any loosening of the underlying controls — the control lists, the SPIRE registration requirement, and the open-licence conditions are all unchanged — but in the repackaging of permissions and the widening of the trusted-destination network on the strength of the UK’s own risk assessment rather than that of a multilateral regime. Two features repay close attention: the divergence between the new destinations and membership of the four export-control regimes, which keeps end-use, end-user, and diversion-risk screening firmly in play; and a parallel measure requiring the licence reference to be entered on the Customs Declaration Service for all tangible exports, bringing open-licence exports within HMRC’s enforcement remit.

We recently published an update examining the consolidation, the expanded destinations, and the operational obligations that, for most exporters, are the salient features.

Read the full insight here.

OFAC’s General License X and the easing of Iran energy sanctions

By Trade Practitioner on June 29, 2026 Posted in Export Controls & Sanctions, US Regulation

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 since 2016, when OFAC implemented the US-Iran Joint Comprehensive Plan of Action (JCPOA).

We recently published an update on these developments. Read the full insight here.

The UK’s 16 June 2026 Russia sanctions package and the OFSI interdiction general licence

By Trade Practitioner on June 18, 2026 Posted in Enforcement Actions, European Regulations, Export Controls & Sanctions, Technology Transfer, Trade Policy & Market Access

On 16 June 2026, as the prime minister attended the G7, the UK announced 70 new sanctions under its Russia regime, comprising 43 designated persons and entities and 27 specified ships, directed at Russia’s shadow fleet, a Main Directorate of the General Staff of the Armed Forces of the Russian Federation (GRU)-linked procurement network centred on the front company Neptune and illicit-finance rails. For the trade practitioner, the package’s significance lies less in the list than in the shift it confirms: paired with May 2026 ship-sanctions amendments and an Office of Financial Sanctions Implementation (OFSI) interdiction general licence in force from 12 June, it moves the UK from passive listing to an active, repeatable interdiction architecture and demonstrated days earlier by the boarding of the tanker SMYRTOS. This alert explains the distinction between designated persons and specified ships, the scope and limits of the general licence, the SMYRTOS operation and the commercial-provenance frontier it opens, as well as the immediate compliance steps for maritime, finance and trade businesses.

We recently published an update on these developments. Read the full insight here.

The Council of the EU’s June 2026 restrictive measures against Russia

By Trade Practitioner on June 16, 2026 Posted in Enforcement Actions, European Regulations, Export Controls & Sanctions, Trade Policy & Market Access, Trade Remedy & Defense

On 15 June 2026, the Council of the EU adopted a further set of restrictive measures in response to what it terms Russia’s war of aggression against Ukraine, adding 34 individuals and 47 entities to the EU’s asset-freeze and travel-ban lists across three sanctions regimes, and renewing the measures responding to the annexation of Crimea and the city of Sevastopol. For the trade practitioner, the significance of the action lies less in its scale than in its composition: rather than amending the sectoral prohibitions, it widens the designation lists across four priority components, the military-industrial complex, the shadow-fleet ecosystem, hybrid activities and human rights violations, and it reaches enablers established well beyond Russia, most notably the ship-management and bunkering companies that keep the shadow fleet at sea. This alert examines the new listings component by component and draws out the cross-border reach and the screening obligations that, for most operators, are the salient features.

We recently published an update on the ruling. Read the full insight here.

The “real risk” threshold for sanctions exposure: The Court of Appeal in The Catalan Sea

By Trade Practitioner on June 10, 2026 Posted in Anticorruption, Enforcement Actions, European Regulations, Export Controls & Sanctions, Trade Policy & Market Access

On 22 May 2026, the UK’s Court of Appeal handed down its judgment in Tonzip Maritime (Singapore) Pte Ltd v. 2 Rivers Pte Ltd (The Catalan Sea) [2026] EWCA Civ 641, allowing the shipowners’ appeal and confirming that a charterparty clause permitting refusal of a voyage order which would “expose” the owners to sanctions is engaged by a reasonable judgment that there is a real risk of sanctions, rather than by proof that a breach is more likely than not. For the trade practitioner, the decision’s significance lies in two dimensions: the threshold it fixes for the “exposure to sanctions” clauses on which owners, charterers and their insurers routinely rely; and the court’s treatment of the ownership-and-control question beneath the refusal, namely the risk that a sanctioned person’s transfer of their interest to a family member shortly after designation is cosmetic rather than genuine. This alert examines the Court of Appeal’s construction of the clause, the line of authority on “exposure” and “real risk” from which it draws, and the practical questions the decision poses for owners and charterers assessing contestable cargo ownership against the EU and UK control rules, including the recognized red flags of circumvention.

We recently published an update on the ruling. Read the full insight here.

AUKUS announces its first Pillar II signature project: Uncrewed undersea capabilities

By Trade Practitioner on June 5, 2026 Posted in Export Controls & Sanctions, Government Contracts, Trade Policy & Market Access, Trade Remedy & Defense

On 30 May 2026, at the Shangri-La Dialogue in Singapore, the US, the UK and Australia announced the first signature project under Pillar II of the AUKUS partnership: the joint development of payloads and enabling systems for uncrewed undersea vehicles, with first capabilities expected in service from 2027. For the trade practitioner, the announcement’s significance lies in the regulatory change that could be on the horizon: an undertaking to widen the trilateral licence-free environment for defence trade by narrowing the list of excluded technologies. This alert examines the signature project, the licence-free regime as it currently stands, and the practical questions for defence suppliers across the three jurisdictions.

Read the full insight.

Sanctions, National Security, and Countermeasures in Convergence: The European Operator Between Competing Obligations

By Trade Practitioner on May 29, 2026 Posted in China, EU, European Regulations, Export Controls & Sanctions

Across April and May 2026 a sequence of regulatory developments redrew the operating environment for European companies engaging with Chinese counterparties. The State Council of the People’s Republic of China promulgated two consolidated countermeasures instruments: Order No. 834 of 31 March 2026 (the Supply Chain Provisions, 供应链产业链安全管理条例) and Decree No. 835 of 13 April 2026 (the Counter-Extraterritoriality Regulations, 中华人民共和国反外国不当域外管辖条例); within weeks, the Ministry of Commerce of the People’s Republic of China (MOFCOM) and the Ministry of Justice of the People’s Republic of China (MOJ) each deployed the architecture for the first time. In parallel, the European Union adopted the 20th sanctions package against Russia, the Commission proposed a bespoke exemption to one of its third-country listings, and the Netherlands transmitted the International Sanctions Measures Act (Wet internationale sanctiemaatregelen, the Dutch Sanctions Bill) to the Tweede Kamer and prohibited a United States acquisition of a Dutch information-technology services provider on national security grounds. Taken together, these instruments convert the European operator’s exposure from a conflict of competing public-policy interests into a conflict of competing primary legal obligations, and extend the logic of sanctions enforcement, security screening, and countermeasures to allied as well as adversary jurisdictions.[1]

The Dutch government blocks a US investor for national security reasons

By Trade Practitioner on May 29, 2026 Posted in EU, Foreign Investment Reviews

In May, the Dutch government formally prohibited Kyndryl from its proposed acquisition of Solvinity, the Dutch IT services provider, following a recommendation by the Bureau Toetsing Investeringen (BTI). The prohibition was adopted under the Dutch telecommunications security screening regime rather than under the broader Dutch foreign direct investment (FDI) framework introduced by the Vifo Act.

We recently published an update examining the transaction. Read the full insight here.