On 12 October 2026, the Council of the European Union added 820 individuals and 826 entities to its sanctions list concerning Russia. The measures target companies and executives linked to Russia’s defence industries, alongside 77 political figures connected with the September elections in occupied Ukrainian territory. The restrictions may also affect commercial relationships with unlisted companies that a listed person owns or controls. Payments, deliveries, and services may consequently be interrupted even where the underlying contract predates the listing. This alert examines the new listings, the rules on frozen assets and the provision of funds or economic resources, and the possible consequences for existing contracts.
Sanctions by statute: The Graham Act and tariffs on Russia’s energy buyers
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 authority to impose tariffs of up to 100% on goods from major buyers of Russian energy. For businesses, its reach extends well beyond Russia. Exporters in China, India, Turkey, and several EU member states could face additional duties across their US sales, regardless of whether the goods themselves connect to Russian energy, and non-US banks and companies face secondary sanctions for covered dealings. Much will turn on how the administration exercises its discretion in the weeks ahead, with the first determinations due by 18 October. This alert examines what the Graham Act requires, the tariff provisions and their exceptions, the exposure of European businesses, and the practical steps companies should take now. Read the full insight HERE.
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 laws and increase supply chain visibility. This ANPRM is in response to President Trump’s June 3, 2026, Executive Order titled “Strengthening Customs Enforcement,” directing stricter new requirements for importers of record (IORs), and particularly foreign importers of record.
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 and no diversion – the sum answers for repeated failures to keep the records and registers that open general export licences require, most of them concerning transfers of controlled technology, together with one breach of an individual licence condition. A record figure for purely administrative conduct would be notable on its own; that Airbus was also named makes it doubly so, since HMRC named an exporter for the first time only in June 2026 and has indicated that naming will, where appropriate, form a condition of future offers. Our alert considers where the figure sits in the published enforcement record, why intangible transfers of technology are the hardest part of the record-keeping obligation to discharge in practice, how the UK duties compare with those under Regulation (EU) 2021/821, and what publication may mean for procurement, financing, and voluntary disclosure decisions. Read the full insight here.
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 departing foreign investors took in place of a market price when they left Russia after February 2022. For the trade practitioner, the significance of the measure lies not in the exit terms it sits alongside, which already leave a seller with something near 5% of appraised value once the 60% discount and the 35% budget contribution are read together, but in its reach backwards into transactions that closed years ago and in the discretion it confers. Two features require close attention: the two-part test, which pairs a conduct provision drawn broadly enough to catch a public announcement of withdrawal with an economic one directed both at token-price exits and at businesses the acquirer has since recapitalised; and the compensation for the loss of the, the claim lies against the acquirer rather than the state, and the same court that cancels the option calculates the sum (or refuse it altogether). This alert examines the new article, the standing and venue rules that send every claim to a single Russian court, and how a judgment of this kind would fare against the EU’s new non-recognition rule and the investment-treaty position. Read the full analysis here.
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 burdens, and gather direct industry feedback regarding future cybersecurity requirements. Based on the recently issued suspension memorandum and accompanying request for information (RFI), defense contractors should evaluate the potential impact on their compliance strategies and consider participating in the comment process before the August 14, 2026, deadline.
We recently published an update on these developments. Read the full insight here.
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 most favourable licence-exception treatment the EAR offers. The rule took effect on filing, 10 July 2026. Press coverage has described it as making controlled military goods, satellites, and advanced computing hardware licence-free for the UAE. For the trade practitioner, its significance lies in the conditions attached: a new approved-entity list confines License Exception STA, and licence-free access to advanced computing items, to consignees and end users BIS has approved by name, leaving the underlying Commerce Control List licence requirements intact and, in the case of advanced computing, expressly preserved. This alert examines the reclassification, the entity-approval mechanism that qualifies it, the position of the UAE within a Country Group A table otherwise keyed to multilateral regime membership, and the practical questions now facing exporters. Read the full insight here.
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
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
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.
