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.
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.
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.
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.
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.
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]
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.
This hugely successful and highly praised event on US export controls regulations, which is jointly organized by the Export Group for Aerospace, Defence & Dual-Use (EGADD) and Squire Patton Boggs, will be celebrating its 19th Anniversary when it takes place in July 2026.
On November 10, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule titled “One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities.” As the title indicates, the final rule formally enacts a one-year suspension of the BIS Affiliates Rule, which had been in effect since September 29, 2025, as we previously reported in “BIS Expands Entity List Controls to All Unlisted Foreign Affiliates Owned 50% or More by Listed Parties.”
On October 9, 2025, China’s Ministry of Commerce (MOFCOM) announced two new decrees (the “New Rules”) significantly expanding and strengthening export controls over the rare earth supply chain: Decree No. 61 primarily targets foreign-made rare earth metals and products, while Decree No. 62 focuses on the control of rare earth-related technology.
