After much anticipation, on November 5, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released a final rule formally extending the suspension of the “Affiliates Rule” through January 10, 2027. This final rule is due to be published in the Federal Register on November 9, 2026. The Affiliates Rule, originally issued as an interim final rule effective September 29, 2025, automatically extends Entity List, Military End-User List, and certain sanctions-based licensing…
The results from the midterm elections have changed the political landscape of the U.S. House of Representatives and Senate. While some individual races remain to be called, the power shift in Congress has been confirmed: Democrats will take control of both the House of Representatives and the Senate. The next Congress, and the way it interacts with the Trump Administration on trade issues, will create new challenges and demand fresh strategies for companies. We share…
On October 9, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added the entire International Criminal Court (“ICC”) to the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to Executive Order 14203 (“EO 14203”) and issued four general licenses authorizing specified transactions involving the court. Designation of the ICC Under EO 14203 OFAC has designated the ICC under section 1(a)(ii)(A) of EO 14203. The ICC designation follows OFAC’s…
Join us in Mountain View, California on Thursday, November 12, for an exclusive in-person forum on Trade Strategy in a Fragmented World. The event will kick off with a fireside chat featuring Peter Harrell (Visiting Scholar Georgetown Law, former White House Senior Director for International Economics and Competitiveness, Contributing Editor, Lawfare), who will share insights on making sense of economic statecraft, the weaponization of tariffs, sanctions, and export controls, and adapting to the proliferation of…