On October 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published an alert (the “Alert”) warning that foreign financial institutions (“FFIs”) that continue to transact with sanctioned Iranian financial institutions “could be targeted at any time without advance notification.” OFAC also amended Iran-related FAQ 156 to remove earlier language indicating that OFAC would generally contact an FFI about its conduct before making a finding that the FFI knowingly engaged…
On August 24, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) launched Operation Economic Outcast, a campaign that OFAC has characterized as an “economic D-Day” against Iran. The action follows OFAC’s earlier “Economic Fury” campaign against Iran, on which we have previously reported here and here. OFAC stated these actions “mark the beginning of a sustained and systematic campaign to close every financial resource that supports the leading state sponsor…
On August 6, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a temporary final rule (the “Rule”) that restricts exports of black mass and tungsten waste and scrap without a license. Beginning August 27, 2026, US persons that sell black mass and tungsten waste and scrap must allocate 100 percent of their monthly sales to US persons, unless they first obtain an adjustment or exception from BIS. This Rule implements…
On July 10, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”), providing enhanced favorable treatment to the United Arab Emirates (“UAE”) under the Export Administration Regulations (“EAR”). BIS indicates the change is a recognition of the UAE’s status as a US Major Defense Partner, its key role in advancing US national security interests including during Operation Epic Fury, its commitment to implementing effective export…