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…
On October 26, 2026, China’s Ministry of Commerce (“MOFCOM”) published the draft Special Provisions on the Protection of Chinese Trade Secrets, introducing a new sanctions tool targeting foreign infringement of Chinese trade secrets. Once finalized, the rules would authorize MOFCOM to impose sanctions on foreign companies, organizations and individuals where such infringement harms, or poses an actual threat to, China’s sovereignty, security or development interests. MOFCOM may initiate investigations before imposing sanctions, and third parties…
On April 28, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took a series of Iran-related actions as part of the Administration’s “Economic Fury” campaign of exerting maximum pressure against Iran. Specifically, OFAC (1) issued an alert warning of the sanctions risks of dealing with Chinese “teapot” oil refineries that process Iranian crude oil and (2) published FAQ 1249, which warns that “toll” payments to the Government of Iran (“GoI”)…
Following months of negotiations and feints, on November 1, 2025, the United States and China reached a trade and economic agreement during bilateral discussions held in the Republic of Korea. The agreement outlines a series of reciprocal measures intended to address trade flows and market access between the two countries. The negotiations had already yielded significant rapprochement between the two countries, including the one-year suspension, as of November 10, 2025, of the “Affiliates Rule,” which…