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Export Controls

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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 23 July 2026, the European Council adopted its 21st package of Russia sanctions as well as additional measures targeting Belarus. The package concentrates on sectors with the greatest impact on Russia’s war economy, including energy, shipping, gold, financial services (including crypto), trade, and the Russian military-industrial complex. Key elements include a full-year suspension of the oil price cap adjustment, a new tool allowing transaction bans on named refineries that process Russian crude (listing one…

On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 2 (“GL 2”) under the Democratic Republic of the Congo Sanctions Regulations (the “DRCSR”) as the eastern Democratic Republic of the Congo (“DRC”) continues to face significant humanitarian challenges, including an Ebola outbreak in the region. GL 2 goes beyond the existing general license found in section 547.513 of the DRCSR, which is limited to…

On June 22, 2026, President Trump signed Executive Order 14411, on Ushering in the Next Frontier of Quantum Innovation (the “EO”). The EO establishes a national policy to maintain a strategic technical advantage in quantum information science and technology (QIST) and leads the development of a robust and trusted quantum ecosystem across QIST research, manufacturing, commercialization, and application. Accordingly the focus of much of the EO is directed at accelerating domestic commercialization and research. Additionally,…