President Trump signed the much-anticipated Russia (and Iran) sanctions bill into law on Friday, September 18, 2026. The final text of H.R. 5334 is available here. In Brief It has been a long journey since Senator Lindsey Graham introduced an earlier version of the bill in the Senate in April 2025. After Senator Graham passed away in July, a new Russia sanctions bill was introduced bearing his name, the Lindsey O. Graham Sanctioning Russia and…
On August 26, 2026, President Trump issued Executive Order 14420, “Declaring a National Emergency to Secure the United States Bulk-Power System” (“EO 14420”), which aims to prevent certain foreign actors from creating or exploiting vulnerabilities in foreign-produced equipment used in the US bulk-power system. EO 14420 builds on and significantly expands Executive Order 13920, “Securing the United States Bulk-Power System” (“EO 13920”), which the Trump administration issued in 2020 and formed the basis of an…
On May 1, 2026, President Trump signed Executive Order 14404 (“EO 14404”) entitled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” which significantly expands the US sanctions framework targeting Cuba. EO 14404 imposed a modern US secondary sanctions regime targeting Cuba that is likely to encourage many non-US companies – particularly those with US assets/business and/or reliance on the US financial system –…
On April 8, 2026, the US Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) issued a joint proposed rule (“Proposed Rule”) to implement provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (“GENIUS Act”). The Proposed Rule implements the GENIUS Act’s anti-money laundering (“AML”) and sanctions compliance program requirements and encourages innovation in payment stablecoins while providing a regulatory regime to mitigate…