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…
The UK Financial Conduct Authority (“FCA”) has recently published proposed changes to its Financial Crime Guide (available here). The Financial Crime Guide sets out the FCA’s expectations for how financial institutions should approach compliance across a range of financial crime areas, and includes examples of what the FCA considers to be good and bad practice. The guide makes clear that firms “should apply the guidance in a risk-based, proportionate way taking into account such factors…
On 15 October 2026, the UK introduced an expanded human rights sanctions regime, via the UK’s new Global Human Rights and International Humanitarian Law Sanctions Regulations 2026 (the “2026 Regulations”). The 2026 Regulations revoke and replace the Global Human Rights Sanctions Regulations 2020 (the “2020 Regulations”). These reforms notably enable the UK to impose sanctions for serious violations of international humanitarian law, as well as for obstructions of humanitarian assistance and conduct that seriously violates…
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…