On December 18, 2025, President Trump signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2026 (P.L. 119-60). A must-pass piece of legislation that funds Department of Defense (“DoD”) operations on an annual basis, the NDAA is a frequent vehicle for trade-related provisions and legislative changes affecting DoD acquisition policies with direct implications for government contractors. The NDAA includes a number of provisions relating to US sanctions, investment security, and supply chain…
On 5 January 2026, Switzerland imposed an immediate freeze on any assets held in Switzerland by former Venezuelan President Nicolás Maduro and the politically exposed persons (PEP) associated with him (see the press release here). This follows Nicolás Maduro’s capture by US forces. Members of the current Venezuelan government are not affected by this asset freeze. The asset freeze is stipulated in the newly released Ordinance on the freezing of assets in connection with Venezuela (Venezuela…
On 12 December 2025, the Swiss Federal Council announced the expansion of its sanctions lists against Russia and Belarus (see press release here). With this expansion, Switzerland has partially implemented the measures adopted by the EU under its 19th sanctions package. The updated Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”; see link here) entered into force on 13 December 2025. Following established procedure, the Federal Department of Economic Affairs, Education…
On December 15, 2025, Canada announced further amendments to the Special Economic Measures (Iran) Regulations (the Regulations). These amendments list an additional 4 individuals under Schedule 1 of the Regulations and took effect on December 12, 2025. All of the newly listed individuals are Iranian senior officials who are stated to have been involved in human rights violations and the facilitation of repressive policies within the Islamic Republic of Iran. The Regulations impose a dealings…