European Sanctions on Iran – Compliance for European Operations
Client Alert | 1 min read | 09.08.08
Recent news reports indicate that the EU is cracking down on small and mid-sized enterprises that are trading with and investing in Iran. There have been no new EU-wide rules since 7 August 2008 when the EU adopted a common position in order to implement United Nations Security Council Resolution 1803 (2008); however, there is increasing pressure on the EU and its Member States to enforce more stringently the existing UN sanctions as well as propose new measures with a broader scope.
In particular, EU authorities are attempting to target small and mid-sized companies and banks that do not have significant interests in the US and that are trying to fill the gap left by larger companies that have scaled down their Iranian operations.
As larger firms exit Iran, European businesses (and US businesses with European operations) will discover new business opportunities there. Exploring those opportunities, and determining whether they can be lawfully pursued, requires a review of the application of both US and EU law. That review must now take into account increased scrutiny by European authorities.
Contacts
Insights
Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26

