Insights

On Friday, September 18, 2026, the U.S. Department of State issued two rules amending the International Traffic in Arms Regulations (ITAR). The first, an interim final rule effective October 19, narrows U.S. Munitions List (USML) Category XX(a) controls on certain uncrewed underwater vehicles. The second, a final rule effective immediately, clarifies policy-of-denial provisions, updates country policies for Ethiopia and Somalia, and adds Saudi Arabia and Peru to the list of major non-NATO allies.

Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken. See our State Attorneys General page for more insights. Below are the updates from October 8-14, 2026:

On October 14, 2026, Tenaris USA, Vallourec Star LP, and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC (the “USW”) filed petitions with the U.S. Department of Commerce (“Commerce”) and the U.S. International Trade Commission (“Commission”) seeking antidumping (“AD”) duties on imports of seamless carbon and alloy steel standard, line, and pressure pipe (“SSLPP”) from Georgia and India, and countervailing duties (“CVD”) on imports of SSLPP from India.

The following is an installment in Crowell & Moring’s Bid Protest Sustain of the Month Series. In this series, Crowell’s Government Contracts Practice keeps you up to date with a summary of one of the most notable bid protest sustain decisions each month. Below, Crowell Consultant (and former GAO Bid Protest Hearing Officer) Cherie Owen discusses GAO’s decision in Ares Enterprise, LLC, B-424548 et al., Sept. 3, 2026, which addressed a situation where an agency attempted to issue a task order that exceeded the scope of both the underlying blanket purchase agreement and the awardee’s Federal Supply Schedule contract.

Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken. See our State Attorneys General page for more insights. Below are the updates from October 1-7, 2026:

On October 12, 2026, the EU adopted its largest-ever single round of Russia sanctions listings, adding 826 companies associated with Russia’s military-industrial complex and 743 executives of these companies to Annex I of Regulation (EU) No 269/2014. The 1,569 additions bring listings under the EU’s regime supporting Ukraine’s territorial integrity to nearly 4,600. Separate measures targeted 77 individuals involved in illegal Russian elections in occupied Ukrainian territory and seven parties connected to North Korea.

California AB 2346, signed into law September 30, 2026, imposes a set of new obligations on e-bike manufacturers, distributors, and retailers. Here is what the law requires and key compliance dates.

The Federal Trade Commission continued its active enforcement agenda this week, targeting deceptive pricing practices across the healthcare, automotive, and retail sectors. The agency also took action against a martial arts franchisor for misleading earnings claims, secured a Robinson-Patman Act resolution involving wholesale T-shirt distributors, and distributed millions of dollars in consumer refunds stemming from prior settlements. These stories and more after the jump.

In our client alert of September 30, 2026,1 we provided an executive summary of federal banking regulators’ Proposed Third-Party Risk Management Guidance (the “Proposal”), a related joint statement on community banks’ engagement with core service providers, and a proposed Federal Reserve guide for traditional community banks (the “Community Bank Guide”).2 This blog post covers what these agency pronouncements mean for fintechs and the banks that sponsor their programs.

The U.S. Court of International Trade (“CIT”) has again rejected the U.S. Department of Commerce’s (“Commerce”) determination that chassis manufactured in Vietnam with Chinese-origin parts are covered by the antidumping (“AD”) and countervailing duty (“CVD”) orders on chassis from China. In Pitts Enterprises, Inc. dba Dorsey Intermodal v. United States, Slip Op. 26-121 (October 7, 2026), Judge Claire R. Kelly remanded Commerce’s redetermination for a second time. The court held that Commerce’s reading of the orders to cover “unfinished subassemblies” is contrary to their plain meaning, and that, in any event, the phrase “any other processing” in the orders does not include welding or fabrication.

On April 2, 2026, President Trump signed two presidential proclamations invoking Section 232 of the Trade Expansion Act of 1962 and Section 604 of the Trade Act of 1974 to impose significant new tariffs on imports of patented pharmaceuticals and pharmaceutical ingredients, and to restructure the existing tariff regime for aluminum, steel, and copper articles and their derivatives. The pharmaceutical proclamation targets patented drugs and active pharmaceutical ingredients (APIs), citing the Secretary of Commerce’s finding that approximately 53 percent of patented pharmaceutical products distributed domestically are produced outside the country, and only 15 percent of patented APIs by volume are domestically produced for the U.S. market. The metals proclamation amends three prior Section 232 actions — Proclamation 9704 of March 8, 2018 (aluminum), Proclamation 9705 of March 8, 2018 (steel), and Proclamation 10962 of July 30, 2025 (copper) — to restructure how tariffs are calculated and which derivative articles are covered.  The administration also issued two separate fact sheets for these actions.

Key Takeaway #1 California’s new AI chatbot law — “Adam’s Law” (SB 1119) — requires companion chatbot operators to conduct mandatory independent child safety audits and annual risk assessments, implement crisis protocols for queries involving self-harm, and notify parents when children disable safety settings. Non-compliance exposes businesses to significant civil liability.

The FTC has been active across both consumer protection and competition spaces in the past two weeks. In the consumer protection space, the Commission published guidance on auto dealer price transparency, announced proposed settlements with companies and individuals resolving complaints of alleged deceptive marketing and unfair practices, and sought public comment on platforms’ role in amplifying impersonation scams. In the competition space, the Commission endorsed a Department of Education proposal to increase competition among higher education accreditors. The Commission also revised its Rules of Practice. These stories and more after the jump.

Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken. See our State Attorneys General page for more insights. Below are the updates from September 24-30, 2026:

Each week, Crowell & Moring’s State Attorneys General team highlights significant actions that State AGs have taken. See our State Attorneys General page for more insights. Below are the updates from September 18-23, 2026:

Key Takeaways:

In Aim for AdVantage, LLC, GAO dismissed a protest as a sanction after finding that the protester had materially misrepresented the facts underlying its challenge to the rejection of its proposal. The protester claimed it had spent two hours trying to submit its proposal through the agency’s digital portal before the deadline, only to be thwarted by undisclosed system limitations.  But a forensic review of the protester’s account activity told a very different story – one in which the protester had not even attempted to access the portal until nearly an hour after the deadline had passed. GAO’s decision to dismiss the protest as a sanction for these misrepresentations serves as a stark warning: fabricating facts in a GAO protest may result in serious consequences.

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, following bipartisan passage in both chambers. Among its most commercially significant provisions is a sweeping new tariff framework targeting Russia and countries that continue to buy Russian energy.

Register now to join Crowell’s State AG team as they kick off a two-part webinar series examining the 2026 State Attorney General elections and what they mean for businesses operating across the United States.