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The Month in International Trade—April 2026

Client Alert | 5 min read | 05.12.26

Top Trade Developments

Crowell Speaks

This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Anand Sithian or Simeon Yerokun or any member of the International Trade Group.

Top Trade Developments

Deadlock Broken: EU Adopts 20th Russia Sanctions Package

 The EU has adopted its 20th package of sanctions in connection with Russia’s ongoing war against Ukraine, resolving a prolonged internal political deadlock that had been caused by vetoes from Hungary and Slovakia. The package amends Regulations 833/2014, 269/2014, and 765/2006 and the respective Council Decisions and Implementing Regulations. The texts entered into force on 24 April 2026.

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For more information, contact: Liesbeth Truyens, Sophie Davis, Celine De Buck

OFAC Expands Venezuela Sanctions Relief: New General Licenses 56 and 57, and Guidance on Reporting Obligations

On April 14, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela” (GL 56), and Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals” (GL 57). OFAC also issued one Venezuela-related Frequently Asked Question (FAQ), FAQ 1248.

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For more information, contact: Carlton Greene, Anand Sithian, Jeremy Iloulian, Rachel Richman, Edward Goetz

OFAC Sanctions Cartel-Linked Casinos and Financial Enablers on the Southern Border

On April 14, 2026, the U.S. Department of the Treasury announced OFAC sanctions targeting a money laundering and cash smuggling network operated by CDN, a U.S.-designated Foreign Terrorist Organization (FTO) with significant influence in Nuevo Laredo, located on the U.S.-Mexico border.

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For more information, contact: Caroline Brown, Carlton Greene, Anand Sithian, Dmitry Bergoltsev

OFSI Imposes £390,000 Penalty on Apple Subsidiary for Russian Sanctions Breaches: Key Compliance Takeaways

The UK’s Office of Financial Sanctions Implementation (OFSI) has published details of a £390,000 penalty it imposed on ADI, an Irish subsidiary of Apple Inc., on 19 March 2026. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. Although the underlying facts are relatively simple, there are several interesting takeaways from OFSI’s penalty notice.

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For more information, contact: Dj Wolff, Sophie Davis, Nicola Phillips

Carbon Border Adjustment Mechanism (CBAM): First Release of CBAM Certificate Price

On 7 April 2026, the Commission published the first quarterly CBAM price at EUR 75.36 per certificate for the first quarter of 2026. The prices for the remaining quarters will be released on 6 July 2026, 5 October 2026, and 4 January 2027, respectively. Each quarterly price will apply to the sale of CBAM certificates for emissions from CBAM goods imported into the Union during that quarter. From 2027 onwards, the price will be published weekly.

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For more information, contact: Vassilis Akritidis, Oleksii Yuzko

Crowell Speaks

“Export Controls and M&A: From Due Diligence to Day One Compliance,” 2026 Spring Virtual Advanced Conference – Trade as Policy: Export Controls, Sanctions, and Industrial Strategy in a New Era, Virtual (May 13, 2026). Speaker: Chandler Leonard.

“AI Export Controls: Model Weights, Compute, and Advanced Semiconductor Restrictions,” 2026 Spring Virtual Advanced Conference – Trade as Policy: Export Controls, Sanctions, and Industrial Strategy in a New Era, Virtual (May 11, 2026). Speaker: Scott Wise

“Economic Repercussions of Tariffs in a New Age Part II,” Bar Association of San Francisco, Virtual (May 7, 2026). Speaker: Jackson Pai

Trump Tariff Refunds Start Hitting Importers’ Bank Accounts
May 6, 2026 – Bloomberg Law
Related Professional: Dan Cannistra

“Latin America Under Scrutiny: Mitigating the Expanding Cross-Industry Risks Posed by Cartels and FTO Designation,”American Conference Institute’s 20thAnnual Flagship Conference on Economic Sanctions and Enforcement Compliance, Washington, DC (April 29, 2026). Speaker: Carlton Greene.

“Beyond Sanctions Screening: Why Evasion Detection Requires Investigation,” NICE Actimize ENGAGE 2026, New York (Apr. 28, 2026). Speaker: Caroline Brown

“Geopolitical Risk in Trade for 2026,” 2026 New York Trade Finance Compliance Annual Meeting, New York (Apr. 28, 2026). Speaker: Anand Sithian

“The New War on Drugs: Cartels, and Transnational Criminal Organizations,” Association of Certified Sanctions Specialists (ACSS) Annual US Conference on Global Sanctions and Export Controls, Washington DC (Apr. 16, 2026). Speaker: Caroline Brown

“The After-Action Review of Recent Sanctions and Export Controls Enforcement Actions,” Association of Certified Sanctions Specialists (ACSS) Annual US Conference on Global Sanctions and Export Controls, Washington DC (Apr. 16, 2026). Speaker: Anand Sithian

“University of Illinois Chicago School of Law 24th Annual Dominick L. DiCarlo U.S. Court of International Trade Lecture, Virtual (April 9, 2026). Speaker: John Brew

Contacts

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