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The Month in International Trade – February 2026

Client Alert | 15 min read | 03.06.26

Chambers Ranks Crowell & Moring International Trade Practice and Lawyers in 2026 Global Guide

Top Trade Developments

Crowell Webinars

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.

Chambers Ranks Crowell & Moring International Trade Practice and Lawyers in 2026 Global Guide

Washington – February 24, 2026: Chambers and Partners has ranked Crowell & Moring’s International Trade practice group and six individual lawyers in the Chambers Global 2026 guide.

The Chambers Global Guide ranks lawyers and law firms in over 200 jurisdictions worldwide. Through in-depth interviews with lawyers and their clients, researchers selected honorees based on client satisfaction, professional ability, and reputation. 

International Trade

International Trade: Customs – USA*
International Trade: Export Controls & Economic Sanctions: The Elite – USA

International Trade: Intellectual Property (Section 337) – USA

International Trade/WTO – Europe-Wide

Partner Vassilis Akritidis – International Trade/WTO – Europe-Wide

Partner John Brew – International Trade: Customs – USA*

Partner David Stepp – International Trade: Customs – USA

Partner Dj Wolff – International Trade: Export Controls & Economic Sanctions – USA

Partner Jeffrey Snyder – International Trade: Export Controls & Economic Sanctions – USA*

Partner Kathryn Clune – International Trade: Intellectual Property (Section 337) – USA 

* Indicates first or second tier ranking

Top Trade Developments

SCOTUS Holds IEEPA Tariffs Unlawful

On February 20, 2026, the Supreme Court issued a pivotal ruling in Trump v. V.O.S. Selections, negating the President’s ability to impose tariffs under IEEPA. The case stemmed from President Trump’s invocation of IEEPA to levy tariffs on imports from Canada, Mexico, China, and other countries, citing national emergencies. Challengers argued—and the Court agreed—that IEEPA does not delegate tariff authority to the President. The power to tariff is vested in Congress by the Constitution and cannot be delegated to the President absent express authority from Congress.

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For more information, contact: Daniel W. Wolff, John Brew, Weronika Bukowski, Sibilla Grenon

UK Government Seeks Evidence on Ownership and Control in Financial Sanctions Regulations

The UK’s Office of Financial Sanctions Implementation (OFSI) has launched a call for evidence concerning the "ownership and control" test within UK financial sanctions. The call for evidence, running until 11:59 p.m. on 13 April 2026, seeks stakeholder views on the challenges and implementation of the "control" limb, with particular focus on its hypothetical element.

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

BIS Fines Teledyne FLIR $1 Million for Unlicensed China-Related Thermal Camera Exports and De Minimis Miscalculations

On February 26, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) reached an administrative enforcement settlement with Teledyne FLIR LLC and its affiliates FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems, Inc. d/b/a Teledyne FLIR OEM, (together, “Teledyne FLIR”), imposing a $1,000,000 civil penalty to resolve alleged violations of the Export Administration Regulations (“EAR”).

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For more information, contact: Scott Wise, Jeremy Iloulian, Chandler Leonard, Nate Young

EU Amendments to List of High-Risk AML/CTF Countries

The European Commission maintains a list of third countries that are deemed to present a significant risk to the stability of the EU financial system due to weak financial controls and governance frameworks for anti-money laundering (“AML”) and counter-terrorism financing (“CTF”). EU member states must impose requirements for enhanced due diligence (“EDD”), strict monitoring measures, and mandatory reporting of suspected offences by regulated entities, including financial institutions (“obliged entities”) within these jurisdictions.

In early December 2025, the Commission adopted two regulations amending its list of third countries, adding Bolivia, the British Virgin Islands, and the Russian Federation to the list, whilst removing Burkina Faso, Mali, Mozambique, Nigeria, South Africa, and Tanzania. The regulations entered into force on 29 January 2026. The updated EU list of countries with deficient AML and CTF regimes is available here.

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For more information, contact: Carlton Greene, Nicola Phillips, Liesbeth Truyens

Treasury Seeks Public Input on CFIUS Known Investor Program and Streamlining of Foreign Investment Reviews

On February 9, 2026, the U.S. Department of the Treasury’s (Treasury) Office of Investment Security (OIS) published a request for information (RFI) seeking public comments on how the Committee on Foreign Investment in the United States (CFIUS) might streamline its foreign investment review process, including through the Known Investor Program (KIP). The RFI requests feedback on (1) proposed eligibility criteria and a draft questionnaire for the KIP, including certain defined terms, and (2) other ways that CFIUS and transaction parties can streamline aspects of the foreign investment review process. Written comments are due March 18, 2026.

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For more information, contact: Caroline Brown, Addie Cliffe, Chandler Leonard, Nimrah Najeeb, Allison Skager, Nate Young

OFAC Launches New Online Voluntary Self-Disclosure Portal

On February 6, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) announced the launch of a new online Voluntary Self-Disclosure (VSD) Portal (the “New Portal”) intended to replace and reduce reliance on ad hoc submission methods with a more secure channel for reporting to OFAC potential sanctions violations. OFAC states that moving disclosures into the New Portal should improve process visibility for disclosing parties, including faster acknowledgment and clearer communication during OFAC’s review. Of note, “OFAC strongly encourages parties to begin submitting voluntary self-disclosures through” the New Portal.

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For more information, contact: Anand Sithian, Jeremy Iloulian, Nate Young, Dmitry Bergoltsev

CBP Launches New Forced Labor Portal

On January 21, 2026, U.S. Customs and Border Protection (“CBP”) announced that its Forced Labor Portal is now live. This new online portal provides a single, centralized platform for importers to submit requests for review when their shipments are detained or excluded due to forced labor enforcement actions. By consolidating what was previously a patchwork of email and paper submission processes, the portal is intended to streamline communications and ensure that all forced labor-related documentation reaches the appropriate CBP officials for timely review.

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For more information, contact: Simeon Yerokun, Pierfilippo Natta, Ani Mard, Andrew Schlegel

Crowell Webinars

Securing Rights to IEEPA Tariff Refunds


View On Demand Here

Join Crowell’s International Trade attorneys for an update in the wake of the Supreme Court’s holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs during peacetime national emergencies. In this webinar, our attorneys will provide advice on affirmative steps importers should take to preserve rights to refunds and answer your questions about the litigation and the Supreme Court’s decision.

Speakers: Dan Cannistra, Daniel W. Wolff, Aaron Marx, Alex Schaefer, Maria Vanikiotis, Weronika Bukowski

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Navigating the EU’s New Economic Security Strategy and Countermeasures: Implications for Global and EU Businesses


View On Demand Here

In collaboration with the IBJ-IJE

Join Crowell’s international trade attorneys for an in-depth analysis of the EU’s new economic security strategy and its practical impact on businesses operating in the region.

Key Topics:

  • EU Trade Countermeasures: Gain insight into the EU’s strategy on trade disputes, how a procedure under the EU Anti-Coercion Instrument works, and the type of trade countermeasures you can expect.
  • Regulatory Updates: Explore changes in economic security regulations at the EU and Belgian levels—including the latest developments in export controls and sanctions.
  • Economic Security & Trade Defence: Understand how shifting priorities in economic security are shaping EU trade defence and customs law.

This session is designed for in-house counsels and business leaders who need to stay ahead of rapidly evolving international trade regulations. Participants will receive actionable guidance to help navigate the complexities of the new EU economic security landscape.

Speakers: Vassilis Akritidis, Liesbeth Truyens, Jean-Baptiste Blancardi

Crowell Speaks

“Hot Topics and Breaking News,”  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

“Latest IEEPA Tariff Updates,” Retail Industry Leaders Association/Retail Litigation Center Spring 2026 Legal Meetings, Washington, DC (March 3, 2026). Speaker: John Brew

“Opening or Closing Gates? Market Access in Global Infrastructure Construction: Between Openness and Strategic Protection,” Inter-Pacific Bar Association (IPBA) Annual Meeting and Conference, New Delhi (February 27, 2026). Speaker: Jeremy Iloulian

“National Security and Business,” 31st Annual National Security Law Conference, Duke Law School, Durham, NC (February 27, 2026). Speaker: Caroline Brown

“Remote Worker Fraud: Balancing Company Security Measures with Anti-Discrimination Obligations When Hiring,” Barbri, Virtual (February 26, 2026). Speaker: Caroline Brown

Shadow tanker plausibly reverts to compliant trade after Venezuela loading
February 25, 2026 – Lloyd’s List
Related Professional: Dj Wolff

Why Asian firms are not cheering Trump tariff ruling
February 25, 2026 – BBC News
Related Professional: Monica Gorman

8 things you need to understand about tariffs on pharmaceuticals and other healthcare products after last week’s Supreme Court ruling
February 23, 2026 - Managed Healthcare Executive
Related Professional: Monica Gorman

SCOTUS rules Trump’s tariffs are illegal – but the fight is far from over
February 20, 2026 – The Verge
Related Professional: Monica Gorman

Trade Expert Breaks Down Supreme Court’s ‘Landmark’ 6-3 Ruling That Struck Down Trump’s Tariffs
February 20, 2026 – Forbes Breaking News
Related Professional: Monica Gorman

Supreme Court Ruling Could Undermine Trump’s Trade Negotiations
February 20, 2026 – Times News (London)
Related Professional: Monica Gorman

Supreme Court Ruling ‘Massive Setback For Trump’, As He Announces 10% Global Tariff
February 20, 2026 – Times News (London)
Related Professional: Monica Gorman

FinCEN Opens Online Portal For Whistleblower Tips
February 16, 2026 – Law360
Related Professional: Anand Sithian

Inside one company’s $173m response to forced labor allegations
February 16, 2026 – Global Investigations Review
Related Professionals: David Stepp, Simeon Yerokun, Laurel Saito

Today’s China Crucible: What It Means for Pharma
February 11, 2026 - Pharmaceutical Executive
Related Professional: Geralyn Ritter and Monica Gorman

Syrian trade surges nearly sixfold a year after government takeover
February 3, 2026 – Lloyd’s List
Related Professional: Dj Wolff

Contacts

Insights

Client Alert | 6 min read | 03.06.26

Tri-Agencies Release Fourth Mental Health Parity Report to Congress

On March 3, 2026, the Department of Labor (DOL), Department of Health and Human Services (HHS), and Department of the Treasury (TREAS) — collectively, the “Tri-Agencies” — published their fourth annual report to Congress on enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA). The 2025 Report demonstrates a shift in approach by the Tri-Agencies in its tone and content and suggests that federal regulators, and the DOL in particular, are not as active as they previously were in MHPAEA enforcement. However, federal enforcement remains ongoing, and state enforcement of mental health parity laws continues to grow. Plans and issuers must continue to maintain comprehensive compliance processes and documentation for MHPAEA compliance....

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