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The Month in International Trade – January 2026

Client Alert | 13 min read | 02.04.26

Liesbeth Truyens, Economic Sanctions and Commercial Disputes Lawyer, Joins Crowell & Moring’s Brussels Office

Crowell & Moring Elects New Trade Group Partner, Promotes Two Others to Counsel

Crowell & Moring Represents FGV Holdings in Successful Modification of CBP Withhold Release Order

Top Trade Developments

Crowell Webinars

Crowell Welcomes

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.

Liesbeth Truyens, Economic Sanctions and Commercial Disputes Lawyer, Joins Crowell & Moring’s Brussels Office

Brussels – January 13, 2026: Liesbeth Truyens has joined Crowell & Moring as a partner in its International Trade Group in Brussels, further strengthening the firm’s ability to serve sophisticated clients across the EU facing complex sanctions and export control issues. Truyens brings over 15 years of experience, both as outside counsel and from within an EU-based financial institution, advising clients on economic sanctions, export controls, supply chain considerations, and commercial disputes.

Truyens provides counseling on economic sanctions and broader international trade issues to clients across a variety of industries, including financial services, international shipping, chemical trading, defense manufacturing and procurement, and oil and energy production. Her practice focuses on a broad range of compliance matters, including export controls, anti-money laundering, anti-bribery, the Private Investigations Act, and related regulatory concerns. Truyens routinely manages complex enforcement issues, supporting organizations through regulatory proceedings and criminal investigations.

Truyens also advises on environmental, social, and governance (ESG) requirements, particularly in the context of European Union directives such as the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CSDDD), Regulation on Deforestation-Free Products (EUDR), and the EU Forced Labor Regulation (FLR). In addition to advisory work, she represents businesses in commercial litigation, both in court and arbitration, and is adept at mediation and reconciliation to efficiently resolve disputes.

Crowell & Moring Elects New Trade Group Partner, Promotes Two Others to Counsel

Maria Vanikiotis is the newest partner in Crowell’s International Trade Group. Her practice is centered around the cross-border movement of goods, with a particular focus on U.S. customs matters. She has specific experience in leading customs investigations, building compliance programs, and counseling importers on tariff management strategies, country-of-origin determinations and marking rules, free trade agreement verifications, complex customs valuations, e-commerce issues, and other regulatory import matters.

Chandler Leonard and  Laurel Saito were both promoted to counsel.

Crowell & Moring Represents FGV Holdings in Successful Modification of CBP Withhold Release Order

Washington – January 16, 2026: Crowell & Moring LLP served as lead counsel to FGV Holdings, a Malaysian agribusiness and food company, in its modification of U.S. Customs and Border Protection’s (CPB) Withhold Release Order (WRO).

CBP announced that it has modified the WRO previously imposed on FGV Holdings Berhad (FGV) and its subsidiaries and joint ventures, allowing the company to resume the importation of palm oil and palm oil products into the United States.

The modification marks the culmination of continued engagement with CBP, following issuance of the original WRO in September 2020. Crowell provided strategic negotiation, representation, and oversight of the corrective action planning and remediation process with CBP.

The Crowell legal team was led by partner David Stepp, with assistance from attorneys Simeon Yerokun, Pierfilippo Natta, Frances Hadfield (former Crowell Counsel), and Laurel Saito.

This achievement reflects the close collaboration between Crowell & Moring and FGV’s leadership including FGV’s Chief Executive Officer and Chief Sustainability Officer and their teams, who demonstrated sustained commitment to operational reforms addressing forced labor risk indicators.

For more details, see FGV’s official release here.

Top Trade Developments

US Customs Announces Withhold Release Order on Coffee from Finca Monte Grande in Mexico

On January 29th, 2026, U.S. Customs and Border Protection announced a Withhold Release Order on all shipments of coffee harvested by Finca Monte Grande, a Mexican coffee farm in Chiapas, Mexico. Effectively immediately CBP will detain all shipments of coffee harvested by Finca Monte Grande at any U.S. Port of Entry for probable forced labor violations.

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For more information, contact: Simeon Yerokun, Brett Everett

Move to a Single List for UK Sanctions Designations

From Wednesday, 28 January 2026, the UK Sanctions List (“UKSL”), published by the Foreign, Commonwealth and Development Office, will act as the sole source of UK sanctions designations made under the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). OFSI’s Consolidated List of Asset Freeze Targets (the “OFSI List”) and its search tool will not be updated beyond 28 January 2026.

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For more information, contact: Sophie Davis

Altomare SA and Kallista Removed from OFAC’s SDN List

On January 21, 2026, the U.S. Office of Foreign Assets Control (OFAC) announced the removal of Greek maritime company Altomare SA and its vessel, Kallista, from the Specially Designated Nationals and Blocked Persons Lists (SDN List).

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For more information, contact: Dj Wolff, Jeremy Iloulian, Laurel Saito, Dmitry Bergoltsev, Ivy Xun

House Passes Remote Access Security Act to Limit Adversaries’ Remote Access to Critical Technology

On January 12, 2026, the U.S. House of Representatives overwhelming passed (369-22) the Remote Access Security Act, modernizing U.S. export controls to address foreign adversaries’ remote access to controlled technologies through cloud computing services.

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For more information, contact: Scott Wise, Jeremy Iloulian, Dmitry Bergoltsev

BIS Fines Exyte $1.5 Million for Unlicensed Transfers to China’s SMIC

On January 7, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $1.5 million civil penalty on Exyte Management GmbH (“Exyte”), a Germany- headquartered engineering and procurement company, after its Shanghai affiliate Exyte Shanghai Ltd., (“Exyte China”) admitted to illegally causing the transfer of approximately $2.8 million in EAR-subject semiconductor equipment to Semiconductor Manufacturing International Corp. (“SMIC”), China’s largest chip manufacturer. BIS designated SMIC on the Entity List in 2020, resulting in the prohibition of the export, reexport, and transfer of all items subject to the Export Administration Regulations (EAR) to SMIC without specific authorization. Exyte must pay the penalty within 75 days to maintain its BIS export privileges.

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For more information, contact: Jeremy Iloulian, Nate Young

China Announces New Export Controls Targeting Japan

On January 6, 2026, China’s Ministry of Commerce (“MOFCOM”) issued Announcement No. 1 [2026], imposing export controls on dual-use items destined for Japan. The measures took effect immediately, with no wind-down period.

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For more information, contact: Scott Wise, Jeff Snyder, Zhiwei Chen, Dmitry Bergoltsev

Treasury to Issue All CBP Refunds Electronically Starting in February

The U.S. Department of the Treasury will cease issuing paper checks for all U.S. Customs and Border Protection (“CBP”) refunds starting on February 6, 2026 according to an Interim Final Rule. A recipient may continue to receive paper checks provided that they have an approved waiver in place in accordance with 31 C.F.R. § 208. Individuals and firms seeking refunds for IEEPA tariffs are unlikely to fall under one of the specific cases provided for in 31 C.F.R. § 208.4(a). Therefore, importers seeking possible refunds of IEEPA tariffs in the event that the Supreme Court finds such tariffs unlawful should ensure that Automated Clearing House (“ACH”) refunds are authorized in the Automated Commercial Environment (“ACE”) Portal.

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For more information, contact: Wing Cheung, Andrew Schlegel

Crowell Webinars

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 Welcomes

Celine De Buck is an Associate based in our Brussels office. Her practice focuses on commercial law, dispute resolution, compliance and, notably, economic sanctions and export control mandates. Celine holds a Master of Laws (cum laude) from KU Leuven (majoring in criminal law and minor in private law) and is fluent in Dutch and English (with working proficiency in French). 

Crowell Speaks

“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

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Related Professional: Dj Wolff

“Tariffs & Sanctions in 2026: Practical Guidance for Asia Regional In-House Counsel,” Association of Corporate Counsel, Singapore (January 28, 2026). Speaker: Nicole Simonian, Dan Cannistra, and Scott Wise

“Making International Business Relations Work in Times of Conflict: Perspectives from Practitioners in China, the USA, and Germany,” Institute of Customs and International Trade Law, University of Münster, Virtual (January 17, 2026). Speaker: Jeff Snyder

“Navigating Tariffs, Classification and Origin Determinations: HTS and Country of Origin Essentials and Grey Areas,” Passport to U.S. Customs Compliance Winter Edition, Virtual (January 16, 2026). Speaker: Simeon Yerokun

“Maintaining American Innovation and Technology Leadership,” U.S. House Committee on Ways and Means, Subcommittee on Trade, Washington D.C. (January 13, 2025). Speaker:  Nigel Cory

Contacts

Insights

Client Alert | 2 min read | 02.23.26

NYC’s Mayor Mamdani Joins the Wave of Local Consumer Protection Enforcement

While state attorneys general have traditionally led consumer protection enforcement, local governments are increasingly deploying their own powers to prosecute high-stakes affirmative litigation. The results speak for themselves: Los Angeles and Chicago have secured multi-million-dollar judgments and settlements in consumer deception cases over the past decade....

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