The Month in International Trade—March 2026

Chambers Europe Guide and Legal 500 Europe, Middle East & Africa (EMEA) Recognize Crowell & Moring Trade Practice and Partner in 2026

Top Trade Developments

• Answering the Top Seven Questions About Pending Section 301 Deadlines
• White House Issues Dual Section 232 Proclamations on Pharmaceuticals and Metals
• EU Co-Legislators Agree on UCC Proposal
• Senate Committee Advances Bill to Shield U.S. Companies from Foreign Judgment Enforcement in the United States Relating to U.S. Sanctions Compliance
• Firewall Up: FCC Bars Foreign-Made Routers in New Covered List Update
• OFAC Issues New General Licenses Authorizing Broad PdVSA Transactions
• Section 301 Investigations Announced for 60 Trade Partners
• Eight Takeaways After Seven Weeks of OFAC’s Six, wait Seven, New and Updated General Licenses for Venezuela
• FinCEN Grants Exceptive Relief to Streamline Beneficial Ownership Verification Requirements for Financial Institutions
• Proposed EU Industrial Accelerator Act Aims to Shore Up Declining EU Manufacturing Sector
• OFAC Sanctions Rwanda’s Military

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.

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Chambers Europe Guide and Legal 500 Europe, Middle East & Africa (EMEA) Recognize Crowell & Moring International Trade Practice and Partner in 2026 Guides

The Chambers Europe 2026 guide and the Legal 500 Europe, Middle East & Africa (EMEA) 2026 edition recognized a number of practice areas and lawyers in Crowell & Moring’s Brussels office including:

International Trade/WTO

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

The Chambers Europe Guide ranks lawyers and law firms in jurisdictions and regions across the continent. Through in-depth interviews with lawyers and their clients, researchers selected honorees based on client satisfaction, professional ability, and reputation

Legal 500 evaluates the legal market, gathering feedback from over 300,000 in-house counsel worldwide and conducting in-depth interviews with leading lawyers. The publication seeks to “highlight the practice area teams who are providing the most cutting edge and innovative advice to corporate counsel.”

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Top Trade Developments

Answering the Top Seven Questions About Pending Section 301 Deadlines

 In March 2026, the Office of the United States Trade Representative (USTR) launched two parallel Section 301 investigations: one targeting manufacturing overcapacity across 16 countries (including China, the EU, Japan, India, Mexico, Vietnam, and other major manufactures), and one targeting forced labor enforcement failures across 60 countries. Here are the top seven questions Crowell & Moring’s International Trade team is getting regarding pending Section 301 comment deadlines from our clients and how to address them.

Click here to continue reading the full version of this alert.

For more information, contact: David Stepp, Simeon Yerokun

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White House Issues Dual Section 232 Proclamations on Pharmaceuticals and Metals

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.

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For more information, contact: Dan Cannistra, Aaron Marx, Brett Everett, Nate Young

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EU Co-Legislators Agree on UCC Proposal

The Council of the European Union (EU) and the European Parliament have reached a long-awaited political agreement to reform the Union Customs Code (UCC). The European Commission presented the UCC reform proposal in May 2023, and the European Parliament adopted its position at first reading in March 2024. The text has since been pending the Council’s first reading for two years.

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For more information, contact: Vassilis Akritidis, Oleksii Yuzko, Nate Young

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Senate Committee Advances Bill to Shield U.S. Companies from Foreign Judgment Enforcement in the United States Relating to U.S. Sanctions Compliance

On March 26, 2026, the Senate Judiciary Committee advanced S.2934, the Protecting Americans from Russian Litigation Act of 2025 (the Bill), introduced by Senators John Cornyn (R-TX) and Alex Padilla (D-CA) in September 2025. The Bill is intended to address situations where U.S. companies that exited Russia to comply with U.S. sanctions following Russia’s 2022 invasion of Ukraine faced retaliatory litigation in Russian courts resulting in adverse judgments, which judgments have then been enforced abroad.

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For more information, contact: Anand Sithian, T. Michael Guiffre, Sophie Davis, Liesbeth Truyens, Nate Young

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Firewall Up: FCC Bars Foreign-Made Routers in New Covered List Update

On March 23, 2026, the Federal Communications Commission (FCC) updated its Covered List—a list of communications equipment and services deemed to pose an unacceptable risk to U.S. national security or the safety and security of U.S. persons—to include consumer-grade routers produced in a foreign country, absent an exemption granted by the U.S. Departments of War (DoW) or Homeland Security (DHS). This designation effectively prohibits the import of all consumer routers that are not produced in the United States.

Click here to continue reading the full version of this alert.

For more information, contact: Caroline Brown, Rajeev Raghavan, Jeremy Iloulian, Sibilla Grenon, Rachel Richman

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OFAC Issues New General Licenses Authorizing Broad PdVSA Transactions

On March 18 and 19, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new Venezuela-related general licenses: General License No. 52 (GL 52), authorizing most previously prohibited transactions involving Petróleos de Venezuela, S.A. (PdVSA)  and General License No. 5V (GL 5V), authorizing further transactions related to the PdVSA 2020 8.5 Percent Bond issued on or after May 5, 2026.

Click here to continue reading the full version of this article.

For more information, contact: Jeremy Iloulian, Heather Sanborn, Dmitry Bergoltsev

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Section 301 Investigations Announced for 60 Trade Partners

On March 12^th, the Office of the United States Trade Representative (USTR) initiated investigations under Section 301(b) of the Trade Act of 1974 of 60 countries for potential forced labor violations resulting in unfair competition for US companies selling abroad. According to U.S. Trade Representative Jameison Greer, the investigations will examine whether these countries have failed to take adequate measures to prevent goods produced with forced labor from entering global supply chains in a manner that burdens or restricts U.S. commerce and places U.S. exporters at a competitive disadvantage abroad.

Click here to continue reading the full version of this article.

For more information, contact: Jeff Snyder, Sibilla Grenon, Ani Mard, Brett Everett

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Eight Takeaways After Seven Weeks of OFAC’s Six, wait Seven, New and Updated General Licenses for Venezuela

Over the last two months, OFAC has issued and updated a series of general licenses and Frequently Asked Questions (FAQs) that allow for a variety of activities in the Venezuela oil, gas, petrochemical products, electricity, and gold sectors when they involve persons sanctioned pursuant to the Venezuela sanctions regulations, including the Government of Venezuela (GOV) and its state-owned oil company PdVSA.

Click here to continue reading the full version of this alert.

For more information, contact: Dj Wolff, Erik Woodhouse, Caroline Brown, Carlton Greene, Jeremy Iloulian, Rachel Richman, Jasmine Masri, Dmitry Bergoltsev

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FinCEN Grants Exceptive Relief to Streamline Beneficial Ownership Verification Requirements for Financial Institutions

In a 2016 rule (CDD Rule), FinCEN introduced new customer due diligence requirements for Covered Institutions. Under the CDD Rule, Covered Institutions were required to collect and verify identifying information about the beneficial ownership of their legal entity customers each time the customer opened a new account — even if minimal time had elapsed between each account opening, or the institution had no reason to believe that the previously verified beneficial ownership information had changed. This led to complaints from some Covered Institutions that the rule was too broad.

Click here to continue reading the full version of this article.

For more information, contact: Carlton Greene, Jackie Schaeffer, Erik Woodhouse

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Proposed EU Industrial Accelerator Act Aims to Shore Up Declining EU Manufacturing Sector

On March 4, 2026, the European Commission proposed the Industrial Accelerator Act (IAA), a draft regulation that aims to reverse the decline of the EU’s manufacturing sector while supporting the adoption of cleaner technologies. The proposal introduces “Made in EU” and low-carbon requirements in public procurement and public support schemes, to create lead markets for European industrial products. The proposal also seeks to increase value creation in the EU and bolster the EU’s economic security by setting conditions for major foreign direct investments (FDI) in strategic sectors.

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For more information, contact: Karl Stas, Jean-Baptiste Blancardi

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OFAC Sanctions Rwanda’s Military

In what amounts to a material expansion of its existing sanctions program arising out of the conflict in the Democratic Republic of the Congo (“DRC”), on March 2, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against the Rwanda Defence Force (“RDF”)—an organization described by OFAC as Rwanda’s military—along with four senior RDF officials. According to Treasury, the RDF has been “supporting, training, and fighting alongside” M23, an armed group already designated by both the United States and United Nations and operating in the eastern DRC. Treasury tied the action  to alleged violations of the “Washington Accords for Peace and Prosperity,” including a recent M23 offensive that resulted in the capture of the city of Uvira in eastern DRC.

Click here to continue reading the full version of this article.

For more information, contact: Dj Wolff, Heather Sanborn, Nate Young

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Crowell Speaks

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

“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

“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

“Navigating the EU’s New Economic Security Strategy and Countermeasures: Implications for Global and EU Businesses,”  Crowell & Moring Webinar in collaboration with ACC (March 30, 2026). Speakers: Vassilis Akritidis, Liesbeth Truyens, Jean-Baptiste Blancardi

“The Evolving Sanctions Landscape: Current Developments and Emerging Risks,” ACSS New York Chapter, New York (March 26, 2026). Speaker: Anand Sithian 

NY Bill Elevates Criminal Risk For ‘Shadow’ Crypto Firms
March 26, 2026—Law360
Related Professional: Carlton Greene, Anand Sithian, Allison Fleming

“China customs: recent legal developments and practical updates,” CustomsClear, Virtual (March 19, 2026). Speaker: Zhiwei Chen

2026 “top advisors” on national security and foreign investment
March 18, 2026—Foreign Investment Watch
Related Professional: Caroline Brown

“US customs: recent legal developments and practical updates,” CustomsClear, Virtual (March 17, 2026). Speakers: Simeon Yerokun and Sibilla Grenon

Iran wages economic war in hopes of outlasting U.S. and Israel
March 18, 2026—Washington Post
Related Professional: Monica Gorman

Higher Oil Prices Could Bring a Global Economic Shock. This Is the Number to Watch
March 13, 2026—Barron's
Related Professional: Monica Gorman

“Work smarter: tools and techniques to boost productivity,” CustomsClear, Virtual (March 12, 2026). Speakers: Nate Young and Aminah Rogers

“Identificación de señales de alerta y factores de riesgo de las organizaciones terroristas extranjeras (FTO): ejemplos concretos de prácticas eficaces de diligencia debida y supervisión de terceros y de la cadena de suministro.” ACI Mexico Summit on Anti-Corruption & Compliance Programs, Mexico City (Mar. 10, 2026). Speaker: Erik Woodhouse

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