The Month in International Trade – September 2026

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Top Trade Developments

U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows 

On September 24, 2026, Treasury Secretary Scott Bessent announced that the United States and China agreed to extend their trade truce through January 10, 2027, two months beyond the original timeline established last November. The extension correspondingly pushes back the effective date of the BIS Affiliates Rule, which had been scheduled to go back into effect on November 9, 2026. As of the date of this writing, BIS has not yet published a Federal Register notice formally extending the suspension by two months. 

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

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State Department Issues Two New Rules Amending the ITAR 

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. 

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For more information, contact: Scott Wise, Chandler Leonard, Edward Goetz 

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OFAC Creates Unified Sanctions Penalties Regulations 

Until now, rules and guidance relating to civil and criminal penalties for violations of the International Emergency Economic Powers Act (“IEEPA”) and the United Nations Participation Act (“UNPA”) have been spread across more than 40 different sanctions program regulations, OFAC’s Enforcement Guidelines at Appendix A to 31 C.F.R. Part 501, and the text of the statutes themselves. In its new Sanctions Penalties Regulations, OFAC is now consolidating penalty provisions and authorities that were previously scattered across individual program-specific rules, and codifying certain existing OFAC practices in the Rule. 

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For more information, contact: Carlton Greene, Nate Young 

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The Lindsey Graham Sanctions Act: What Businesses Need to Know About the New Tariffs 

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. 

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For more information, contact: Dan Cannistra 

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Commerce Initiates AD/CVD Investigations on Linear Hydraulic Cylinders as Petitioners Press for Broad Scope 

The U.S. Department of Commerce has initiated antidumping (“AD”) and countervailing duty (“CVD”) investigations of Linear Hydraulic Cylinders and Parts Thereof from Canada, China, India, Mexico, and South Korea, effective September 8, 2026. The AD investigations cover imports from all five countries, while the CVD investigations cover imports from China, India, and Mexico. 

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For more information, contact: Dan Cannistra, Alex Schaefer, Pierce Lee 

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CBP Issues Notice of Rulemaking on Executive Order 14411, “Strengthening Customs Enforcement” 

U.S. Customs and Border Protection (“CBP”) is considering amending its regulations to require new disclosures designed to give the agency greater visibility into the supply chains of goods imported into the United States. The proposals target three areas: 1. enhanced identification of parties involved in importation; 2. integration of technical tracing solutions; and 3. collection of foreign export documentation.  Crowell is available to provide support to clients in preparing responses to CBP’s ANPRM, in advance of CBP’s deadline on December 1, 2026. 

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For more information, contact: John Brew, Aaron Marx, Nate Young

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Crowell Speaks 

“The Digital Assets Regulatory Reset: What Has Changed, What Has Not, and What Legal and Compliance Teams Need to Watch,” Digital Assets: Compliance, Enforcement & Regulatory Oversight, New York (November 17, 2026). Moderator: Anand Sithian

Compliance Conference 2026, New York City Bar Association, New York (October 20, 2026). Speaker: Carlton Greene 

“IEEPA 2.0: Navigating the Current U.S. Tariff Landscape,” Retail Law Conference, Kansas City (October 14, 2026). Speakers: John Brew and Dan Campbell 

“Section 301 Forced Labor Investigations: UFLPA Overlap and What Companies Should Do Now,” 15th Advanced Forum on U.S. Customs Compliance & Enforcement, Washington, D.C. (October 8, 2026). Speaker: John Brew 

President Trump signs new sanctions on Russia
September 18, 2026 – BBC
Related Professional: Erik Woodhouse 

“Export Controls Beyond Goods: Understanding How Services & Technology Can Trigger Export Controls,” Trademo Webinar (September 17, 2026). Speaker: Jeremy Iloulian  

Kalshi’s Drug Trial Bets Raise Alarm Over Ethics, Insider Trades.
September 16, 2026 – Bloomberg Law
Related Professional: Anand Sithian 

“Trade, Tariffs, and Supply Chain,” 4th Annual Midwest Government Contracts Seminar, Chicago (September 16, 2026). Speakers: John Brew and Weronika Bukowski  

“Government Contracts and International Trade M&A,” 4th Annual Midwest Government Contracts Seminar, Chicago (September 16, 2026). Speakers: Michael Samuels, Christian Curran, Jeremy Iloulian, and Riley Delfeld  

“On the Banned List: What the FCC’s Expanding Covered List Means for Your Business,” Crowell Webinar (September 15, 2026). Speakers: Caroline Brown and Rajeev Raghavan 

“EU Forced Labor Regulation & Comparative Analysis with the US & UK Regimes,” ICPA Fall Europe Conference, Glasgow (September 9, 2026). Speaker: Vassilis (Vass) Akritidis 

“When the Chips are Down: Europe’s Stake in the Global Chip War,” ISA International Conference, Oxford (September 4, 2026).  Speakers: Monica Gorman 

“The Geopolitics of Industrial Policy: A Fireside Chat with Lord William Hague and Dr. Monica Gorman,” ISA International Conference, Oxford (September 3, 2026).  Speakers: Monica Gorman