The Month in International Trade—May 2026

Crowell & Moring’s International Trade Group Secures Top Rankings in Chambers USA 2026

Top Trade Developments

• USTR Proposes Sweeping Tariffs as Part of Section 301 Forced Labor Import Enforcement Investigation
• Executive Order on Strengthening Customs Enforcement
• BIS Confirms Advanced Chip License Requirements to D:5 and Macau-Headquartered Entities Worldwide
• Rough Seas for International Cartels: DOJ Indicts Four of the Largest Container Manufacturers and Executives for Price-Fixing
• Supply Chain Disruption – Again
• ATF Catches Up With Export Control Reform (Better Late Than Never!)

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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Crowell & Moring’s International Trade Group Secures Top Rankings in Chambers USA 2026

In the Chambers USA 2026 guide, Crowell & Moring trade attorneys earned seven individual rankings for six attorneys, as well as four national practice area rankings. The Chambers guide ranks the country’s top law firms and lawyers through in-depth research, client interviews, and feedback from attorneys at peer firms.

International Trade
International Trade: Customs – Nationwide*
International Trade: Export Controls & Economic Sanctions: The Elite – Nationwide
International Trade: Intellectual Property (Section 337) – Nationwide
Partner John B. Brew – International Trade: Customs – Nationwide*
Partner David Stepp – International Trade: Customs – Nationwide
Partner Jeffrey L. Snyder – International Trade: Export Controls & Economic Sanctions – Nationwide*
Partner  Dj Wolff – International Trade: Export Controls & Economic Sanctions – Nationwide
Partner  Kathryn L. Clune – International Trade: Intellectual Property (Section 337) – Nationwide

Financial Services Regulation
Partner Anand Sithian – Financial Services Regulation: Banking (Enforcement & Investigations) – Nationwide

Litigation
Partner Anand Sithian – Litigation: White-Collar Crime & Government Investigations – New York

National Security
National Security – Nationwide*
*Indicates first or second tier ranking

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Top Trade Developments

USTR Proposes Sweeping Tariffs as Part of Section 301 Forced Labor Import Enforcement Investigation

On June 2, 2026, the U.S. Trade Representative (USTR) announced a landmark set of enforcement actions under Section 301 of the Trade Act of 1974, targeting 60 economies worldwide for failing to prohibit the importation of goods produced with forced labor. This is one of the most sweeping forced labor-related trade enforcement actions in U.S. history. USTR has proposed new tariffs ranging from 10% to 12.5% on all products from these economies. Interested parties may file public comments, due by July 6, and the USTR has scheduled a public hearing on July 7 before final implementation. Companies sourcing from any of the 60 affected economies should assess exposure immediately.

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For more information, contact: David Stepp, Simeon Yerokun

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Executive Order on Strengthening Customs Enforcement

On June 3, 2026, the White House issued an Executive Order (“Strengthening Customs Enforcement”) that directs the U.S. Department of Homeland Security (“DHS”) and U.S. Customs and Border Protection (“CBP”) to take a series of actions intended to combat customs fraud, transshipment, forced labor imports, duty evasion, and other trade-related violations. While many of the directives will require future rulemaking or policy changes before becoming effective, the Order signals a significant increase in customs enforcement and scrutiny of foreign importers.

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For more information, contact: Valerie Ellis, John Brew, Brett Everett

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BIS Confirms Advanced Chip License Requirements to D:5 and Macau-Headquartered Entities Worldwide

On May 31, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance clarifying that the license requirement for advanced computing items – first established on November 17, 2023 – continues to apply to entities that are subsidiaries of companies headquartered in Country Group D:5 (i.e., “U.S. Arms Embargoed Countries”) or Macau, even when those entities operate outside of D:5 or Macau destinations. The guidance directly addresses industry confusion following BIS’s May 2025 announcement that it would not enforce the new compliance requirements introduced by the AI Diffusion Rule.

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

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Rough Seas for International Cartels: DOJ Indicts Four of the Largest Container Manufacturers and Executives for Price-Fixing

Last month, the U.S. Department of Justice (DOJ) Antitrust Division (the Division) revealed criminal charges against China International Marine Containers (Group) Co., Ltd. (CIMC) and several other major Chinese companies and executives involved in the manufacture and sale of standard dry shipping containers, which are used for shipping dry, unrefrigerated cargo on ships around the world. One of the executives was arrested at an airport in France and is awaiting extradition to the U.S. The indictment charged these defendants with violating Section 1 of the Sherman Act by conspiring to restrict output and fix prices of standard dry containers, including in the U.S. market, from 2019 to 2024.

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For more information, contact: Daniel Zelenko, Megan Wolf, Jessica Franzetti, Samuel Blackington

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Supply Chain Disruption – Again

Businesses affected by the Strait of Hormuz crisis are likely to be navigating both sides of the contractual liability equation: seeking to enforce protections while simultaneously trying to limit their own exposure. This balancing act will feel familiar to those who managed supply chain disruptions during the Covid pandemic or in response to Russian sanctions. But the scale of uncertainty and the severity of the current situation make it particularly challenging to chart a clear path forward. This note provides an overview of the English-law issues that have arisen in this current crisis and is relevant for companies and legal counsel seeking to understand and mitigate contractual risk in their supply chains, including for shipping, energy, commodities, and construction.

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For more information, contact: Meagan Bachman, Nicola Phillips, Lauren Blanchard

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ATF Catches Up With Export Control Reform (Better Late Than Never!)

On May 6, 2026, the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”) published a final confirmatory rule updating its regulations to reflect changes stemming from the ECR initiative. The rule adds references to the U.S. Department of Commerce (“Commerce”) alongside existing references to the U.S. Department of State (“State”), acknowledging what has been true for several years: both agencies share jurisdiction over defense articles on ATF’s USMIL.

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

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Crowell Speaks

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

ACSS New York Chapter Event “Renewed Focus on Cartels, Transnational Criminal Organizations, and Foreign Terrorist Organizations: Compliance Challenges for Financial Institutions and Multinationals.” New York (June 4, 2026). Panelist: Caroline Brown

Recent Trends in U.S. Trade Remedy Measures and Strategic for Korean Exporters: Renewed Anti-Dumping and Countervailing Duty Risks in the New Tariff Environment (Korean)
June 1, 2026 - Weekly Customs and Tariff Insights (Korean), vol.2181/ Korea Customs and Trade Development Institute

“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

Importers weigh lawsuits as Trump’s 10% global tariff faces appeal
May 13, 2026 – Supply Chain Drive

“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

The World Needs a Hormuz Fertilizer Initiative Now
May 2, 2026 - The Hill

Trump Likes the Idea of the Government Owning Some US Companies but Took a Pass on Spirit Airlines
May 2, 2026 – Associated Press