Insights

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued six new general licenses, and updated a seventh that allow for many activities related to: the export of Venezuelan oil and petrochemical products from Venezuela; the exploration, development, and production of oil, gas, and petrochemical products in Venezuela; the generation, transmission, storage, or distribution of electricity in Venezuela; the export to Venezuela of U.S.-origin diluents; negotiating for investment in the oil, gas, petrochemical, and electricity sectors in Venezuela; and the export of Venezuelan gold.

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

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.

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.

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.

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

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.

On December 19, 2025, the Department of Justice (DOJ) announced a $54.4 million settlement with Ceratizit USA, LLC, a distributor of tungsten carbide products, resolving allegations that the company violated the False Claims Act (FCA) by evading customs duties on products imported from China. This settlement is believed to be the largest ever customs-related FCA resolution, and this high-water mark underscores the government’s heightened enforcement focus on tariff evasion.

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.

On November 12, 2025, Judge King in the U.S. District Court for the Western District of Washington granted in part Haldiram India Ltd.’s (“Plaintiff” or “Haldiram”) motion for a preliminary injunction against Punjab Trading, Inc. (“Defendant” or “Punjab Trading”), a seller alleged to be importing and distributing gray market snack food products not authorized for sale in the United States. The court found that Haldiram was likely to succeed on the merits of its trademark infringement claim because the products at issue, which were intended for sale in India, were materially different from the versions intended for sale in the U.S., and for this reason were not genuine products when sold in the U.S. Although the court narrowed certain overbroad provisions in the requested order, it ultimately enjoined Punjab Trading from importing, selling, or assisting others in selling the non-genuine Haldiram products in the U.S. market.

Yesterday, the Supreme Court of the United States heard oral argument in the consolidated case challenging the use of the International Emergency Economic Powers Act (“IEEPA”) to justify sweeping import tariffs. At issue is whether IEEPA authorizes the President, upon declaring a national emergency, to impose tariffs and, if so, whether that delegation is constitutionally permissible.

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.

The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions the past month, including the Trump Administration’s first sanctions directly imposed on Russia. These coordinated actions—which particularly target the Russian energy sector—indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those sanctions.

In June 2025, the European Commission adopted its first-ever measures under the International Procurement Instrument Regulation (IPI), restricting access to the EU public procurement market for medical devices for economic operators and medical devices from the People’s Republic of China. This is the first application of the IPI, a new trade instrument aimed at tackling lack of reciprocity in access to public procurement in third countries.

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes.

On August 28, 2025, France, Germany, and the UK (the E3) initiated the process to reinstate (or snapback) UN sanctions on Iran. The snapback mechanism (which was set to expire on October 18, 2025) is outlined in UN Security Council Resolution 2231 (UNSCR 2231).

U.S. Government and private sector sources continue to report efforts by Democratic People’s Republic of Korea (DPRK) nationals to infiltrate companies around the world by posing as information technology (IT) professionals, in order to get hired by U.S. and other businesses and gain access to sensitive company systems. Crowdstrike, a U.S. cybersecurity company, has reported a 220% increase in the number of companies infiltrated by North Korean threat actors over the last 12 months. In particular, a DPRK-affiliated group known as “Famous Chollima” has leveraged artificial intelligence and deepfake technology to generate synthetic identities, as well as resumes and CVs, draft communications, and conduct job interviews. Enforcement actions brought by the U.S. Department of Justice identify victims in the cryptocurrency sector, including decentralized finance (“DeFi”) projects. In addition, media reports indicate that North Korean hackers are purportedly offering fake job offers targeting employees in the cryptocurrency sector, with the goal of stealing crypto.

On August 28, the U.S. Department of Commerce Bureau of Industry and Security (BIS) published a final rule that modifies the Export Administration Regulations (EAR) to reduce the number of export control restrictions on Syria, in alignment with Executive Order 14312, Providing For The Revocation of Syria Sanctions. The key adjustments made by this rule include the addition of new or expanded license exception eligibility for exports and reexports to Syria (which significantly broadens the number of items that can be exported or reexported to Syria) and the adoption of more permissive license review policies for exports and reexports to Syria.

The Best Lawyers in America 2026 Recognizes 43 Crowell & Moring Attorneys, One Selected as Lawyer of the Year