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ARTICLE · 08 OCTOBER 2026

National Security Regulation & Investment Risk: Quarterly Update From Washington

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National security regulation is evolving with expanded sanctions authorities, new CFIUS resources, and heightened enforcement across export controls and anti-corruption. Companies face broader FOCI review requirements, stricter Iran and Cuba sanctions, and increased scrutiny of indirect channels and third-party relationships in compliance programs.

GlobalGovernment, Public Sector
Hrishi N. Hari
Hrishi N. Hari
Shannon Reaves
Shannon Reaves
Betsy Feuerstein
Betsy Feuerstein
Daniel Kim
Daniel Kim
Marston Ho-Ming Li
Marston Ho-Ming Li

Key Takeaways

  • National security regulation is broadening, but not uniformly. This quarter combined expanded sanctions authorities and a proposed extension of FOCI review with targeted regulatory relief and efforts to make investment-security processes more efficient. The existing outbound investment rules remain operative while Treasury develops regulations implementing the COINS Act, but recent White House policy statements expressly contemplate broader restrictions.
  • Companies should prepare for the possible implementation of BIS’s Affiliates Rule, scheduled to enter into effect on November 10, 2026, while monitoring whether BIS extends the current suspension. Recent reports suggest the Rule may be suspended for two additional months (until January 10, 2027).

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