Red Notice - November 2016

President Trump has signed into law the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, dramatically expanding U.S. sanctions on Russia's financial and energy sectors while establishing unprecedented tariff authorities on Russian goods and imports from countries purchasing Russian energy.

The Trump administration's Venezuela oil deal and expanded General Licenses have opened unprecedented opportunities for multinationals to invest in Venezuela's energy, mining, and telecommunications sectors, while simultaneously launching "Operation Economic Outcast" to impose crushing economic pressure on Iran.

On September 18, 2026, President Donald Trump signed into law the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 (Act), a significant package of sanctions, trade restrictions and related measures...

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.

The U.S. Department of Commerce's Bureau of Industry and Security issued guidance on May 31, 2026, clarifying licensing requirements for advanced computing items and AI technologies. The guidance maintains export restrictions for entities in certain countries while providing limited relief for data center operators, though questions remain about future regulatory direction. Companies must now strengthen their compliance programs and supply-chain due diligence as BIS continues to prioritize national security

The U.S.-Canada trading relationship has reached a critical juncture as both nations implement escalating trade measures, with Canada's counter-tariffs taking effect and the United States responding with unprecedented import bans on Canadian alcoholic beverages, dairy products, and motorcycles. These actions mark a significant expansion of the Trump Administration's use of Section 338 of the Tariff Act of 1930, moving beyond additional tariffs to outright import restrictions. What does this escalation mean

U.S. Customs and Border Protection has begun processing IEEPA tariff refunds through its CAPE system, but Phase III covering finally liquidated entries faces delays and requires court orders. With the Department of Justice appealing the universal refund order and class certification pending, importers with finally liquidated entries may need to file individual lawsuits at the Court of International Trade to preserve their claims before statutory deadlines expire.

The U.S. House of Representatives has passed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, which directs the President to impose tariffs of up to 500 percent on Russian imports and up to 100 percent on imports from countries that are significant purchasers of Russian energy. The bill includes provisions for Presidential waiver authority and a five-year sunset clause...

U.S. Customs and Border Protection has announced that importers with court orders for IEEPA duty refunds on finally liquidated entries can begin filing for those refunds starting October 6, 2026, through the CAPE Phase 3 system. This development follows the Supreme Court's February 2026 decision striking down IEEPA tariffs and represents a critical step for importers seeking refunds on entries liquidated for more than 80 days.

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, introducing unprecedented tariff authority that could impose duties up to 100% on goods from countries purchasing Russian energy or facilitating sanctions evasion. The legislation creates a novel framework where tariffs stack on top of existing duties while codifying Russia sanctions into statute...

On July 22, 2026, the Federal Communications Commission (FCC or Commission) adopted a Third Report and Order and Third Further Notice of Proposed Rulemaking (covered separately here) in which the Commission advances its ongoing efforts to secure the U.S.

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, introducing unprecedented tariff authority that could impose duties up to 100% on goods from countries purchasing Russian energy or facilitating sanctions evasion. The legislation creates a novel framework where tariffs stack on top of existing duties while codifying Russia sanctions into statute...

California's Legislature has unanimously passed SB 690, a landmark reform that could eliminate thousands of pending class action lawsuits based on website tracking technologies under the California Invasion of Privacy Act. The bill removes the private right of action for pen register claims arising from routine web analytics tools, potentially reshaping the data privacy litigation landscape while companion bills simultaneously expand substantive privacy obligations.

On September 16, 2026, President Trump issued a presidential memorandum titled “Restoring Reciprocity in Government Procurement”, directing the Director of the Office of Management and Budget and the United States Trade Representative, in coordination with the Federal Acquisition Regulatory Council, to identify and take legally permitted steps to remove or restrict Canadian-origin items across the federal civil procurement system.

On August 25, 2026, the U.S. Department of Justice (DOJ or the Department) announced a $21.5 million settlement with Deloitte LLP and four affiliated entities (collectively, Deloitte), marking the second False Claims Act (FCA) settlement under the Department’s Civil Rights Fraud Initiative launched in May 2025.

The SEC's Division of Examinations has identified six critical areas where investment advisers commonly fall short in their annual compliance reviews, from timing failures to inadequate documentation and unimplemented corrective actions. Understanding these deficiencies is essential for advisers seeking to strengthen their compliance infrastructure and avoid examination risks.

The Trump administration has issued an executive order requiring enhanced interagency coordination and stricter oversight of the H-1B nonimmigrant visa program. Federal agencies must now review employers' workforce practices, including past and planned layoffs of U.S. workers, while strengthening enforcement mechanisms to prevent program abuse.

The Protect College Sports Act of 2026 (PCSA), introduced in the Senate on June 2, 2026, by Senators Ted Cruz (R-TX) and Maria Cantwell (D-WA) and joined by Senators Eric Schmitt (R-MO) and Chris Coons (D-DE), represents a comprehensive federal legislative effort to reshape the governance and economics of intercollegiate athletics...

Last week, the Trump administration and federal agencies announced several initiatives related to artificial intelligence (AI).

Unlocking Part 15 Spectrum for D2D: The FCC adopted an NPRM exploring rule changes to allow devices operating under Part 15 unlicensed rules (such as Wi-Fi and Bluetooth) to communicate directly with authorized satellites.