OFAC Issues General License On Authorized Transactions With Iran-Related Entity

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.

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.

On January 12, 2026, President Trump announced via Truth Social: "[e]ffective immediately, any Country doing business with the Islamic Republic of Iran will pay...

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...

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.

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 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.

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 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.

FinCEN notified U.S. financial institutions that the Financial Action Task Force ("FATF") updated the list of jurisdictions with strategic deficiencies in combating anti-money laundering and countering the financing of terrorism ("AML/CFT").

The Health Resources and Services Administration has announced a revised 340B Rebate Model Pilot Program for drugs subject to Medicare's Maximum Fair Price, expanding eligibility to manufacturers with selected drugs for 2026 and 2027. The program introduces new data requirements, dispute resolution mechanisms, and stricter compliance monitoring while addressing stakeholder concerns about administrative burden and program integrity.

The Surface Transportation Board has lifted its abeyance and established a procedural roadmap for the Union Pacific and Norfolk Southern merger proceeding, marking the official start...

Landlords of rent stabilized buildings in New York City have filed a lawsuit challenging the rent freeze passed by the Rent Guidelines Board, questioning the Board's independence and data integrity. With operating costs rising 31% over five years while the Board voted 7-1 for a freeze affecting 1 million apartments, the case raises critical questions about the balance between tenant protection and landlord viability.

The SEC has issued a groundbreaking Innovation Exemption order that creates a five-year regulatory framework for trading tokenized versions of major U.S. exchange-listed stocks. This temporary relief exempts certain digital asset venues and liquidity providers from traditional securities regulations, establishing permissioned environments for on-chain secondary markets while maintaining investor protections.

On February 25, 2026, the Office of the Comptroller of the Currency (the "OCC") issued a Notice of Proposed Rulemaking (the "NPRM") to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the "GENIUS Act").

The Treasury Department and IRS have proposed new regulations that would establish an explicit racial nondiscrimination requirement for private schools seeking federal tax exemption under Section 501(c)(3). These proposed rules go beyond existing law by prohibiting all forms of racial discrimination in education regardless of intent, legality, or purpose, potentially affecting admissions policies, scholarship programs, and other school-administered initiatives.

This September 2026 edition of Quorum examines critical developments in corporate governance, M&A transactions, and securities regulation, including Delaware Court decisions on strategic investor rights and control group standards, new SEC guidance on beneficial ownership reporting, and Supreme Court rulings on disgorgement remedies. The newsletter also analyzes FTC perspectives on vertical mergers in defense sectors and provides comprehensive updates on the SEC's 2026 regulatory agenda under Chairman Atkin

California's Air Resources Board has released comprehensive guidance for entities preparing their first greenhouse gas emissions reports under SB 253, introducing a voluntary reporting platform and clarifying expectations for the November 2026 deadline. The guidance addresses critical questions about data collection requirements, assurance standards, and enforcement discretion for companies that weren't tracking emissions as of December 2024. Understanding these reporting parameters and submission options w

An investment management firm founded and owned by legendary investor (and New York Mets owner) Steve Cohen on August 11 filed a petition in Tax Court contesting an IRS audit adjustment...