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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.
Chambers Ranks Crowell & Moring International Trade Practice and Lawyers in 2026 Global Guide
Washington – February 24, 2026: Chambers and Partners has ranked Crowell & Moring’s International Trade practice group and six inpidual lawyers in the Chambers Global 2026 guide.
The Chambers Global Guide ranks lawyers and law firms in over 200 jurisdictions worldwide. Through in-depth interviews with lawyers and their clients, researchers selected honorees based on client satisfaction, professional ability, and reputation.
International Trade
International Trade: Customs – USA*
International Trade: Export Controls & Economic Sanctions: The Elite – USA
International Trade: Intellectual Property (Section 337) – USA
International Trade/WTO – Europe-Wide
Partner Vassilis Akritidis – International Trade/WTO – Europe-Wide
Partner John Brew – International Trade: Customs – USA*
Partner David Stepp – International Trade: Customs – USA
Partner Dj Wolff – International Trade: Export Controls & Economic Sanctions – USA
Partner Jeffrey Snyder – International Trade: Export Controls & Economic Sanctions – USA*
Partner Kathryn Clune – International Trade: Intellectual Property (Section 337) – USA
* Indicates first or second tier ranking
Top Trade Developments
SCOTUS Holds IEEPA Tariffs Unlawful
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.
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For more information, contact: Daniel W. Wolff, John Brew, Weronika Bukowski, Sibilla Grenon
UK Government Seeks Evidence on Ownership and Control in Financial Sanctions Regulations
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.
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For more information, contact: Sophie Davis, Nicola Phillips, Dj Wolff
BIS Fines Teledyne FLIR $1 Million for Unlicensed China-Related Thermal Camera Exports and De Minimis Miscalculations
On February 26, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) reached an administrative enforcement settlement with Teledyne FLIR LLC and its affiliates FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems, Inc. d/b/a Teledyne FLIR OEM, (together, “Teledyne FLIR”), imposing a $1,000,000 civil penalty to resolve alleged violations of the Export Administration Regulations (“EAR”).
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For more information, contact: Scott Wise, Jeremy Iloulian, Chandler Leonard, Nate Young
EU Amendments to List of High-Risk AML/CTF Countries
The European Commission maintains a list of third countries that are deemed to present a significant risk to the stability of the EU financial system due to weak financial controls and governance frameworks for anti-money laundering (“AML”) and counter-terrorism financing (“CTF”). EU member states must impose requirements for enhanced due diligence (“EDD”), strict monitoring measures, and mandatory reporting of suspected offences by regulated entities, including financial institutions (“obliged entities”) within these jurisdictions.
In early December 2025, the Commission adopted two regulations amending its list of third countries, adding Bolivia, the British Virgin Islands, and the Russian Federation to the list, whilst removing Burkina Faso, Mali, Mozambique, Nigeria, South Africa, and Tanzania. The regulations entered into force on 29 January 2026. The updated EU list of countries with deficient AML and CTF regimes is available here.
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For more information, contact: Carlton Greene, Nicola Phillips, Liesbeth Truyens
Treasury Seeks Public Input on CFIUS Known Investor Program and Streamlining of Foreign Investment Reviews
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.
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For more information, contact: Caroline Brown, Addie Cliffe, Chandler Leonard, Nimrah Najeeb, Allison Skager, Nate Young
OFAC Launches New Online Voluntary Self-Disclosure Portal
On February 6, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) announced the launch of a new online Voluntary Self-Disclosure (VSD) Portal (the “New Portal”) intended to replace and reduce reliance on ad hoc submission methods with a more secure channel for reporting to OFAC potential sanctions violations. OFAC states that moving disclosures into the New Portal should improve process visibility for disclosing parties, including faster acknowledgment and clearer communication during OFAC’s review. Of note, “OFAC strongly encourages parties to begin submitting voluntary self-disclosures through” the New Portal.
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For more information, contact: Anand Sithian, Jeremy Iloulian, Nate Young, Dmitry Bergoltsev
CBP Launches New Forced Labor Portal
On January 21, 2026, U.S. Customs and Border Protection (“CBP”) announced that its Forced Labor Portal is now live. This new online portal provides a single, centralized platform for importers to submit requests for review when their shipments are detained or excluded due to forced labor enforcement actions. By consolidating what was previously a patchwork of email and paper submission processes, the portal is intended to streamline communications and ensure that all forced labor-related documentation reaches the appropriate CBP officials for timely review.
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For more information, contact: Simeon Yerokun, Pierfilippo Natta, Ani Mard, Andrew Schlegel
Crowell Webinars
Securing Rights to IEEPA Tariff Refunds
Join Crowell’s International Trade attorneys for an update in the wake of the Supreme Court’s holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs during peacetime national emergencies. In this webinar, our attorneys will provide advice on affirmative steps importers should take to preserve rights to refunds and answer your questions about the litigation and the Supreme Court’s decision.
Speakers: Dan Cannistra, Daniel W. Wolff, Aaron Marx, Alex Schaefer, Maria Vanikiotis, Weronika Bukowski
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Navigating the EU’s New Economic Security Strategy and Countermeasures: Implications for Global and EU Businesses
In collaboration with the IBJ-IJE
Join Crowell’s international trade attorneys for an in-depth analysis of the EU’s new economic security strategy and its practical impact on businesses operating in the region.
Key Topics:
- EU Trade Countermeasures: Gain insight into the EU’s strategy on trade disputes, how a procedure under the EU Anti-Coercion Instrument works, and the type of trade countermeasures you can expect.
- Regulatory Updates: Explore changes in economic security regulations at the EU and Belgian levels—including the latest developments in export controls and sanctions.
- Economic Security & Trade Defence: Understand how shifting priorities in economic security are shaping EU trade defence and customs law.
This session is designed for in-house counsels and business leaders who need to stay ahead of rapidly evolving international trade regulations. Participants will receive actionable guidance to help navigate the complexities of the new EU economic security landscape.
Speakers: Vassilis Akritidis, Liesbeth Truyens, Jean-Baptiste Blancardi
Crowell Speaks
“The New War on Drugs: Cartels, and Transnational Criminal Organizations,” Association of Certified Sanctions Specialists (ACSS) Annual US Conference on Global Sanctions and Export Controls, Washington DC (Apr. 16, 2026). Speaker: Caroline Brown
“The After-Action Review of Recent Sanctions and Export Controls Enforcement Actions,” Association of Certified Sanctions Specialists (ACSS) Annual US Conference on Global Sanctions and Export Controls, Washington DC (Apr. 16, 2026). Speaker: Anand Sithian
“Hot Topics and Breaking News,” University of Illinois Chicago School of Law 24th Annual Dominick L. DiCarlo U.S. Court of International Trade Lecture, Virtual (Apr. 9, 2026). Speaker: John Brew
“Identificación de señales de alerta y factores de riesgo de las organizaciones terroristas extranjeras (FTO): ejemplos concretos de prácticas eficaces de diligencia debida y supervisión de terceros y de la cadena de suministro.” ACI Mexico Summit on Anti-Corruption & Compliance Programs, Mexico City (Mar. 10, 2026). Speaker: Erik Woodhouse
“Latest IEEPA Tariff Updates,” Retail Industry Leaders Association/Retail Litigation Center Spring 2026 Legal Meetings, Washington, DC (Mar, 3, 2026). Speaker: John Brew
“Opening or Closing Gates? Market Access in Global Infrastructure Construction: Between Openness and Strategic Protection,” Inter-Pacific Bar Association (IPBA) Annual Meeting and Conference, New Delhi (Feb. 27, 2026). Speaker: Jeremy Iloulian
“National Security and Business,” 31st Annual National Security Law Conference, Duke Law School, Durham, NC (Feb. 27, 2026). Speaker: Caroline Brown
“Remote Worker Fraud: Balancing Company Security Measures with Anti-Discrimination Obligations When Hiring,” Barbri, Virtual (Feb. 26, 2026). Speaker: Caroline Brown
Shadow tanker plausibly reverts to compliant trade after Venezuela loading
February 25, 2026 – Lloyd’s List
Related Professional: Dj Wolff
Why Asian firms are not cheering Trump tariff ruling
February 25, 2026 – BBC News
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February 23, 2026 - Managed Healthcare Executive
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SCOTUS rules Trump’s tariffs are illegal – but the fight is far from over
February 20, 2026 – The Verge
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Trade Expert Breaks Down Supreme Court’s ‘Landmark’ 6-3 Ruling That Struck Down Trump’s Tariffs
February 20, 2026 – Forbes Breaking News
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Supreme Court Ruling Could Undermine Trump’s Trade Negotiations
February 20, 2026 – Times News (London)
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Supreme Court Ruling ‘Massive Setback For Trump’, As He Announces 10% Global Tariff
February 20, 2026 – Times News (London)
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FinCEN Opens Online Portal For Whistleblower Tips
February 16, 2026 – Law360
Related Professional: Anand Sithian
Inside one company’s $173m response to forced labor allegations
February 16, 2026 – Global Investigations Review
Related Professionals: David Stepp, Simeon Yerokun, Laurel Saito
Today’s China Crucible: What It Means for Pharma
February 11, 2026 - Pharmaceutical Executive
Related Professional: Geralyn Ritter and Monica Gorman
Syrian trade surges nearly sixfold a year after government takeover
February 3, 2026 – Lloyd’s List
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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