Worldwide: Export Controls & Trade & Investment Sanctions

German technology giant Robert Bosch GmbH has become the first company to receive a declination under the Department of Justice's new criminal corporate enforcement policy after voluntarily disclosing export control violations involving sanctioned Chinese company Huawei. The case involved over $70 million in sensor products and software reexported to Huawei entities on the BIS Entity List, resulting in a $36 million settlement but avoiding criminal prosecution. This landmark resolution demonstrates how volu

Richard Montes de Oca and Jillian Cash explore how the Committee on Foreign Investment in the United States (CFIUS) and international trade tariffs intersect to shape strategic decision-making for companies operating in today's complex global marketplace. Their analysis examines the regulatory frameworks that businesses must navigate when engaging in cross-border transactions and international commerce.

The U.S. Senate's proposed National Defense Authorization Act for Fiscal Year 2027 introduces a two-phase ban on adversary-nation connected vehicles at military installations, building on existing Commerce Department regulations. This measure reflects Congress's growing focus on preventing foreign-linked automotive technology from accessing sensitive defense infrastructure and collecting data on military operations.

On June 17, 2026, the Department of Justice (DOJ) made a significant announcement by issuing its first declination of prosecution under the Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP).

On June 23, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on various individuals and entities associated with the Prince Group pursuant to Executive Order (“E.O.”) 13581, as amended by E.O. 13863.

The Trump Administration has issued a temporary general license authorizing certain transactions involving Iranian energy products following the Islamabad Memorandum of Understanding. While this represents a significant shift in US sanctions policy, companies face complex legal risks including potential terrorism-related liability, ambiguous guidance, and the possibility of swift policy reversal within the 60-day authorization window.

The U.S. Government has escalated its challenge to the Court of International Trade's authority regarding IEEPA tariff refunds, filing an appeal with the Federal Circuit. This legal battle centers on whether courts can order the return of tariff payments for entries that have been finally liquidated for more than 90 days, with significant implications for multinational companies that paid these tariffs.

On June 22, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Iran General License X (GL X), titled “Authorizing the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian-Origin through August 21, 2026.”

Export control regimes define how defense technologies move across borders and who can invest in them.