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A presidential memorandum signed September 16, 2026 extends the administration's September 8 direction to strip Canadian-origin goods from the entire federal civil procurement system, instructing OMB, USTR and the FAR Council to take steps "permitted by applicable law" and notify agencies of domestic alternatives. Nothing is excluded yet: Canadian end products remain eligible until implementing action, and the civilian scope excludes Department of War procurements, which sit under a separate reciprocal defense procurement understanding.

The mechanics are unresolved. The most plausible vehicle is USTR delisting Canada as a Trade Agreements Act designated country, which would bar Canadian end products above TAA thresholds rather than merely trigger a Buy American price penalty, and would require modifications to existing contracts. GSA MAS Refresh 33, pushed from September to October, is the near-term indicator of how aggressive the removal will be.

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President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 on September 18, 2026, moving much of the US Russia sanctions framework from executive order into statute and making many designations mandatory, with an initial presidential review due within 30 days (on or before October 18, 2026). New mandatory measures cover Russian government-owned or affiliated entities, "oligarchs" who have not opposed the war, transferees of their assets, vessel providers, shadow-fleet owners, insurers, servicers and permissive foreign ports, and messaging entities used to circumvent sanctions. The Act also codifies investment, services and sovereign-debt restrictions, directs the SEC to delist Russian government-affiliated issuers, mandates the Russian uranium import ban and Rosatom leadership sanctions, and extends the Iran Sanctions Act five years.

For counsel, note that pre-enactment general licenses survive (§ 114(h)), but reliance must be tested against each designation authority, and the president retains broad § 115 waiver power on national-interest certification.

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Evonik Corporation and Huntsman International LLC have filed a petition with the U.S. Commerce Department and the International Trade Commission seeking antidumping and countervailing duties on specific amine compounds imported from China. The scope includes defined organic amines used as polyurethane catalysts, identified by CAS numbers and HTSUS subheadings. Petitioners allege dumping margins of 261‑476% and claim Chinese subsidies exceed de minimis levels. The investigation schedule calls for DOC initiation on October 19 2026, ITC preliminary questionnaires by October 13, hearings in late October, and preliminary DOC determinations from December 2026 through March 2027, with final decisions expected by mid-2027. For sophisticated counsel and corporate clients in chemicals, manufacturing, and supply-chain management, the case raises material risk exposure, potential duty liabilities, and compliance deadlines that could reshape import costs. Stakeholders should monitor the scope definition, possible duty rates, and opportunities to submit comments or request hearings. The petition u

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On September 21, 2026, California Governor Gavin Newsom signed seven data center bills that primarily take effect on January 1, 2027, according to Foley & Lardner. Reported subject matter spans new tariff provisions, entitlement rules and disclosure obligations, with hyperscale cloud operators, data center developers and electric power producers all implicated.

The significance is structural rather than incremental. Data center load growth is forcing the question of who pays for the generation, transmission and distribution capacity it consumes, and a seven-bill package signals a settled legislative position rather than a single isolated mandate. Rate design, cost allocation and disclosure duties touching hyperscalers will ripple through utility commission proceedings, power purchase agreements, site selection and project financing, and the compliance posture of developers whose economics were underwritten under the prior regime.

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The US Federal Communications Commission (FCC) is expanding its "Covered List," a key national security tool that blocks market access for communications equipment deemed to pose an unacceptable risk. Recent additions have moved beyond targeting specific companies to banning broad categories of technology—including drones, consumer routers, advanced robotics, and power inverters—based on their country of production. This shift means equipment can be blocked from receiving the FCC authorization required for US importation and sale, regardless of the manufacturer's nationality. The restrictions impact any company with global manufacturing, including US-headquartered firms producing abroad. Furthermore, the FCC is now scrutinizing internal components, demanding unprecedented visibility deep into supply chains. While a "conditional approval" process offers a potential exemption, it requires extensive disclosure of corporate structure and manufacturing details. Companies that import, make, or use connected devices must now urgently assess their supply-chain vulnerabilities as the governme

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The Committee on Foreign Investment in the United States (CFIUS) has released its annual report for calendar year 2025, revealing critical trends for cross-border transactions. While total filings increased moderately, the data shows a significant strategic shift for dealmakers. Short-form "declarations" grew in popularity, but their clearance rate dropped to an all-time low of 66%, down from 78% the prior year. Consequently, a higher percentage of parties (26%) who filed declarations were later required to submit a more extensive full "notice," lengthening their review timelines. The report also shows a continued, albeit reduced, use of mitigation agreements and sustained scrutiny of non-notified transactions, with CFIUS requesting filings for nine such deals after identifying them. For deal counsel, the declining success rate of declarations complicates filing strategy, requiring a more nuanced risk assessment between the faster, but increasingly uncertain, short-form process and the more laborious full notice. The data suggests that despite stated policy goals of streamlining alli

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Several African nations, including the Democratic Republic of the Congo, Mali, Zambia, and Ghana, are increasingly asserting sovereign control over their natural resources, particularly minerals critical for the global energy transition. This wave of 'resource nationalism' includes measures such as increasing royalty rates and taxes, mandating higher state or local shareholdings in mining projects, banning the export of unprocessed minerals to force domestic refining, and, in some cases, cancelling licenses and nationalizing assets.

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The US International Trade Commission (ITC) has opened a public comment period to guide the revival of its reporting duties under Section 338 of the Tariff Act of 1930. This follows the executive branch's recent and novel use of Section 338 to impose tariffs and import exclusions on Canadian products, alleging discriminatory trade practices against US alcoholic beverages, dairy, and motor vehicles. The statute empowers the president to retaliate against countries that burden US commerce.

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