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The U.S. Federal Communications Commission (FCC) on July 28, 2026, added foreign-produced "advanced robotic devices" to its Covered List, a roster of equipment deemed to pose an unacceptable national security risk. Under the Secure and Trusted Communications Networks Act, listed equipment cannot receive FCC authorization, effectively barring new or modified models from being imported or sold in the U.S. The action, widely seen as targeting Chinese technology, follows similar prohibitions on drones, routers, and power inverters.

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Mexico's executive branch has introduced a bill to establish a formal national security screening process for foreign direct investment (FDI), modeled on the CFIUS regime in the United States. If enacted, the law would create a mandatory, suspensory pre-closing filing for foreign acquisitions of more than 49% equity in Mexican companies operating in broadly defined "sensitive sectors" including critical technology, energy, and strategic infrastructure.

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The IMO's proposed Net-Zero Framework would set mandatory GHG limits and emissions pricing across international shipping, with Tier 1 penalties of $100 and Tier 2 penalties of $380 per tonne of CO2 equivalent for non-compliant fleets. FMC Chairman DiBella has publicly questioned whether the resulting costs on U.S. cargo would be inflationary and whether the regime would displace existing systems like the EU ETS. She has gone further, suggesting the framework could itself become the subject of an FMC investigation. Under 46 U.S.C. §§ 42101-42109 and 46 C.F.R. Part 550, the FMC can probe foreign laws, regulations, or carrier practices that create conditions unfavorable to U.S. foreign commerce, with remedies ranging from fee equalization and sailing limits to per-voyage penalties up to $1 million and, in extreme cases, requests to deny port entry. Sophisticated shippers, carriers, and counsel should reassess tariff surcharges, service-contract allocation clauses, and exposure to retaliation against flag states, while tracking the IMO's London session, the November intersessional, and t

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On August 13, 2026, the White House Office of Trade and Manufacturing Policy released 'The Great Transshipment Scam,' estimating $10 billion to $100+ billion in annual tariff revenue losses from goods routed through Vietnam, Malaysia, Thailand, Mexico, and Cambodia to evade Section 301 tariffs. The same day, DOJ's National Fraud Enforcement Division issued a memorandum identifying global trade and commerce as a primary enforcement focus, covering illicit transshipment, country-of-origin fraud, undervaluation, sanctions evasion, and foreign forced labor schemes. CBP is building an AI 'detective border' that fuses anomaly detection, link analysis, capacity validation, and physical-to-digital verification to flag suspicious routing, bills of lading, origin claims, and container imaging. NFED plans to reach roughly 500 attorneys and staff by late August and continue expanding for two years, deploying sophisticated data analytics. The memo signals that civil customs exposure can escalate to criminal prosecution, with potential coordination across CBP, DOJ, and Commerce. Sophisticated coun

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Corporate compliance programs are now being urged to treat forced-labor prevention with the same rigor as anti-corruption efforts. This shift is driven by aggressive enforcement of laws like the US Uyghur Forced Labor Prevention Act (UFLPA), which establishes a rebuttable presumption that goods from certain regions are made with forced labor and are therefore banned from importation. The guide explains that this reverses the burden of proof, requiring importers to affirmatively demonstrate that their supply chains are clean through extensive due diligence and traceability measures. For sophisticated counsel and clients, this transforms supply-chain ethics from a reputational concern into a critical legal and business continuity risk. Failure to adapt can lead to shipment seizures, significant financial loss, and severe brand damage. Companies should now be integrating forced-labor risk assessments directly into their existing compliance frameworks and mapping supply chains beyond direct suppliers to prepare for potential enforcement actions.

A U.S. Court of International Trade (CIT) decision that struck down the Biden administration's two-year suspension of certain solar tariffs has created significant uncertainty for the renewables industry. The ruling, which is now being challenged at the U.S. Court of Appeals for the Federal Circuit, could lead to the imposition of substantial retroactive antidumping and countervailing duties on solar products imported from Southeast Asia between 2022 and 2024. Although the federal government has withdrawn from the appeal, industry groups are pressing on, and collection of the duties remains stayed.

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The International Maritime Organization's (IMO) proposed Net-Zero Framework (NZF), which aims to decarbonize global shipping through emissions limits and carbon pricing, is facing scrutiny from the U.S. Federal Maritime Commission (FMC). The framework could significantly increase shipping costs for U.S. importers and exporters via fuel mandates and financial penalties for non-compliance, such as a proposed $380 per tonne of CO2 equivalent. These costs, if passed on by carriers, could be deemed unjust practices under the U.S. Shipping Act. FMC Chair Ann-Dora DiBella has publicly stated the framework could trigger an investigation under the FMC's seldom-used Section 19 authority, which addresses foreign laws or practices unfavorable to U.S. trade. Such a finding could lead to significant remedies, including per-voyage fees up to $1 million or denial of U.S. port entry. Counsel for carriers and shippers should monitor upcoming IMO negotiations and the FMC's posture, as what began as a global climate initiative could become a contentious U.S. trade policy dispute requiring contractual ri

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The Committee on Foreign Investment in the United States' (CFIUS) annual report for calendar year 2025 shows a 7% increase in total filings, driven by a sharp rise in short-form declarations. However, the data reveals tougher scrutiny, as the proportion of declarations cleared by the Committee fell from approximately 78% in 2024 to 66% in 2025. Consequently, CFIUS requested parties to submit a more extensive full notice in 26% of declaration cases, up from 15% the prior year, creating potential for significant deal delays.

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The US Department of Justice (DOJ) has established the permanent Global Trade & Commerce Enforcement Section (GTCES) to investigate and prosecute criminal import, trade, and customs fraud. Working with the Department of Homeland Security, the DOJ also released "A Resource Guide to Trade Fraud Enforcement," its first comprehensive framework on the topic.

This development signals a heightened and enduring government focus on trade compliance. The guide specifically emphasizes the use of the False Claims Act (FCA), including its "reverse false claim" provision, to pursue customs fraud, tariff evasion, and duty underpayment. This substantially increases financial risk for companies, as the FCA allows for treble damages and significant civil penalties, and enables qui tam lawsuits. Corporate counsel should note the guide's focus on robust internal compliance, active supply chain auditing, and the benefits of the DOJ's voluntary self-disclosure policy. Companies should review their trade compliance programs in light of these announced priorities.

The Federal Communications Commission (FCC) has added foreign-produced advanced robotic devices and power inverters to its "Covered List," blocking any new models from receiving the authorization required for importation and sale in the United States. The commission cited unacceptable risks to national security for the move, which follows similar recent restrictions on foreign-produced drones and routers. Existing models that received FCC authorization before July 28, 2026, are not affected and can continue to be imported, sold, and receive software updates.

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The UK government has initiated a call for evidence to assess the potential introduction of a domestic digital product record (DPR) framework, a move that parallels the EU’s established Digital Product Passport (DPP) system. The inquiry, open for stakeholder input until September 21, 2026, seeks to determine how digital records could enhance product transparency, streamline compliance, and support market surveillance.

For businesses operating across Europe, this development raises critical questions about future regulatory alignment. While the EU’s DPP requirements are already being implemented and apply in Northern Ireland under the Windsor Framework, the UK’s approach for Great Britain remains undecided. A divergent UK standard could create a separate compliance track, complicating product data management, labeling, and supply chain logistics for manufacturers and retailers.

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The U.S. Department of Justice has established the permanent Global Trade & Commerce Enforcement Section to investigate and prosecute criminal import and trade fraud. Working with the Department of Homeland Security, the DOJ also released A Resource Guide to Trade Fraud Enforcement, described as the first comprehensive framework of its kind for these matters. The guide and new section signal a heightened federal priority on combating conduct that undermines US industries, evades tariffs, or introduces illicit goods into supply chains. For corporate counsel, the development highlights increased enforcement risk, particularly through the False Claims Act, which allows for treble damages and is a key tool for pursuing customs fraud and duty underpayments. The governments guidance emphasizes the importance of robust corporate compliance programs, including active supply-chain auditing and verification of partner representations. Companies involved in international trade should review their compliance and disclosure policies in light of the specific priorities and authorities outlined in

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The Committee on Foreign Investment in the United States (CFIUS) has released its annual report for calendar year 2025, revealing important trends for cross-border dealmakers. While total filings increased, driven by a 21% rise in short-form declarations, the committee's willingness to quickly clear them has fallen sharply. The proportion of declarations cleared within the 30-day assessment period dropped to 66% from 78% in 2024. Correspondingly, CFIUS more frequently requested parties to file a longer, more detailed notice after reviewing a declaration, a trend that can add significant delays to transaction timelines.

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