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Top Trade Developments
- Power Play: New Executive Order Targets Electrical Grid Equipment
- FCC Clarifies Covered List for Power Inverters and Advanced Robotic Devices
- FinCEN Finalizes BOI Reporting Rule: What U.S. Companies Need to Know
- Following the Money: FinCEN Maps the Financial Footprint of Human Smuggling
- Reminder: 2026 OFAC Annual Report of Blocked Property Due September 30, 2026
- BIS Restricts Exports of “Black Mass,” Tungsten Waste, and Scrap
Crowell Webinar
Crowell Speaks
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.
Top Trade Developments
Power Play: New Executive Order Targets Electrical Grid Equipment
On August 26, 2026, President Trump issued EO 14420, prohibiting the acquisition, importation, transfer, or installation of foreign-produced bulk-power system electric equipment that meet certain criteria.
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For more information, contact: Tyler O’Connor, Caroline Brown, Rajeev Raghavan, Alexandra Barbee-Garrett
FCC Clarifies Covered List for Power Inverters and Advanced Robotic Devices
On July 28, 2026, the Federal Communications Commission (FCC) updated its Covered List — established through the Secure and Trusted Communications Networks Act — to include foreign-produced connected power inverters and advanced robotic devices, following an executive branch national security determination that they “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.” Equipment on the Covered List is ineligible for FCC equipment authorization, effectively prohibiting the import, sale, or marketing of those products without an exception or approval.
A few weeks later, on August 20, the FCC issued a new public notice and updates to its Frequently Asked Questions (FAQ) that modifies its Covered List entry for foreign-produced power inverters, following a second National Security Determination from the U.S. Department of War (DoW), and updates its guidance on foreign-produced advanced robotic devices.
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For more information, contact: Caroline Brown, Rajeev Raghavan, Dmitry Bergoltsev
FinCEN Finalizes BOI Reporting Rule: What U.S. Companies Need to Know
Key Takeaway: Domestic reporting companies—meaning entities formed under the laws of any U.S. state or Tribal jurisdiction—have no beneficial ownership information reporting obligations to FinCEN under the final rule.
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For more information, contact: Carlton Greene, Anand Sithian, Caroline Brown, Mirenda Gwin
Following the Money: FinCEN Maps the Financial Footprint of Human Smuggling
Key Takeaway: On August 13, 2026, FinCEN issued a Financial Trend Analysis showing 67,540 Bank Secrecy Act (BSA) reports filed between 2023 and 2025 involved more than $4.9 billion in reported suspicious activity potentially related to human smuggling.
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For more information, contact: Carlton Greene, Dmitry Bergoltsev
Reminder: 2026 OFAC Annual Report of Blocked Property Due September 30, 2026
The deadline to file OFAC’s Annual Report of Blocked Property (“ARBP”) is approaching fast. All “U.S. persons” — including U.S. financial institutions, companies, and individuals — who hold property blocked pursuant to any OFAC sanctions program should take a moment to assess their reporting obligations, as set forth in 31 C.F.R. § 501.603.
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For more information, contact: Carlton Greene, Anand Sithian, Jeremy Iloulian, Edward Goetz
BIS Restricts Exports of “Black Mass,” Tungsten Waste, and Scrap
Key Takeaways: The Bureau of Industry and Security (“BIS”) issued a temporary final rule under the Defense Priorities and Allocations System (“DPAS”) that restricts exports of shredded lithium-ion battery scrap containing cathode material, known as “black mass,” as well as tungsten and other waste by U.S. entities. Published on August 6, 2026, and effective immediately upon publication, the rule’s Directive Allocation Order takes effect on August 27, 2026, at which point all monthly sales of these materials must be allocated exclusively to U.S. buyers. The Directive Allocation Order remains in effect through August 27, 2027 (unless adjusted by BIS). Exports to non-U.S. persons require a separate DPAS authorization, which does not replace a BIS export license under the Export Administration Regulations (“EAR”), if required. BIS considered the directive necessary citing the threat to national defense and security posed by the “inadequate supply of critical minerals and materials” (“CMMs”).
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For more information, contact: Scott Wise, Jeremy Iloulian, Chandler Leonard, Nate Young
Crowell Webinar
09.15.26, 12:00 PM EDT – 12:45 PM EDT
On the Banned List: What the FCC’s Expanding Covered List Means for Your Business
Join Crowell & Moring for a timely webinar on the FCC’s recent expansions of its Covered List, which now prohibits foreign-made routers, power inverters, and advanced robotic devices on national security grounds. These expansions carry broad and immediate consequences for companies across multiple industries—not only those in the communications sector, but also businesses in the technology, energy, and manufacturing sectors that rely on these devices in their operations, supply chains, and procurement pipelines.
Attendees will gain an understanding of the practical implications of these bans and have the opportunity to ask questions and gain direct insights from attorneys who have been at the forefront of advising clients on the FCC Covered Lists and national security regulatory matters.
Contact Emily Feldman with any questions.
Crowell Speaks
“IEEPA 2.0: Navigating the Current U.S. Tariff Landscape,” Retail Law Conference, Kansas City (October 14, 2026). Speakers: John Brew and Dan Campbell
“Section 301 Forced Labor Investigations: UFLPA Overlap and What Companies Should Do Now,” 15th Advanced Forum on U.S. Customs Compliance & Enforcement, Washington, D.C. (October 8, 2026). Speaker: John Brew
“Trade, Tariffs, and Supply Chain,” 4th Annual Midwest Government Contracts Seminar, Chicago (September 16, 2026). Speakers: John Brew and Weronika Bukowski
“EU Forced Labor Regulation & Comparative Analysis with the US & UK Regimes,” ICPA Fall Europe Conference, Glasgow (September 9, 2026). Speaker: Vassilis (Vass) Akritidis
U.S. expands scope of Iran secondary sanctions
August 24, 2026 – BBC
Related Professional: Erik Woodhouse
Syria’s ports surge back to life as sanctions ease and regional trade shifts
August 18, 2026 – Lloyd’s List
Related Professional: Dj Wolff
Europe wants ITAR-free weapons. US firms are trying to adjust
August 4, 2026 – Breaking Defense
Related Professional: Scott Wise
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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