United States: Export Controls & Trade & Investment Sanctions

Recent U.S. cartel designations are fundamentally reshaping compliance requirements for American companies with operations or investments in Mexico. Partners from Holland & Knight examine how enforcement actions targeting Mexican financial institutions and agricultural supply chains are creating new legal exposure, even for organizations with established compliance programs, and discuss what enhanced due diligence measures companies must now implement to navigate cross-border business risk.

The U.S. Supreme Court's February 2026 decision striking down IEEPA tariffs triggered an immediate pivot to Section 301 investigations covering 60 countries. Over two weeks of hearings, 175 witnesses testified before USTR officials who actively questioned stakeholders about industrial overcapacity and forced labor evidence.

The Strait of Hormuz disruption is driving up fuel, freight, and feedstock costs across ocean, air, and trucking sectors, while trade policy moves in conflicting directions with court challenges to tariffs alongside new sector-specific duties. Shippers face rising pricing that outpaces demand, harder-to-forecast landed costs, and compressed decision windows for sourcing strategies in an environment of structural overcapacity.

On May 7, 2026, the U.S. Court of International Trade (CIT) ruled that the 10% global tariffs imposed by the Trump administration in late February 2026 under Section 122 of the Trade Act of 1974 are unlawful.

The Sanctions Update is compiled by Steptoe’s International Trade and Regulatory Compliance team and Steptoe’s Strategic Risk team.

The era of ‘globalization without guardrails’ is giving way to a new, more complex age. In some areas, trade tariffs, tougher national security restrictions, and export controls are adding friction to cross-border commerce. In others, the easing of regulatory constraints and new policy priorities are creating opportunities for investment and innovation.

Import fraud (also referred to as “customs fraud”), which has fallen under the spotlight of the Department of Justice, is any attempt to evade duties, taxes, or trade regulations.

The Sanctions Update, compiled by attorneys from Steptoe’s award-winning International Regulatory Compliance team and the Stepwise: Risk Outlook editorial team, publishes every Monday.

This comprehensive sanctions update covers major developments across US, UK, EU, and Asia-Pacific jurisdictions, including President Trump's expanded Cuba sanctions framework...