Worldwide: Export Controls & Trade & Investment Sanctions

FinCEN’s March 30, 2026, Notice of Proposed Rulemaking (NPRM) marks a major step toward fully operationalizing the agency’s whistleblower program, designed to incentivize reporting of Bank Secrecy Act (BSA), sanctions, IEEPA, and other illicit finance violations.

The table below presents a structured timeline of executive actions, policy directives, and trade-related decisions issued by President Trump’s administration from January 2025 to the present. It focuses on critical areas such as tariffs, economic sanctions (OFAC), the priorities of the Department of Justice, customs regulations, and broader trade and economic policies.

U.S. Customs and Border Protection has launched Phase I of its CAPE system in ACE to process IEEPA tariff duty refunds following the Atmus Filtration court order.

A BIS investigation is one of the most serious enforcement risks in international trade. The Bureau of Industry and Security (BIS), part of the U.S. Department of Commerce, enforces the Export Administration Regulations (EAR): the rules that control how U.S.-origin goods, software, and technology can be exported, reexported, or transferred between countries.

Economic sanctions compliance in the United States runs on a strict-liability standard. In plain terms: you don’t have to mean to violate sanctions to be in violation. For businesses, banks, investment funds, law firms, and multinational executives, the difference between an OFAC General License (GL) and a Specific License (SL) isn’t a technical footnote, it can determine whether a transaction moves forward smoothly or turns into a costly enforcement problem. It’s directly tied to civil penalty risk, reputational exposure, and overall enterprise risk management.

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The global aviation leasing and finance market continues to navigate an era of unprecedented geopolitical risk.

Since the U.S. military’s abrupt capture of Venezuelan President Nicolás Maduro on January 3, 2026, the Trump administration has authorized many activities involving Venezuela...

This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters...