Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

On 26 May 2026, Secretary of State Marco Rubio and Indian External Affairs Minister Subrahmanyam Jaishankar signed a Strategic Critical Minerals Cooperation Framework at Hyderabad House in New Delhi, formalising bilateral cooperation across the full critical-minerals and rare-earths value chain — mining, processing, recycling, and downstream investment. The framework commits both governments to protecting sensitive supply chains from coercive market practices and reducing collective vulnerability to single-source monopolies, extending the FORGE (Forum on Resource Geostrategic Engagement) bilateral architecture from its February 2026 founding phase into a FORGE expansion phase. The US Government is mobilising over $30 billion in letters of interest, loans, investments, and other support alongside the private sector in support of FORGE-aligned projects; simultaneously the four Quad partners (US, Japan, Australia, India) announced a separate Quad Critical Minerals Initiative Framework targeting up to $20 billion in government and private-sector mobilisation.

The US Department of Commerce published its final affirmative determination in the less-than-fair-value (LTFV) antidumping investigation of polypropylene corrugated boxes from Vietnam (Federal Register doc 2026-10109, published 20 May 2026), finding that all Vietnamese producers/exporters constitute a single Vietnam-wide entity subject to a 130.58% AD rate based solely on Adverse Facts Available (AFA) due to non-cooperation. Commerce also issued a final affirmative determination of critical circumstances, triggering retroactive provisional-measures liability on entries made during the 90-day look-back period. The period of investigation covered 1 July 2024 through 31 December 2024; the ITC must issue its final injury determination within 45 days for an AD order to take effect.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 18 May 2026 that Adani Enterprises Limited (AEL), a flagship publicly traded entity of India's Adani Group (NSE: ADANIENT), agreed to pay $275,000,000 to settle apparent civil liability for violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) arising from AEL's purchases of liquefied petroleum gas (LPG) shipments through a Dubai-based commodity trader between November 2023 and June 2025, where red flags should have placed AEL on notice that the LPG originated from Iran. Approximately $192 million in payments for the Iranian-origin LPG shipments were processed through US financial institutions, providing the US nexus for OFAC jurisdiction. OFAC determined the apparent violations were EGREGIOUS and not voluntarily self-disclosed; AEL did not admit fault but committed to implementing enhanced compliance measures. The settlement is the largest OFAC enforcement action against an Indian corporate entity on record and was announced concurrently with parallel DOJ and SEC resolutions forming part of a broader US legal-relief package for the Adani Group.

On 8 May 2026 the US Department of Commerce and South Korea's Ministry of Trade, Industry and Resources (MOTIR) signed the Korea-U.S. Shipbuilding Partnership Initiative (KUSPI) MOU, establishing a standing bilateral platform covering commercial shipbuilding cooperation, workforce development, industrial modernisation, and maritime manufacturing investment. The agreement creates the Korea-U.S. Shipbuilding Partnership Center in Washington D.C. (expected operational later in 2026) as the permanent coordination mechanism for technical exchanges, shipyard productivity improvement projects, FDI into the US maritime industrial base, and joint workforce training. KUSPI operationalises the $150 bn Korean investment sub-pledge to US shipbuilding — itself a tranche of the broader $350 bn / $20 bn-annual-cap commitment under the December 2025 US-Korea Strategic Trade and Investment Deal — and structurally positions the US-ROK allied axis as the coordinated civilian shipbuilding counterweight to China's dominant global shipyard share.

A divided three-judge panel of the US Court of International Trade (CIT), in Slip Op. 26-47 (Court Nos. 26-01472 and 26-01606, decided 7 May 2026), held 2-1 that President Trump's Proclamation 11012 — which imposed a temporary 10% ad-valorem import surcharge under Section 122 of the Trade Act of 1974 — exceeded statutory authority because the proclamation did not identify a "fundamental international payments problem" as defined by the 1974 Congress (the balance-of-trade or current-account deficit relied upon by the government is not the type of balance-of-payments deficit the statute contemplates). The court issued a permanent injunction prohibiting CBP from collecting Section 122 duties from the three prevailing plaintiff- importers and ordered refunds with statutory interest for duties already paid; it declined to issue a nationwide injunction. The US Court of Appeals for the Federal Circuit (CAFC) entered an administrative stay of the CIT injunction on 12 May 2026 pending appeal, and the CIT denied the government's own motion to stay its ruling on 20 May 2026; the CAFC appeal is now pending.

USTR formally initiated the second statutorily mandated four-year review of its Section 301 investigation into China's acts, policies, and practices related to technology transfer, intellectual property, and innovation (Federal Register 2026-08806, published May 6, 2026). The review covers tariff actions imposed on approximately $300 billion of Chinese goods across Lists 1–4B (25% on most lists; 7.5% on List 4A) and will determine whether those actions should be continued, modified, or terminated. Interested parties may file continuation requests in two 60-day windows: May 7–July 5, 2026 (for the July 6, 2018 action) and June 24– August 22, 2026 (for the August 23, 2018 action). DISTINCT from the March 2026 Section 301 excess-capacity investigations (which target 16 economies on overcapacity sectors) and from the June 2026 Section 301 forced-labor enforcement action (60 economies); this review is China-specific, IP/TT-focused, and mandated by the original Biden-era statutory clock under Section 304(c) of the Trade Act of 1974.

President Trump signed Executive Order 14404, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy," on 1 May 2026. The order operationalises the country-specific national emergency declared by EO 14380 (29 January 2026) — which had been preserved after the SCOTUS *Learning Resources* vacatur of the IEEPA tariff authority — by establishing a sectoral OFAC blocking regime. Section 2 authorises asset-blocking against any foreign person determined by the Secretary of Treasury (in consultation with State) to operate in Cuba's energy, defense and related materiel, metals and mining, financial services, or security sectors, or "any other sector" subsequently designated. Section 3 suspends entry under INA § 212(f) for covered aliens. Section 4 authorises secondary sanctions against foreign financial institutions that knowingly conduct or facilitate significant transactions for blocked persons, with both correspondent-account and SDN-listing remedies. The EO itself includes no annex of named designations — those are issued by OFAC under separate determinations.

On May 1, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated China-based independent ("teapot") refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. — described as China's second-largest teapot — together with approximately 40 shipping firms and vessels operating as part of Iran's shadow fleet. OFAC sanctioned 19 shadow-fleet vessels (crude, LPG, and petrochemical tankers) as blocked property of designated owners or managers. The action was taken under Executive Order 13902 (Iran petroleum and petrochemical sectors) in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. Treasury press release SB0472. Concurrent with the designations, OFAC issued Iran-related General License W authorising the wind-down of transactions involving the persons newly blocked on May 1, 2026, and published a structurally novel Iran-related Alert, "Sanctions Risks of Iranian Demands for Strait of Hormuz Passage." The Alert states that payments to the Government of Iran or the IRGC — directly or indirectly — for safe passage through the Strait of Hormuz are not authorised for US persons (including US financial institutions) or US-owned/-controlled foreign entities. OFAC also issued new FAQ 1250 to accompany the Alert and GL W. The wave is one of the largest single-day Iran enforcement actions of the Trump 2.0 administration. Treasury characterises it as part of a campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The Strait of Hormuz Alert is the operational US response to Iranian regulatory threats against the ~20% of global oil and ~25% of global LNG transiting Hormuz, putting tanker owners, P&I clubs, flag states, and oil-buyer compliance teams on direct notice.

On April 30, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added former Democratic Republic of the Congo President Joseph Kabange Kabila to the Specially Designated Nationals (SDN) List pursuant to Executive Order 13413, as amended by Executive Order 13671 (the DRC sanctions program), for having materially assisted, sponsored, or provided financial, material, or technological support to the March 23 Movement (M23) and its political-military coalition the Congo River Alliance (Alliance Fleuve Congo, AFC). Treasury press release SB0480 ("Treasury Sanctions Former Democratic Republic of the Congo President for Ties to Armed Conflict") frames the designation as enforcement of the Washington-brokered DRC-Rwanda framework: M23 controls a substantial share of mineral-rich eastern DRC (cobalt, coltan, tin, tungsten, gold) and AFC's renewed rebellion has fuelled a mass-displacement crisis. The notice was published in the Federal Register on May 5, 2026 (FR Doc. 2026-08672). The designation blocks all property and interests in property of Kabila subject to US jurisdiction and prohibits US-person dealings with him. It is a discrete enforcement step under the broader US-DRC Strategic Partnership Agreement (4 December 2025 — the "Washington Accords") and complements earlier 2026 designations of Rwanda Defence Force-linked actors. Treasury frames the action as signalling that political support to M23/AFC, not just direct military or commercial activity, will trigger blocking sanctions.

The Office of the United States Trade Representative released the 2026 Special 301 Report on 30 April 2026, designating Vietnam as a Priority Foreign Country (PFC) — the most severe category under Section 182 of the Trade Act of 1974 (19 U.S.C. § 2242). This is the first PFC designation since Ukraine held the status from 2013 through 2015, a gap of approximately 11 years. The PFC designation triggers a statutory 30-day window (expiring ~30 May 2026) within which USTR must decide whether to initiate a Section 301 investigation under 19 U.S.C. § 2412(b)(2)(A), which could lead to tariffs, withdrawal of trade benefits, or other Section 301 enforcement remedies against Vietnam. Separately, the EU was added to the Watch List for the first time, citing AI training-data, geographical-indications, and customs-enforcement concerns.

On 27 April 2026, US Assistant Secretary of State Caleb Orr and Bolivian Mining Minister Marco Antonio Calderón signed a Critical Minerals Memorandum of Understanding in Washington DC, establishing a non-binding cooperation framework targeting lithium, cobalt, and copper supply chains. The MoU is the first major bilateral economic instrument between the US and Bolivia since the 2008–09 expulsion of the US Ambassador, marking a strategic realignment by the post-Paz government toward Western investment partnerships. The agreement commits both governments to attract private-sector investment to Bolivia's critical-minerals endowment — including the Salar de Uyuni lithium resource (~21 Mt LCE, world's largest identified reserve) — as operational follow-through to Bolivia's February 2026 Critical Minerals Ministerial participation and the FORGE launch. It runs in parallel with Bolivia's domestic Proyecto de Ley del Litio (filed December 2025), which would open extraction-stage YLB operations to private partnership and introduce a progressive royalty structure.

On April 24, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added 19 entities and 19 vessels to the Specially Designated Nationals (SDN) List under Executive Order 13902 (Iran petroleum and petrochemical sectors), in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. The action is the first OFAC designation of a Chinese independent ("teapot") refinery — Hengli Petrochemical (Dalian) Refinery Co., Ltd., described as one of Iran's largest single customers for crude oil and petroleum products, having purchased billions of US dollars' worth since at least 2023 from cargoes brokered by Sepehr Energy Jahan Nama Pars Company (the oil sales arm of Iran's Armed Forces General Staff, controlled by the Ministry of Defense / MODAFL). Co-designations span shipping firms and vessels registered in China, Hong Kong, Panama, Marshall Islands, Liberia, and Vietnam. Concurrent with the designations, OFAC issued Iran-related General License V authorising a 30-day wind-down (through May 24, 2026) of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. and certain majority-owned entities. Treasury press release SB0472 ("Economic Fury Targets Global Network Fueling Iran's Oil Trade and Shadow Fleet") frames the action as part of the maximum-pressure campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The April 24 designations directly triggered the first-ever operational use of China's Blocking Rules (MOFCOM Announcement No. 21 of May 2, 2026) and preceded a second OFAC Iran wave on May 1, 2026 (General License W + Strait of Hormuz Sanctions Risk Alert).

The US Department of Commerce published preliminary affirmative antidumping duty (AD) determinations on April 23, 2026 (Federal Register publication April 28, 2026), finding that crystalline silicon photovoltaic cells (whether or not assembled into modules) from India, Indonesia, and Laos are being sold in the US at less than fair value. Preliminary dumping margins are 123.04% for India, 35.17% for Indonesia, and 22.46% for Laos, with Commerce ordering US Customs and Border Protection to begin collecting AD cash deposits at those rates (107.77% adjusted cash-deposit rate for India; 22.06% for Laos). This runs parallel to, and stacks on top of, the CVD case on the same merchandise and countries (see responds_to), meaning combined AD+CVD cash-deposit burdens on subject imports now exceed 100% for all three origins. Final AD determinations are due July 13, 2026 (India, Indonesia) and September 9, 2026 (Laos).

President Trump issued five Presidential Determinations on 20 April 2026 under Section 303 of the Defense Production Act of 1950 (50 U.S.C. § 4533), invoking the authority granted by Executive Order 14156 (Declaring a National Energy Emergency, signed 20 January 2025). The five determinations cover: (1) domestic petroleum production, refining, and logistics; (2) large-scale energy and energy-related infrastructure development, manufacturing, and deployment; (3) natural gas transmission, processing, storage, and LNG capacity; (4) coal supply chains and baseload power generation; (5) grid infrastructure, equipment, and supply chain. Each determination authorises the relevant Cabinet Secretary (primarily Energy) to use DPA §303 powers — direct loans, loan guarantees, purchase commitments, and equity investments — to expand domestic capacity in the named category.

FinCEN issued an amendment to its June 30, 2025 special-measure order (90 FR 27770) that had prohibited US covered financial institutions from transmitting funds to or from CIBanco S.A., a Mexican multiple-banking institution previously designated as of primary money-laundering concern in connection with illicit-opioid trafficking. Effective April 16, 2026, the amendment authorizes transmittals of funds ordinarily incident and necessary for the Government of Mexico to liquidate CIBanco. The carve-out is narrow: the broader §2313a prohibition on US-side correspondent activity with CIBanco remains in force outside the liquidation channel.

The US Bureau of Industry and Security issued a final rule (RIN 0694-AK74, 91 FR 17851, FR doc 2026-06851, signed 7 April 2026, published 9 April 2026, effective 7 April 2026) extending two compliance dates in the January 2025 Foundry Due Diligence (FDD) interim final rule that introduced the "Authorized IC Designer" / "Approved IC Designer" framework for advanced-computing integrated circuits controlled under ECCN 3A090.a. The prior 13 April 2026 cutoff for Authorized IC Designer status — the self-certification pathway available to designers headquartered in Country Group A:1 / A:5 / Taiwan and not parented in Macau or D:5 — is moved to 31 December 2026, and the application window to become an Approved IC Designer is extended to the same date with a subsequent 180-day authorization runway. The rule is a procedural deadline-extension only; it does not change the substantive scope, eligibility criteria, ECCN classifications, or end-use / end-user restrictions of the FDD IFR.

On 2 April 2026 President Trump issued a Presidential Proclamation under Section 232 of the Trade Expansion Act of 1962 ("Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients into the United States") imposing a 100% ad valorem tariff on imports of patented pharmaceutical products listed in the FDA Orange Book and Purple Book, together with the active pharmaceutical ingredients (APIs) and key starting materials used to make them. The base rate takes effect at 12:01 a.m. EDT on 31 July 2026 for the 17 manufacturers identified in Annex III, and on 29 September 2026 for all other companies. The proclamation adopts findings of the Section 232 investigation initiated by the Department of Commerce on 14 April 2025 into pharmaceuticals and APIs as a national- security supply-chain risk. The instrument is structured around a multi-tier rate ladder rather than a flat tariff: concessionary 15% rates for EU/Japan/South Korea/Switzerland/Liechtenstein under reciprocal-deal tracks, 10% for the UK with a pathway to 0% under the pending UK pharmaceutical agreement, a "+20%" surcharge for companies operating under a Commerce-approved onshoring plan (until 2 April 2030), and a 0% pathway for companies that combine an approved onshoring plan with an MFN-pricing agreement with HHS (until 20 January 2029). Generics, biosimilars and their ingredients, orphan drugs, nuclear medicines, plasma-derived therapies, fertility treatments, and cell/gene therapies are carved out.

Presidential Proclamation 11021 of 2 April 2026 (signed by President Trump, effective 6 April 2026 at 12:01 a.m. EDT, published 9 April 2026 at 91 FR 18201) consolidates and restructures the Section 232 tariff architecture for aluminum, steel, and copper. The proclamation modifies Proclamations 9704 (aluminum), 9705 (steel), and 10962 (copper) and applies tiered ad valorem duties to the full customs value of imported articles regardless of metal content: 50% on aluminum/steel articles and most copper articles; 25% on certain copper articles and on derivative articles substantially made of the three metals; 10% on derivative articles produced abroad using entirely US-smelted/cast metals; and 0% supplemental duty where existing tariffs already meet a 15% combined-rate floor. UK products receive preferential rates (25% on primary articles and 15% on certain derivatives) contingent on UK smelting/casting under the US–UK trade framework.

The Department of Commerce's International Trade Administration published a Federal Register notice on 10 April 2026 (91 FR 18412, doc 2026-06952) opening the inaugural Call for Proposals for the American AI Exports Program established under Executive Order 14320. Proposals are accepted from 1 April 2026 through 5:00 pm EDT on 30 June 2026 from US industry-led "pre-set" consortia offering full-stack American AI export packages — AI-optimised hardware, data pipelines, AI models and systems, security and cybersecurity measures, and sector-specific applications — for presentation by the US government to foreign public- and private-sector buyers. Designated consortia receive priority US-government advocacy, priority consideration for export-control licence engagement, interagency coordination, and federal-financing referrals (EXIM, DFC), with a 14-business-day completeness review and 60-calendar-day designation decision once a proposal is deemed complete.

On March 20, 2026, OFAC issued Iran-related General License U (GL U), temporarily authorizing the sale, delivery, offloading and — notably, for the first time in decades — importation into the United States of Iranian-origin crude oil and petroleum products, but only for cargo already loaded onto vessels as of 12:01 a.m. EDT that day. The window ran through April 19, 2026, after which the authorization lapsed. The license excluded any transaction touching Cuba, North Korea, or Russian-government-controlled areas of Ukraine, and did not waive any other, non-Iran sanctions program. OFAC formally published GL U (and the separate, entity-specific GL V wind-down license for Hengli Petrochemical) in the Federal Register on June 10, 2026 — a retrospective publication of licenses already issued and, by then, already expired.

On 19 March 2026, USTR Ambassador Jamieson Greer and Japan's Ministry of Foreign Affairs, METI, and Ministry of Finance jointly released the "United States-Japan Action Plan for Critical Minerals Supply Chain Resilience" — the operational follow-on to the 27 October 2025 US-Japan Framework. The Action Plan formally commits both governments to develop a plurilateral trade initiative in critical minerals "supported by price floors or other measures", to consult on embedding "border-adjusted price floors" in a binding plurilateral agreement, and to identify specific mining/processing/manufacturing projects in the US, Japan, or third countries for prioritised joint financing. It is the first formal US/Japan trade-policy commitment to administered floor-pricing as an instrument of critical-minerals trade governance, and explicitly invites third countries to join the contemplated plurilateral.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced on 17 March 2026 that TradeStation Securities, Inc. agreed to pay $1,110,661 to settle 481 apparent violations of the Iranian Transactions and Sanctions Regulations (31 CFR Part 560), the Syrian Sanctions Regulations (31 CFR Part 542), and the Ukraine-/Russia-Related Sanctions Regulations (31 CFR Part 589) that occurred between 21 June 2021 and 15 June 2022. The violations arose from a mobile-platform software update that inadvertently caused the firm's second-tier geo-blocking to screen the IP address of a U.S.-located server rather than the user's IP, allowing customers in Iran, Syria, and Crimea to execute securities-related transactions. OFAC determined the apparent violations were non-egregious and voluntarily self-disclosed, resulting in a significantly reduced settlement amount.

On 13 March 2026 USTR Jamieson Greer and Ecuador's Minister of Production, Foreign Trade and Investment Luis Alberto Jaramillo signed the United States–Ecuador Agreement on Reciprocal Trade in Washington, formalising the framework agreed in November 2025. Ecuador commits to preferential treatment for >90% of its agricultural schedule (including tariff elimination on soybeans, fresh/processed fruit, alcoholic beverages, tea, tree/ground nuts, dairy, beef, pork and poultry), to discontinue applying the Andean Price Band System to US-origin agricultural goods, to accept US remanufactured goods and US motor-vehicle safety/emissions standards, and to commit on digital-trade non-discrimination plus the multilateral moratorium on customs duties on electronic transmissions. The US in return grants MFN tariff treatment to qualifying Ecuadorian goods that "cannot be grown, mined, or naturally produced" in the US, by 1 August 2026 or entry into force (whichever is later). The Agreement enters into force 30 days after both parties notify completion of domestic procedures.

On 11 March 2026 USTR Ambassador Jamieson Greer initiated parallel Section 301 investigations into the acts, policies, and practices of 16 economies — China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India — relating to structural excess capacity and overproduction in manufacturing sectors. The Federal Register notice (FR doc 2026-05214; dockets USTR-2026-0067 and USTR-2026-0068) was published on 17 March 2026. Covered sectors include aluminum, automobiles, batteries, cement, chemicals, electronics, energy goods, glass, machine tools, machinery, paper, plastics, processed food and beverages, robotics, satellites, semiconductors, ships, solar modules, steel, and transportation equipment. Written comments were due by 15 April 2026; USTR held the public hearing beginning 5 May 2026. This is the most sweeping multi-economy Section 301 initiative since the 2018 China investigation and is structurally distinct from the China-only 2024-05-14 §301 tariff hikes and the 2025-07-15 Brazil §301 investigation.

FinCEN issued an expanded Geographic Targeting Order (GTO) requiring money services businesses (MSBs) located in designated counties and ZIP codes across Arizona, California, New Mexico, and Texas to file Currency Transaction Reports (CTRs) on cash transactions between $1,000 and $10,000 — well below the standard $10,000 CTR threshold. The order took effect March 7, 2026 and runs through September 2, 2026; the FR notice (FR Doc. 2026-04641) was published March 10, 2026. The expansion adds Bernalillo, Doña Ana, and San Juan Counties in New Mexico and Maricopa and Pima Counties in Arizona to the geography covered by the prior September 10, 2025 GTO. Compliance date for newly-covered MSBs is April 6, 2026; reports must be filed within 30 days (extended from the standard 15-day CTR deadline). The instrument is part of the post-2024 US enforcement architecture targeting fentanyl-related illicit-finance flows through the US-Mexico border MSB channel.

The US Department of Commerce published its final affirmative determination of sales at less-than-fair-value in the antidumping investigation of animal feed-grade L-lysine (lysine) from China (case A-570-215) on 23 July 2026, following a preliminary determination published 6 March 2026 (91 FR 11030). Commerce found a China-wide weighted-average dumping margin of 139.83% (cash deposit rate 139.65% after subsidy-offset adjustment), based on adverse facts available after Commerce found Zhengzhou Longgu Trading Co., the sole company with a calculated margin, and the Eppen Group group of producers/exporters uncooperative and ineligible for a separate rate in the final determination. A group of separate-rate companies — including Anhui BBCA Biochemical, Heilongjiang Wanlirunda Biotechnology, and others exporting through trading intermediaries such as Agromate Sg, Ainore (Tianjin), and Aollen Biotech — received a 73.55% dumping margin (73.37% cash deposit rate). The order covers lysine regardless of form (HCl, sulfate, liquid) under HTSUS 2922.41.0090 and related subheadings. A companion countervailing-duty investigation (preliminary 22 January 2026, 91 FR 2745) was finalized the same day; suspension of liquidation runs from 6 March 2026, with a final AD order contingent on an ITC injury determination due within 45 days of the final LTFV finding.

The US Department of Commerce published preliminary affirmative countervailing duty (CVD) determinations on February 26, 2026, finding that producers and exporters of crystalline silicon photovoltaic cells (whether or not assembled into modules) from India, Indonesia, and Laos received countervailable government subsidies. Preliminary subsidy rates are 125.87% for India; 85.99%–143.30% by individual Indonesian producer (104.38% all-others rate); and a uniform 80.67% for Laos. Commerce ordered US Customs and Border Protection to begin collecting cash deposits at these rates on subject imports pending a parallel antidumping investigation and final determinations later in 2026. The case originated from a petition filed in August 2025 by US crystalline silicon PV manufacturers.

On 26 February 2026 USTR published a Federal Register notice (90 FR 9686, docket USTR-2026-0034) inviting public comment on the design of a plurilateral Agreement on Trade in Critical Minerals and accompanying policy actions to strengthen critical-mineral supply-chain resilience. The notice signals that the agreement under consideration would include "a commitment by all parties to implement minimum prices or other price mechanisms, with appropriate border measures" — a coordinated price-floor/border-adjustment regime across like-minded partners to incentivise ex-China mining, processing, and refining investment. Comments were due 19 March 2026.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 25 February 2026 that a U.S. person agreed to pay $3,777,000 to settle potential civil liability for 20 apparent egregious violations of the Syrian Sanctions Regulations (31 CFR Part 542) occurring between January 2018 and December 2021. The individual provided managerial services — reviewing and signing financial statements, approving operational and employee expenses, and supervising service-fee collection — as an officer and board member of four Syrian real-estate companies supporting luxury real-estate development projects in Syria. OFAC determined the conduct was egregious and not voluntarily self-disclosed, setting the settlement at 10× the statutory IEEPA base amount per apparent violation (the maximum egregious multiplier) and establishing a significant personal-liability precedent for U.S. persons serving on boards or in officer roles of companies in sanctioned jurisdictions.

President Trump signed Executive Order "Ending Certain Tariff Actions" on 20 February 2026 (Federal Register doc 2026-03832, published 25 February 2026), terminating the additional ad-valorem duties imposed under nine prior IEEPA-based executive orders. The order followed within hours of the US Supreme Court's 6-3 decision the same day in Learning Resources, Inc. v. Trump, 607 U.S. ___ (2026), holding that the International Emergency Economic Powers Act does not authorize the President to impose tariffs and vacating the Trump 2.0 IEEPA tariff regime. The EO directs CBP to cease collection "as soon as practicable"; CSMS guidance set the collection-end date at 12:00 a.m. eastern on 24 February 2026. The order explicitly preserves all underlying national-emergency declarations and all non-IEEPA trade actions — Section 232 of the Trade Expansion Act, Section 301 of the Trade Act, Section 122 of the Trade Act, and Section 201 — so the Section 232 cascade and the paired Section 122 10% temporary surcharge (effective 24 Feb 2026) remain in force. This is the first SCOTUS-driven repeal of a presidential tariff regime in the modern era and recalibrates the entire post-2024 US tariff architecture by removing IEEPA as a legal pillar.

President Trump signed a Presidential Proclamation on 20 February 2026 invoking Section 122 of the Trade Act of 1974 (19 U.S.C. § 2132) to impose a temporary 10% ad-valorem import surcharge on articles imported into the United States, effective 12:01 a.m. EST on 24 February 2026. The proclamation was issued within hours of the US Supreme Court's 20 February 2026 ruling in Learning Resources, Inc. v. Trump, which held that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to set tariffs and vacated the IEEPA-based reciprocal-tariff regime previously in effect. The Section 122 surcharge is statutorily limited to 150 days (terminates 24 July 2026 absent Congressional extension) and the statute caps any such surcharge at 15% ad valorem. Goods qualifying as USMCA originating from Canada or Mexico are exempt; CAFTA-DR textile/apparel articles meeting specified rules of origin are exempt; and a substantial product-exception list excludes critical minerals, energy products, certain pharmaceuticals, electronics, vehicles, aerospace products, specified agricultural goods, and goods already subject to Section 232 duties (the Section 122 duty does not stack on Section 232).

On 19 February 2026 Presidents Trump and Prabowo finalised the Agreement on Reciprocal Trade (ART) between the United States and Indonesia. The deal locks the US reciprocal tariff on Indonesian imports at 19% (down from the 32% threatened in April 2025), with 0% on a defined list of products and a textile/apparel quota benchmarked to US-cotton/MMF inputs. Indonesia commits to remove export restrictions on all industrial commodities — explicitly including critical minerals across the full value chain — and to grant US investors national treatment in mineral exploration, mining, processing and export. Indonesia also agrees to eliminate tariff barriers on >99% of US-origin goods, while a Freeport-McMoRan MOU extends the Grasberg copper-mine licence (~USD 10bn/yr revenue, world's 2nd largest copper mine) and a parallel commercial package totalling ~USD 33bn (energy USD 15bn, aerospace incl. Boeing USD 13.5bn, agriculture USD 4.5bn) is signed alongside.

President Trump signed Executive Order 14387 on 18 February 2026, invoking Section 101 of the Defense Production Act (DPA) to ensure an adequate domestic supply of elemental phosphorus and glyphosate-based herbicides. The order delegates DPA §101 priority-allocation and contract- direction authority to the Secretary of Agriculture, authorises USDA to direct the production and distribution of these inputs for national-defense purposes, and grants legal immunity to domestic producers acting in compliance with USDA directives. The EO is the first DPA invocation specifically targeting the phosphorus supply chain, reflecting the concentration of global white/yellow phosphorus production in China (~75% share) and the existence of only a single operating US producer.

The Federal Acquisition Regulatory Council (DOD, GSA, and NASA) published a Notice of Proposed Rulemaking on 17 February 2026 (FR Doc 2026-03065, 91 FR 7223) implementing Section 5949(a) of the NDAA FY2023 (Pub. L. 117-263), which bars executive agencies from acquiring electronic products or services containing semiconductor components designed, produced, or provided by SMIC, CXMT, YMTC, or their affiliates. A Part B prohibition extends the restriction to "critical systems" whose subsystems incorporate covered semiconductors regardless of COTS sourcing. The comment period closed 20 April 2026; proposed prohibitions take effect 23 December 2027.

OFAC reached a $1,720,000 civil penalty settlement with IMG Academy LLC on 12 February 2026 to resolve 89 apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations (31 CFR Part 598) arising from tuition-related transactions processed on behalf of two individuals designated as SDNs under the Kingpin Act between 2018 and 2023. OFAC determined the apparent violations were NON-EGREGIOUS and not voluntarily self-disclosed; the penalty reflects substantial cooperation and remedial measures taken by IMG Academy after becoming aware of the violations. This is the first OFAC enforcement action in the register against a US educational or academic-services institution, establishing Kingpin Act SDN-screening obligations for schools and training academies accepting international student tuition payments.

On 12 February 2026, Ambassador Jamieson Greer of the Office of the United States Trade Representative oversaw the signing of the US-Taiwan Agreement on Reciprocal Trade (ART) in Washington, DC. The instrument was signed under the auspices of the American Institute in Taiwan (AIT) and the Taipei Economic and Cultural Representative Office in the United States (TECRO). Headline terms: (i) US IEEPA reciprocal-tariff rate on Taiwan reduced from 20% to 15% and Section 232 auto-parts/timber/lumber rate cut from 25% to 15%; (ii) Taiwan eliminates or reduces 99% of its tariff barriers on US goods, most immediately and the remainder phased over three years; (iii) Taiwan side commits ~USD 85bn in directed purchases through 2029 (USD 44.4bn LNG/crude, USD 15.2bn civil aircraft and engines, USD 25.2bn power equipment); (iv) sectoral chapters covering tariffs, non-tariff barriers, digital trade, economic security, and high-tech supply-chain resilience. Operationally linked to the 15 January 2026 AIT-TECRO Memorandum of Understanding on investment, under which Taiwan pledges USD 250bn in direct Taiwanese-enterprise investment in the US plus USD 250bn in Taiwan-government credit guarantees (USD 500bn total) to fund US-side industrial parks/clusters in advanced semiconductors, energy, and AI manufacturing. Entry into force is conditional on Taiwan's Legislative Yuan completing its review.

On 10 February 2026 in Baku, US Vice President JD Vance and Azerbaijani President Ilham Aliyev signed a Charter on Strategic Partnership — a foundational bilateral instrument covering five cooperation tracks: economy and trade, energy, connectivity and digital development (including AI), security and defense, and critical-minerals transit. The Charter commits both governments to facilitate the transit of critical minerals via the Trans-Caspian Middle Corridor to global markets, and formally recognises the Trump Route for International Peace and Prosperity (TRIPP) as the multi-modal connectivity link between mainland Azerbaijan and the Nakhchivan Autonomous Republic. The instrument builds on the 8 August 2025 MoU signed in Washington during the Armenia-Azerbaijan Peace Summit that established the Strategic Working Group tasked with drafting the Charter, and marks the first US Vice-Presidential visit to Azerbaijan since Dick Cheney in 2008.

On 9 February 2026 USTR Ambassador Jamieson Greer and Bangladesh Adviser Sheikh Bashir Uddin signed the Agreement on Reciprocal Trade (ART) between the United States and Bangladesh in Washington DC — USTR's first ART signing in South Asia, preceding the US-India interim-trade-framework finalisation by three days. The deal locks the US reciprocal tariff on Bangladesh-originating goods at 19% (down from 35% under the April 2025 IEEPA regime) and establishes a zero-percent mechanism for products on the Annex III aligned- partner list (EO 14346, 5 September 2025). Bangladesh commits to significant preferential market access for US industrial and agricultural goods — including chemicals, machinery, motor vehicles, medical devices, ICT equipment, energy products, soy, dairy, beef, poultry, tree nuts, and fruit — and to eliminating specified non- tariff barriers including acceptance of US Federal motor-vehicle safety and emissions standards, FDA certificates, and prior marketing authorisations for medical devices and pharmaceuticals.

President Trump signed Executive Order 14382, "Addressing Threats to the United States by the Government of Iran," on 6 February 2026 (effective 12:01 a.m. EST on 7 February 2026; published in the Federal Register on 11 February 2026 as FR doc 2026-02813, 91 FR 6493-6496). Invoking IEEPA, the National Emergencies Act, section 604 of the Trade Act of 1974 and 3 U.S.C. § 301, the order declared a country-specific national emergency with respect to Iran and established a secondary-tariff-authority framework: an additional ad valorem duty (the EO offers "for example, 25 percent" as illustration but sets no binding rate) is authorised on imports of articles produced by any foreign country determined to directly or indirectly purchase, import, or otherwise acquire any goods or services from Iran. Determinations are made by the Secretary of Commerce, with rate recommendations from the Secretary of State in consultation with Treasury, DHS and USTR; the President retains final authority. EO 14382 was structurally modelled on EO 14245 (Venezuelan oil importing countries, 24 March 2025) and EO 14380 (Cuba, 29 January 2026), and was on the list of nine IEEPA-based tariff EOs whose tariff component was vacated by the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* (20 February 2026). The companion EO 14389 of 20 February 2026 ("Ending Certain Tariff Actions") extinguished the tariff authority for entries on or after 12:00 a.m. ET on 24 February 2026; the underlying Iran national- emergency declaration was preserved. No third-country determination or specific rate was operationalised under EO 14382 prior to vacatur.

On 6 February 2026 Presidents Trump and Modi announced a framework for an Interim Trade Agreement that resets the bilateral tariff posture installed in 2025. Two operative instruments: (i) an executive order signed 6 February eliminating, effective 7 February 2026, the additional 25% IEEPA "Russian-oil" duty on Indian imports imposed by EO 14329 (27 August 2025), conditional on India's commitment to cease buying Russian crude and to expand defence cooperation; and (ii) reduction of the EO 14257 reciprocal-tariff rate on India from 25% to 18% on listed product categories (textiles and apparel, leather and footwear, plastics and rubber, organic chemicals, home décor, artisanal products, certain machinery), to take effect on finalisation of the Interim Agreement. India commits to eliminate or reduce tariffs on all US industrial goods and a wide range of agricultural products (DDGs, red sorghum, tree nuts, fresh and processed fruit, soybean oil, wine, spirits) and to purchase >USD 500bn of US energy, ICT, coal, aircraft and aircraft parts, and precious-metals products over five years. The framework also commits the parties to negotiating "robust, ambitious, and mutually beneficial digital trade rules" and to addressing non-tariff barriers in medical devices, ICT import licensing, and food/agricultural standards. US tariff reductions on Indian generic pharmaceuticals, gems, diamonds, aircraft parts, and certain automotive components are flagged as contingent on completion of the full Interim Agreement.

On 6 February 2026, Texas Governor Greg Abbott announced a USD 14,076,031 grant from the Texas Semiconductor Innovation Fund (TSIF) to Coherent Corp. to accelerate scaled production of 6-inch Indium Phosphide (InP) wafers at its Sherman, Texas facility. The grant supports a broader USD 154 million capital-investment project that will establish what the announcement describes as the world's first 6-inch InP wafer fabrication plant, consolidating Coherent's North American semiconductor operations. InP wafers underpin photonics components used in data-center interconnects, telecommunications, AI compute networking, advanced sensing, and 6G wireless/satellite links. TSIF was established under the Texas CHIPS Act signed by Abbott in 2023.

In a final rule published in the Federal Register on 4 February 2026 (effective 3 February 2026), the Bureau of Industry and Security (BIS) deleted the "X" designation for Cambodia from Country Group D:5 of the Export Administration Regulations (EAR), removing Cambodia from the EAR's list of arms-embargoed destinations. The action conforms the EAR to a Department of State final rule of 7 November 2025, which removed Cambodia as an arms-embargoed destination under International Traffic in Arms Regulations (ITAR) §126.1. Cambodia remains designated in Country Group D:1 and remains subject to the military and military-intelligence end-use/end-user controls in EAR §§744.21 and 744.22.

On 4 February 2026, in Washington, DC, Guinea's Minister of Mines and Geology Bouna Sylla and US Under Secretary of State for Economic Affairs Jacob Helberg signed an intergovernmental Memorandum of Understanding to cooperate on critical-mineral supply chains, covering exploration, extraction, processing, and downstream investment. The MoU was one of eleven founding-member bilateral instruments signed simultaneously at the inaugural FORGE (Forum on Resource Geostrategic Engagement) Critical Minerals Ministerial hosted by Secretary of State Marco Rubio. Guinea holds approximately 26% of global bauxite reserves (~3.7bn tonnes) and is the world's largest bauxite exporter and #2 alumina exporter, making it the choke-point upstream node for any non-Chinese aluminium value chain.

On 4 February 2026 USTR Ambassador Jamieson Greer and Mexican Secretary of Economy Marcelo Ebrard announced a U.S.-Mexico Action Plan on Critical Minerals — a first-of-its-kind 60-day bilateral work programme to develop coordinated trade policies and supply-chain mechanisms for critical minerals. The Action Plan tasks both governments with identifying a priority mineral list, exploring border-adjusted price floors as a candidate trade instrument, and consulting on how price floors could be incorporated into a binding plurilateral agreement on trade in critical minerals. It is framed as a confidence- building measure ahead of the USMCA Joint Review (statutory deadline 1 July 2026) and as the Mexico-side template that parallels concurrent USTR engagements with the EU and Japan.

On 4 February 2026, in Washington, DC, the United States and the Kingdom of Morocco signed an intergovernmental Memorandum of Understanding to cooperate on critical-mineral and rare-earth supply chains, covering exploration, extraction, processing, and downstream investment. The MoU was one of eleven founding-member bilateral instruments signed simultaneously at the inaugural FORGE (Forum on Resource Geostrategic Engagement) Critical Minerals Ministerial hosted by Secretary of State Marco Rubio. Morocco holds approximately 70-75% of the world's known phosphate reserves and is a globally significant cobalt, copper, and nickel producer; the framework explicitly aims to attract Western investment into Moroccan downstream processing capacity rather than raw-mineral export.

On 4 February 2026, in Washington, DC, Peru and the United States signed an intergovernmental Memorandum of Understanding to cooperate on critical-mineral supply chains, covering exploration, extraction, processing, and downstream investment. The MoU was one of eleven founding-member bilateral instruments signed simultaneously at the inaugural FORGE (Forum on Resource Geostrategic Engagement) Critical Minerals Ministerial hosted by Secretary of State Marco Rubio, with Vice President JD Vance, Treasury Secretary Scott Bessent, Interior Secretary Doug Burgum, Energy Secretary Chris Wright, and USTR Jamieson Greer. Peru is the world's second-largest copper producer (~12% of mined supply), a top-two silver and zinc producer, the leading Latin American gold producer, and a globally significant source of tin, molybdenum, and lead — making it the most strategically important Latin American signatory of the FORGE founding cohort alongside Argentina.

On 4 February 2026, in Washington, DC, Philippine Secretary of Environment and Natural Resources Raphael P.M. Lotilla and US Under Secretary of State for Economic Affairs Jacob Helberg signed an intergovernmental Memorandum of Understanding to cooperate on diversifying global critical-mineral supply chains and to promote bilateral investment in mapping, survey, processing, refining, and recycling of critical minerals and rare earths. The MoU was one of eleven founding-member bilateral instruments signed simultaneously at the inaugural FORGE (Forum on Resource Geostrategic Engagement) Critical Minerals Ministerial hosted by Secretary of State Marco Rubio. The framework explicitly aims to push the Philippines' mining sector beyond raw-ore export toward domestic value-add and downstream processing.

On 4 February 2026, Secretary of State Marco Rubio launched the Forum on Resource Geostrategic Engagement (FORGE) at the inaugural Critical Minerals Ministerial in Washington, DC, attended by representatives from 54 countries and the European Commission. FORGE is the successor to the 2022 Minerals Security Partnership (MSP) and is structured as a plurilateral coalition that creates a preferential trade-and-investment zone for critical minerals, including coordinated price-floor mechanisms designed to counter adversarial market manipulation — explicitly framed against Chinese mineral-supply dominance. The Republic of Korea chairs FORGE through June 2026. Eleven bilateral critical-minerals frameworks/MoUs were signed simultaneously (Argentina, Cook Islands, Ecuador, Guinea, Morocco, Paraguay, Peru, Philippines, UAE, UK, Uzbekistan), and FORGE is paired with Project Vault, an EXIM Bank direct loan facility of up to USD 10 billion to back FORGE-aligned critical-mineral projects.

On 4 February 2026, in Washington, DC, US Deputy Secretary of State Christopher Landau and Uzbekistan Foreign Minister Bakhtiyor Saidov signed an intergovernmental Memorandum of Understanding on Securing Supply in the Mining and Processing of Critical Minerals and Rare Earths. The MoU was one of eleven founding-member bilateral instruments signed simultaneously at the inaugural FORGE (Forum on Resource Geostrategic Engagement) Critical Minerals Ministerial and supersedes the September 2024 Biden-era US-Uzbekistan critical-minerals MoU. On 18 February 2026, the U.S. International Development Finance Corporation (DFC) and EXIM signed Heads of Terms with Uzbekistan's Ministry of Investment, Industry, and Trade and the Fund for Reconstruction and Development of Uzbekistan establishing a Joint Investment Framework — including a proposed U.S.–Uzbekistan Joint Investment Holding Company — covering critical minerals (exploration, extraction, processing), infrastructure, and energy under a three-year Economic Cooperation Programme valued at up to USD 35bn.

On 3 February 2026, Glencore and the US-government-backed Orion Critical Mineral Consortium (led by Orion Resource Partners LP and the DFC) signed a non-binding MOU for Orion CMC to acquire a 40% stake in Glencore's DRC interests — Mutanda Mining (Mumi) and Kamoto Copper Company (KCC) — implying a combined enterprise value of approximately $9 billion. The transaction directly operationalises the December 2025 US-DRC Strategic Partnership Agreement at the equity level, giving the US government-backed buyer rights to appoint non-executive directors and to direct its share of copper and cobalt production to US-aligned offtakers. In 2025, Mumi and KCC together produced 247.8 kt copper metal and 33.5 kt cobalt, making this the largest single US critical-mineral equity-capture move in the DRC to date.