Industrial Policy & Trade Monitor· 2675 actions· ✨ 91 recent

On 30 September 2026 OFAC published a final rule (91 FR 61741) amending the Cuban Assets Control Regulations, 31 CFR part 515, to implement 2025 NSPM-5. It prohibits indirect financial transactions with entities and subentities on the State Department's Cuba Restricted List, adds an anti-evasion prohibition, removes the "U-Turn" funds-transfer general licence (§ 515.584(d)), and eliminates the group people-to-people travel and professional-meetings authorizations (grandfathering and wind-down provisions apply). Effective on publication.

On 30 September 2026 OFAC published a final rule (91 FR 61748) adding the Cuba Sanctions Regulations, 31 CFR part 516, to implement Executive Order 14404 of 1 May 2026, which established sectoral blocking sanctions on Cuba. The rule is issued in abbreviated form for immediate public guidance, with E.O. 14404 reproduced as an appendix; OFAC states it intends to supplement part 516 with fuller regulations that may include interpretive guidance, definitions and general licenses. It is effective on publication and adds no new designations.

On 23 September 2026 USTR announced the final country allocations of the FY2027 WTO tariff-rate quota for imported raw cane sugar. The total quota is 1,117,195 metric tons raw value (MTRV), the WTO minimum commitment; 1,061,202 MTRV was allocated by notice of 24 July 2026 (91 FR 46822) and the remaining 55,993 MTRV is distributed to additional countries in this announcement. In-quota quantities may enter the United States from 1 October 2026, and allocations to net sugar-importing countries require origin documentation and certificates of quota eligibility.

The Bureau of Industry and Security published a temporary final rule (91 FR 60505, RIN 0694-AK57) implementing the anti-stockpiling directive of Proclamation 11052 (6 August 2026), which sets Section 232 minimum import prices and tariffs on polysilicon and derivatives from 4 December 2026. The rule, effective 22 September through 3 December 2026, lets Commerce bar importers of record that import volumes substantially above their historic averages, caps weekly volumes of importers registered with CBP on or after 6 August 2026, and sets a waiver process.

On 18 September 2026 the President signed a proclamation extending Proclamation 10973 (originally issued 19 September 2025), which conditions issuance/entry on new H-1B specialty-occupation petitions on a $100,000 payment by the sponsoring employer, for a further 12 months through 21 September 2027 (exceptions remain at DHS Secretary discretion for national-interest cases). Alongside it the President signed a companion executive order, "Enhancing Program Integrity and Interagency Coordination in the Administration of the H-1B Nonimmigrant Visa Program," directing DHS, State and Labor to coordinate review of H-1B petitions and consult Commerce, Education and SBA on employment data, with heightened scrutiny for employers with recent or planned US-worker layoffs. The accompanying fact sheet cites a 92% drop in H-1B registrations by the largest IT-outsourcing firms (24,946 to 2,055) and a ~97% decrease in consular H-1B processing requests since the original 2025 proclamation. ## Severity basis Quant anchor from the primary source: $100,000 flat fee per covered H-1B petition, extended for a further 12-month term (through 2027-09-21); a measured 92% reduction in H-1B registrations by the largest IT-outsourcing filers (24,946 → 2,055) and a ~97% drop in consular H-1B processing requests attributed to the fee regime since its 2025 introduction. Severity 4/5: a binding, renewed cost barrier with a demonstrated order-of-magnitude effect on offshore-staffing-dependent filers, not a one-off or symbolic measure.

President Trump signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, into law on 18 September 2026, after the House concurred in Senate amendments on 16 September 2026 (262-159) and the Senate passed it on 7 August 2026 (86-11). The Act authorizes a 500% tariff on all US imports of Russian-origin goods and up to 100% tariffs on the top five importers of Russian oil and gas and the top five countries supporting Russia's oil "shadow fleet," alongside sanctions on Russian banks, the Russian financial system, and shadow-fleet vessels. It also extends the Iran Sanctions Act through 2031. All tariff/sanctions authority is discretionary: the President may decline to impose it by certifying to Congress that doing so serves the national interest, and may terminate it if Russia agrees to a durable peace with Ukraine. The Act sunsets five years after enactment.

The US Department of State amends the International Traffic in Arms Regulations (22 CFR Parts 120, 123, 125 and 126) to clarify certain policy-of-denial provisions, update country policies for Ethiopia and Somalia, add Saudi Arabia and Peru to the list of Major Non-NATO Allies (MNNA), and make other miscellaneous corrections. The Ethiopia change implements a February 5, 2026 Secretary of State determination terminating the ITAR policy of denial on defense-article and defense-service exports to Ethiopia's armed forces, police, intelligence and other internal-security forces — a change from the denial posture imposed during the Tigray war. Saudi Arabia and Peru's MNNA designations (Presidential determinations of January 13 and 14, 2026 respectively) make both countries eligible for preferential ITAR treatment, including certain license exemptions, priority license-application review, and participation in cooperative defense R&D programs. The rule is effective on publication.

On 18 September 2026 the U.S. Department of State published an interim final rule amending the International Traffic in Arms Regulations (ITAR) to remove certain uncrewed underwater vehicles (UUVs) from U.S. Munitions List Category XX(a), effective 19 October 2026. Vessels removed from the scope of Category XX(a)(10) that are not separately described elsewhere on the USML become subject to the Commerce Department's Export Administration Regulations (EAR) instead — a reclassification from the stricter State Department license regime to Commerce jurisdiction, not a full decontrol. The Department states the removed vessels "do not warrant control under the ITAR" and is separately soliciting comments on further refining UUV controls and license exemptions.

The US Department of Commerce issued a preliminary affirmative determination (case A-570-228) that tin mill products from China are being sold in the US at less than fair value, finding a China-wide dumping margin of 136.52% based on adverse facts available (no Chinese producer/exporter responded to the investigation), adjusted to a 130.17% cash deposit rate after offsetting the parallel countervailing-duty determination. Commerce also made a preliminary affirmative finding of critical circumstances, extending provisional measures and cash-deposit collection retroactively. The investigation was petitioned by United States Steel Corporation and the United Steelworkers union; final determinations are scheduled for around 1 December 2026.

OFAC added four Cuban state-owned nickel-sector enterprises to the SDN List under Executive Order 14404 — Centro de Investigaciones del Níquel (CEDINIQ), Empresa de Ingeniería y Proyectos del Níquel (CEPRONIQUEL), a technical/computing services entity (SERCONI), and Pinares S.A. — alongside three individual Cuban-national designations and a parallel round of military-modernization-linked designations. The action, publicised as "Further Sanctions on Cuba's Mineral Wealth and Military Modernization Apparatus," blocks all US-person transactions and freezes US-touching assets of the named entities, targeting the research, engineering and technical-services layer behind Cuba's nickel extraction and processing industry.

The US Department of Commerce issued a preliminary affirmative countervailing duty determination (case C-570-229) finding that producers/exporters of tin mill products from China received countervailable subsidies at a rate of 66.61% ad valorem, applied both to the individually-examined respondents (Shougang Holding Trade (Hong Kong) Ltd. and Shougang Jingtang United Iron & Steel Co. Ltd.) and to the all-others rate, based on facts available with adverse inferences after non-cooperation. Commerce also made a preliminary affirmative finding of critical circumstances, and directed CBP to suspend liquidation and collect cash deposits on entries from the date of publication. The final CVD determination is aligned to issue alongside the companion antidumping determination, currently scheduled no later than 2026-11-30.

On September 14, 2026, the US Treasury's Office of Foreign Assets Control designated VTB Bank Public Joint Stock Company under Executive Order 13902 (Iran financial-sector sanctions), citing correspondent banking relationships VTB built with sanctioned Iranian financial institutions and settlement systems VTB created for bilateral rial/ruble trade that Treasury says moved frozen Iranian assets. VTB was already designated under EO 13662 (2025) and EO 14024 (2022) for Russia-related conduct; this action adds an Iran-sanctions legal basis and SDN listing, part of the broader "Operation Economic Outcast" campaign Secretary Bessent announced August 24, 2026. No specific dollar figure for the moved assets was disclosed.

The US Department of State amends 22 CFR §126.1 of the International Traffic in Arms Regulations (ITAR) to extend the suspension of the Republic of Cyprus's status as a proscribed destination for defense exports, imports and sales for a further one-year period, from October 1, 2026 through September 30, 2027. The rule continues the current policy that originally lifted the arms embargo to Cyprus effective October 1, 2022, and has been renewed annually since. No new relief or restriction is introduced; the suspension is extended on its existing terms.

On 9 September 2026 President Trump signed five proclamations under Section 338 of the Tariff Act of 1930 responding to Canada's 8 September 2026 retaliatory tariffs on roughly $20bn of US exports (steel, dairy, agricultural equipment). The proclamations impose outright import bans on certain Canadian alcoholic-beverage and dairy products that had been subject to the 50% Section 338 duties imposed 22 August 2026 (following Canada's continued discrimination against US alcohol and dairy commerce), and separately exclude certain Canadian motor-vehicle-sector products from importation for the same reason. The proclamations also modify the product scope of the July 20, 2026 Section 338 tariff actions, removing items such as rock salt and cement and adding others, including all-terrain vehicles and additional dairy products. The import bans take effect 29 September 2026; the product-list modifications take effect 15 September 2026. The duties/bans apply regardless of USMCA origin and stack on top of Section 232 tariffs.

On 8 September 2026 President Trump signed an Executive Order, "Adjusting Certain Delegations Under the Defense Production Act," amending EO 13603 (National Defense Resources Preparedness) to split energy-related Defense Production Act authorities that had been held solely by the Secretary of Energy, giving the Secretary of the Interior independent authority over energy matters within Interior's purview. Disputes between the two Secretaries are routed to the National Energy Dominance Council (and, where national-security infrastructure is implicated, jointly to the National Security Council). The order additionally delegates DPA Section 101(c)(1)-(2) authority to the Secretaries of the Interior, Commerce, and Energy, each empowered to exercise it independently of the others. This is a second EO with the same title as the March 13, 2026 order (EO 14391), further reallocating the same delegation structure rather than replacing it outright.

Commerce initiated periodic administrative reviews of antidumping duty (AD) and countervailing duty (CVD) orders with July anniversary dates, following timely requests under 19 CFR 351.213(b). Among the named respondents are JFE Steel Corporation and Nippon Steel Corporation (Cold-Rolled Steel Flat Products from Japan, A-588-873), POSCO and Hyundai Steel Company (Corrosion-Resistant Steel Products from South Korea, A-580-878/C-580-879), China Steel Corporation (Corrosion-Resistant Steel Products from Taiwan, A-583-856), Interpipe entities (Oil Country Tubular Goods from Ukraine, A-823-815), and Goodluck India Limited and Tube Investments of India Ltd. (Cold-Drawn Mechanical Tubing from India, A-533-873). The notice also covers unrelated AD/CVD orders on goods including pasta, mattresses, citric acid, paper shopping bags, tires and PET film from other countries. Review periods are predominantly 1 July 2025 - 30 June 2026; Commerce intends to issue final results no later than 31 July 2027. This is a review of existing orders, not a new duty — current cash-deposit rates continue unchanged pending the review's outcome.

President Trump signed an executive order on 4 September 2026 directing the Secretary of Agriculture to prioritise Packers and Stockyards Act enforcement against concentrated meat-packer buying power (the four largest beef packers control ~85% of purchases, up from 36% four decades ago), modernise meat-inspection rules to lower processing costs, expand interstate shipment of state-inspected meat via a new USDA coordinator role, and establish a "Strengthening Processing for U.S. Ranchers" guaranteed loan program for small and regional beef processors. The order sets 60-day reporting deadlines for USDA but does not itself appropriate or specify a dollar figure for the new loan program.

FinCEN reissued the Southwest Border Geographic Targeting Order (GTO), requiring money services businesses (MSBs) in designated ZIP codes to file Currency Transaction Reports on cash transactions between $1,000 and $10,000 — below the standard $10,000 CTR threshold. The reissued order runs September 3, 2026 through March 1, 2027 (180 days) and covers Bernalillo, Doña Ana, and San Juan Counties in New Mexico and Cameron, El Paso, Hidalgo, Maverick, and Webb Counties in Texas. Newly-covered MSBs (relative to the March 2026 order) have a compliance date of October 3, 2026. Treasury Secretary Bessent framed the order as targeting Mexico-based drug-cartel money laundering through the border MSB channel.

On 4 September 2026, OFAC issued Iran General License CC, authorizing wind-down of transactions involving Golden Global Yatırım Bankası, Golden Global Varlık Kiralama, and Golden Global Portföy Yönetimi (three linked Istanbul financial entities blocked the same day under E.O. 13902), through 12:01 a.m. EDT on 19 September 2026. On 8 September 2026, following SDN designation of 34 entities and one individual — chiefly Iranian passenger airlines (Air Shiraz, ATA Airlines, Iran Air Tour, Iran Aseman, Mahan-network carriers among others) and their UAE/UK/Malaysia/Kazakhstan support entities — and suspension of Iran General License J-1 (which had authorized reexport of civil aircraft to Iran), OFAC issued General License DD, authorizing wind-down of civil-aviation-related and other transactions previously authorized under the Iranian Transactions and Sanctions Regulations, through 12:01 a.m. ET on 23 September 2026. Both licenses were formally published in the Federal Register on 11 September 2026. Neither license relaxes the underlying restrictions; both are time-limited exit ramps administering an already-restrictive posture.

Following concurrent first five-year ("sunset") reviews, the US Department of Commerce and USITC determined that revoking the antidumping duty orders on silicon metal from Bosnia and Herzegovina, Iceland and Malaysia, and the countervailing duty order on silicon metal from Kazakhstan, would likely lead to continuation or recurrence of dumping, countervailable subsidies and material injury to the US industry. Commerce published continuation of all four orders effective 2026-09-03, so US Customs and Border Protection keeps collecting AD/CVD cash deposits at the existing rates — Kazakhstan's 120.00% economy-wide CVD rate, Bosnia and Herzegovina's 21.41% AD rate, Iceland's 37.83%-47.54% AD range, and Malaysia's 12.27% final AD rate — for a further five years absent a subsequent review.

On September 2, 2026, OFAC amended its Venezuela minerals-sector general licenses to bring coal within their scope and to name a second Venezuelan state-owned company, Carbones del Zulia S.A. ("Carbozulia"), alongside the existing mining SOE CVG Compañía General de Minería de Venezuela C.A. ("Minerven"). GL 51D (supersedes 51C, dated August 27, 2026) authorizes export, sale, purchase and transport of Venezuelan-origin coal or minerals, including gold; GL 54C (supersedes 54B) authorizes supply of goods, technology and services to coal-or-minerals operations; and new GL 55A authorizes negotiating and entering contingent contracts (bids, MOUs, agreements in principle) for coal-or-minerals investment, each contract conditioned on separate OFAC authorization before execution. OFAC also amended FAQ 1247. All three licenses remain conditioned on US/UK/France/Singapore dispute-resolution forum selection, routing of blocked-person payments into the Foreign Government Deposit Funds established by Executive Order 14373, and continue to exclude Russia-, Iran-, North Korea-, Cuba- and China-linked counterparties.

The US Department of State published an interim final rule removing from the US Munitions List (USML) certain civil aircraft modified to incorporate aircraft survivability equipment (ASE) — directed infrared countermeasures (DIRCM) and the missile-warning systems that operate them, used to protect aircraft from MANPADS and other guided-weapon threats. Qualifying aircraft (FAA- or allied-NATO-certificated transport/commuter types before modification) move from State/ITAR licensing jurisdiction to the less restrictive Commerce/EAR regime under ECCN 9A991.b. The rule also excludes certain reexport and temporary-import activities involving such ASE from ITAR licensing requirements entirely. Effective October 13, 2026, with public comments accepted through September 28, 2026.

The US Department of State extended, through 30 August 2028, a standing temporary modification of Category XI(b) of the US Munitions List (USML) — the ITAR category covering electronic systems and software specially designed for collecting, surveying, monitoring or exploiting the electromagnetic spectrum for intelligence purposes. The modification reinstates pre-30-December-2014 control scope by reinserting the phrase "analyze and produce information from" and adding software to the Category XI(b) description, after a 2014 USML revision was read by some exporters as narrowing coverage of intelligence-analytics software. This is the latest in a chain of extensions dating to the original July 2014 rule (79 FR 37536), most recently extended through August 2026 (86 FR 48021); no new items are added to or removed from the Munitions List by this action.

President Trump signed Executive Order 14420 on 26 August 2026, declaring a national emergency under IEEPA and the National Emergencies Act over foreign threats to the US bulk-power system. The order generally prohibits the acquisition, import, transfer, or installation of foreign-produced bulk-power system electric equipment — transformers, inverters, battery storage, generators, circuit breakers, turbines, and industrial control systems, including associated software and remote-access capabilities — where a transaction involves a "Covered Foreign Entity" and poses a risk of sabotage, unauthorized access, or catastrophic disruption to critical infrastructure. Local electric distribution facilities are excluded. No countries or companies are named in the order itself; DOE must publish implementing rules within 120 days (by 24 December 2026) identifying covered equipment and entities, and submit recommended Federal Acquisition Regulation revisions within 180 days.

On 26 August 2026, President Trump signed a proclamation temporarily expanding the in-quota tariff-rate quota for lean beef trimmings by 300,000 metric tons, released in three 100,000 mt tranches over 90 days starting 1 September 2026. The additional volume lets eligible trading partners (excluding FTA partners and countries with existing country-specific quotas) import lean beef trimmings for combination with U.S. beef into ground beef at the lower in-quota duty rate rather than the higher out-of-quota rate, on a first-come, first-served basis across four specific HTSUS statistical lines. Importers are directed to pass through a 25% discount from the going import price. The measure responds to elevated U.S. ground-beef prices driven by a shrunken domestic cattle herd and screwworm-related border disruption, and follows an earlier TRQ expansion the White House dates to 6 February 2026.

The Bureau of Industry and Security (BIS) issued a final rule (FR Doc. 2026-17231) removing two Hong Kong Science Park / Kwai Chung addresses from the Entity List entry for Arrow Electronics (Hong Kong) Co., Ltd. under the destination of China. The Hong Kong entity itself remains listed; only the two named addresses are dropped as recognized locations for that entry. Effective August 21, 2026. This is the second narrowing of the Arrow Electronics Entity List footprint in under a year, following the November 2025 removal of Arrow China Electronics Trading Co., Ltd. and six aliases.

On 24 August 2026, the Director of OFAC, in consultation with the Department of State and pursuant to 31 CFR 560.802, determined that section 1(a)(i) of Executive Order 13902 shall apply to the aviation, digital asset, gold, shipping, and technology sectors of the Iranian economy, effective the same day and formally published in the Federal Register on 27 August 2026 (FR Doc 2026-17487). The determination — part of a Treasury campaign publicly branded "Operation Economic Outcast" — exposes any person operating in, or knowingly engaging in a significant transaction for the sale, supply, or transfer of significant goods or services to or from, these five sectors to secondary-sanctions and SDN-listing risk under E.O. 13902, and extends potential correspondent/ payable-through account restrictions to foreign financial institutions that knowingly facilitate such transactions. OFAC did not publish sector definitions and concurrently suspended several general licenses covering educational exchange, personal remittance, conference, and academic/ sports-exchange activity with Iran (administered separately via GL AA and GL BB, wind-down through 8 September 2026).

President Trump signed a Section 232 proclamation on 13 August 2026 (published in the Federal Register 19 August 2026, FR doc 2026-16979) imposing tariffs on unmanned aircraft systems (UAS/drones) and components, following a Commerce Department finding that US reliance on foreign-produced (chiefly Chinese, e.g. DJI/Autel) drones and critical components creates supply-chain and cybersecurity national- security risk. A 100% ad valorem tariff applies to Annex I items (drones with maximum takeoff weight over 25kg, thermal-imaging drones, docking stations, and listed critical components); a 25% ad valorem tariff applies to Annex II items (other listed UAS). Qualifying-origin content from the EU, Japan, Korea, Switzerland, Taiwan and Liechtenstein is capped at 15%; UK-origin content is capped at 10%. UAS duties take effect 3 September 2026; component duties take effect 9 February 2027. The proclamation also authorizes Commerce to set up an onshoring program giving temporary relief to firms committing to build or expand US production of covered drones and components.

BIS published a temporary final rule under DPA section 101 (following a Presidential Determination dated July 30, 2026 that recoverable critical minerals and materials are scarce and essential to national defense) requiring U.S. persons to allocate 100 percent of their monthly sales of black mass (shredded lithium-ion battery scrap containing lithium, cobalt, nickel, manganese and graphite) and tungsten waste and scrap to other U.S. persons, effectively barring export of these materials without an explicit BIS adjustment or exception. The order takes effect August 27, 2026, runs for one year through August 27, 2027, and BIS is accepting public comments through November 4, 2026 on whether additional sales requirements are needed. This is the first US DPA/export-control action targeting the recycling and secondary-materials stage of the critical minerals supply chain, rather than primary mining or refining.

On 24 July 2026 Commerce's International Trade Administration published the preliminary results of the first full five-year ("sunset") review of the countervailing duty order on phosphate fertilizers from Morocco (case C-714-004, in force since 2021). Commerce preliminarily determined that revoking the order would likely lead to continuation or recurrence of a countervailable subsidy to OCP Group at a rate of 20.04% ad valorem — well above OCP's most recent administrative-review rate of 16.81% and the 2.11% rate that applied after a December 2025 court remand. The review is procedural and does not itself change the duty currently being collected; it addresses whether the underlying CVD order survives long-term, separate from the temporary emergency AD/CVD duty-free window the White House granted on 29 June 2026.

President Trump signed Executive Order 14415 on 20 July 2026, tightening the 10 U.S.C. 4872(c)(1) "specialty metals" waiver process for defense contractors: from 1 January 2027, waivers will be granted only under approved mitigation plans showing "exhaustive efforts" to source compliant materials and a documented timeline for removing non-compliant content. The order requires the Secretary of War to develop, within 180 days, a supply-chain mapping policy compelling contractors to trace covered materials to raw-material origin ("indentured Bill of Materials"), with final implementing regulations due 90 days after that, and a source-qualification acceleration strategy for domestic and allied alternatives to "unreliable foreign suppliers" due within 90 days. Mandatory progress reporting runs at 6-month intervals through 1 January 2028. The order explicitly preserves the U.S. Strategic Critical Minerals Reserve ("Project Vault") and Export-Import Bank-financed or government-backed sourcing arrangements from its restrictions.

BIS published a final rule removing the UAE from Export Administration Regulations Country Groups D:3 and D:4 and adding it to Country Group A:5 — the tier reserved for the closest US allies. The change unlocks License Exception STA (military items, commercial satellites/spacecraft, and dual-use goods for oil/gas, desalination and civil nuclear power) plus several other license exceptions, and grants the UAE government and BIS-preapproved entities (currently G42 and Core42 only, per Supplement No. 8) license-free export of advanced computing items. Preapproved private entities have a 270-day window to become majority US-owned or lose automatic eligibility; other private UAE entities must still petition BIS case-by-case.