The US sanctions regime against Iran reached a critical inflection point this week. General Licence X (GLX), issued by OFAC on 22 June 2026 to authorise the production, delivery, and sale of Iranian-origin crude oil and petrochemical products (including associated shipping, port operations, insurance underwriting, financing, and US dollar payments), was revoked on 7 July following Iranian attacks
The United States activated the second-stage statutory sanctions mechanism under the Chemical and Biological Weapons Control and Warfare Elimination Act (CBW Act) against Sudan's Armed Forces (SAF), effective 20 July 2026. The designation stems from a formal US government determination — made in April 2025 — that the SAF used chlorine barrel bombs north of Khartoum in 2024. The SAF's failure to ce
Source: Modern Diplomacy: Sanctioning Sudan's Army — Washington's Chemical Weapons Red Line Meets Riyadh's RealpolitikLegal RiskGeopoliticsSanctions & Trade
The EU adopted its 21st package of Russia sanctions on 23 July 2026 — the largest in terms of individual designations in four years. The package covers: 48 individuals and 170 entities subject to asset freeze and travel ban; 33 Russian banks newly subject to transaction bans; 94 Russian banks and financial institutions total (with prior transaction bans expanded to include asset freezes); new thir
A coalition of 25 Democratic-led states filed a complaint in the US Court of International Trade on August 3 challenging tariffs of 10% or 12.5% imposed on goods from 60 US trading partners — economies collectively accounting for 99.4% of US imports. The tariffs were announced on July 23, one day before temporary Section 122 tariffs expired; the states allege this timing demonstrates the administr
AFS Law's July 2026 customs and trade roundup documents two significant enforcement-adjacent actions. OFAC revoked its Iranian oil general license after just two weeks, following renewed attacks in the Strait of Hormuz, leaving only a short wind-down window — illustrating how rapidly sanctions authorizations can reverse in the US-Iran military conflict context. Separately, BIS revised its licensin
Effective July 24, 2026, the Trump administration imposed 10% tariffs on approximately 60 economies that have adopted forced-labor import prohibitions, and 12.5% on those that have not, under Section 301 of the Trade Act of 1974 — covering roughly 99.4% of US imports. The duties replaced the expiring 10% Section 122 across-the-board surcharge, itself a replacement for the IEEPA "Liberation Day" re
The Liberty Justice Center filed suit in the US Court of International Trade on July 24, 2026, within hours of the Section 301 forced-labor tariffs taking effect — the same organization whose litigation produced the Supreme Court's February 2026 IEEPA ruling. The lawsuit argues Trump's 10–12.5% duties are an unlawful attempt to restore the global tariff policy the Supreme Court already struck down
The 10% global blanket tariff under Section 122 expires at 12:01 AM July 24, 2026 — the statutory 150-day limit. The replacement mechanism is USTR's Section 301 forced-labor duties, finding all 60 nations deficient as of June 2. Proposed rates: 10% on 15 countries with existing forced-labor frameworks (Canada, Mexico, UK, EU, Switzerland, Norway, and others); 12.5% on 46 countries including China,
USTR concluded its 12-month Section 301 investigation on July 15 and announced a 25% tariff on most Brazilian imports (HTSUS 9903.05.01) effective July 22, 2026. Covered categories span digital trade, electronic payment services, IP protection, ethanol market access, anti-corruption enforcement, and illegal deforestation. Carve-outs include Section 232 goods (steel, aluminum, copper, autos), civil
Three presidential proclamations under Section 338 of the Tariff Act of 1930 — a near-century-old statute — target Canadian motor vehicles, wine/beer, dairy, hockey sticks, cement, furniture, and refrigeration machinery with 50% tariffs effective August 19. Critically, these tariffs are NOT blocked by USMCA qualification, unlike USMCA-compliant goods that were exempt from Section 122. Canadian 25%
Following a Section 232 investigation citing 54% of US patented pharmaceuticals manufactured abroad, a 100% baseline tariff on pharmaceuticals takes effect for Annex III companies on July 31, with remaining companies following September 29. Company/country-specific exclusions and rate reductions exist for approved onshoring commitments; EU/Switzerland/UK/Japan rates are aligned with trade agreemen
OFAC issued General License X1 on July 7, superseding GL X and terminating the sanctions waiver for Iranian oil exports structured to run through August 21. In the 16 authorized days (June 22–July 7), approximately 20 Iranian tankers moved ~70 million barrels generating an estimated $5–6bn in export revenue before the ceasefire talks collapsed. Cargoes loaded before July 7 face payment and clearan
The bipartisan Sanctioning Russia Act (S. 1241, July 10) would impose up to 100% tariffs on the top five purchasers of Russian crude oil or natural gas, with an exception for countries importing less than 15% of Russia's natural gas and taking "significant steps" to reduce. Mandatory sanctions on Putin, senior military/political leaders, oligarchs, state-owned enterprises, banks, the shadow fleet,
The US declined to extend USMCA at the first joint review (effective July 1, 2026). The agreement remains fully operational but now enters a 10-year annual review cycle until 2036, with a 6-month withdrawal notice required for actual termination. This increases policy uncertainty for over $1.6 trillion in annual North American trade. A subsequent 6-month withdrawal notice could be triggered at any
The July 1, 2026 USMCA joint review concluded without renewal: the United States declined to extend the agreement in its current form, triggering the annual review mechanism under Article 34.7 that keeps the agreement in force but subjects it to annual renegotiation until 2036. The first annual review session began July 20, 2026, with Mexico immediately signaling it would target auto and steel tar
OFAC recorded eight separate sanction actions in the seven-day window ending July 16, across Iran, Cuba, Russia, cyber-related, counter-terrorism, non-proliferation, and the Democratic Republic of the Congo. Iran led volume: designations and a designation update on July 14, designations and a new general license on July 10, and an amended general license on July 8. Russia saw an amended general li
On July 1, 2026, the USMCA Free Trade Commission held its mandatory six-year joint review under Article 34.7, and the United States declined to confirm a 16-year extension, with USTR Ambassador Jamieson Greer stating the US "did not agree to renew the USMCA in its current form," even as Mexico and Canada both confirmed support for renewal. For law firms advising North American supply chain clients
The European Union's regulatory filing confirming its side of the EU-US trade agreement took effect July 1, 2026, removing import duties on a range of US goods and applying through December 31, 2029, with built-in safeguards allowing the EU to suspend concessions if Washington breaches the deal's terms. Trade counsel should flag the sunset date and snap-back mechanism to clients now, since the fou
Treasury's Office of Foreign Assets Control designated a Kigali-based gold refinery, its executives, and affiliated Rwandan mining companies on June 25 for laundering gold mined in M23/Rwanda Defence Force-occupied territory in eastern Congo, followed on June 26 by sanctions on eight individuals and entities tied to procurement and recruitment networks sustaining Sudan's civil war. For sanctions a
China escalated its counter-measures this week, sanctioning 56 U.S. companies — including rare-earth miners, defense-linked firms, and Alibaba's U.S.-facing entities — in direct retaliation for a Pentagon "CMC List" designation. The sanctions impose asset freezes within China and prohibit any Chinese entity or individual from conducting business with the listed firms, effective June 30. Alibaba se
U.S. Customs and Border Protection issued two new Withhold Release Orders on June 23 targeting garment producers Needle Craft Ltd. and Casual Wear Apparel LLC in Jordan, and confirmed a separate WRO against Serbia Zijin Copper — the second Serbian operation targeted in six months. WROs immediately trigger detention of all shipments at U.S. ports of entry, requiring importers to either re-export go
The EU gave final Council approval on June 25 to legislation implementing the July 2025 EU-US tariff framework, meeting Trump's July 4 deadline by days. Under the deal, the EU removes import duties on all U.S. industrial goods and grants preferential access to U.S. seafood and agricultural products; the U.S. caps tariffs on most EU exports at 15%, covering autos, pharmaceuticals, and semiconductor