Insights on National Security

On July 13, the US Department of Defense/War (DoD) announced the immediate suspension of the Cybersecurity Maturity Model Certification (CMMC) Phase 2 requirements, which previously were scheduled to go into effect November 10. Contractors were subsequently invited to comment on the future of the CMMC.

Welcome to the August 2026 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

At the midpoint of 2026, the agriculture industry is navigating a complex and ever-changing legal landscape shaped by the evolution of artificial intelligence (AI), trade and capital-market uncertainty, regulatory reform, and other policy issues.

Welcome to the July 2026 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

On June 18, the US Department of Commerce, Bureau of Industry and Security (BIS), announced the release of one new General Authorization (GA) and one amended GA related to the January 16, 2025, “Securing the Information and Communications Technology and Services Supply Chain: Connected Vehicles” Rule (the Connected Vehicles Rule).

The US Department of Defense (DoD) issued a memorandum yesterday directing immediate suspension of the Cybersecurity Maturity Model Certification (CMMC) Phase 2 roll-out, which previously was scheduled to go into effect November 10.

Welcome to the June 2026 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

Making good on promises to lift US sanctions on Iranian oil, a new license lifts virtually all sanctions restrictions for two months on the production, sale, delivery, or offloading of Iranian crude oil, petroleum products, and petrochemical products.

Making good on promises to lift US sanctions on Iranian oil, a new license lifts virtually all sanctions restrictions for two months on the production, sale, delivery, or offloading of Iranian crude oil, petroleum products, and petrochemical products.

One week after the US House of Representatives passed a Farm Bill that expressly integrates food security into national security, Congressman John Moolenaar, Chairman of the Select Committee on China, and 13 bipartisan cosponsors introduced a standalone bill that would take significant additional steps aimed at safeguarding US national security and food security.

Welcome to the April 2026 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

Importers now have a path to reclaim tariffs they never should have paid.

The Trump Administration’s tariff strategy has undergone a significant legal pivot in recent weeks. After the February 20 US Supreme Court ruling that invalidated the International Emergency Economic Powers Act (IEEPA) tariffs, the Administration immediately announced that they would impose tariffs under alternative authorities, seemingly in an attempt to mirror the IEEPA tariff regime.

International Trade & Investment Counsel Sylvia Costelloe will lead a workshop titled “Connected-Vehicle AI & Data Compliance Lab” on March 9, 2026.

On February 11, the US Department of Commerce’s Bureau of Industry and Security (BIS) announced a settlement agreement and $252 million civil penalty against California-based Applied Materials Inc. and its subsidiary Applied Materials Korea, Ltd.

Welcome to the February 2026 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

In a January 20 interim final rule, the Bureau of Industry and Security (BIS) eased restrictions on the export, reexport, and transfer (in-country) of certain types of unmanned aerial vehicles (UAVs) to lower risk destinations.

Welcome to the January 2026 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

The past year, global trade upended. Through aggressive use of tariffs under the International Economic Emergency Powers Act (IEEPA), expanded Section 232 investigations, and a sustained enforcement crackdown, the Trump Administration made good on US Trade Representative (USTR) Jamieson Greer’s promise to “remake the global order.” The result: a fundamentally different operating environment for importers.

On January 15, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule revising its license review policy for exports of Nvidia H200 chips and its equivalents to China and Macau.

Last year saw a number of significant developments in US export controls and sanctions.

On January 2, President Trump issued an Executive Order (EO) under Section 721 of the Defense Production Act of 1950 requiring HieFo Corporation to divest the digital chips business of EMCORE Corporation, which it acquired in April 2024, due to national security concerns.

Welcome to the December 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

Welcome to the November 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and significant insights in an accessible format, concluding with our main takeaways — aka “And the Fox Says…” — on what you need to know.

It’s hard not to experience whiplash with export controls recently. A little over a month ago, the Bureau of Industry and Security (BIS) announced the new Affiliates Rule, which took effect immediately on September 29.