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On 21 June 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorising certain transactions relating to the production, sale, delivery and offloading of Iranian-origin crude oil, petrochemical products and petroleum products. This represents a remarkable — if temporary — departure from the comprehensive United…

EU customs authorities are intensifying enforcement around customs classification, with scrutiny of goods assembled in the EU after importation. The European Public Prosecutor’s Office (EPPO) 2025 Annual Report explicitly identifies assembly operations performed after import as a common fraud pattern used to evade customs duties. The concern centres on components that, when classified individually, attract…

Key Takeaways

  • OFSI has published updated enforcement guidance introducing a new case assessment matrix, discount structures, a settlement scheme, and fixed penalties for procedural breaches.
  • The new framework allows for cumulative discounts for voluntary disclosure (up to 30%), settlement (20%), and the Early Account Scheme (up to 20%), which can reduce penalties by up to 70%.
  • Fixed penalties of £5,000 or £10,000 will apply to information, reporting, and licensing breaches.
  • OFSI plans to double maximum penalties to £2 million/100% of breach value.
Continue Reading Carrot over the Stick? Reforms to OFSI Civil Enforcement Processes incentivise early engagement and settlement

The European Parliament and Council have reached a provisional political agreement to permanently end all imports of Russian natural gas into the EU on an accelerated timetable. The deal brings forward key deadlines for LNG and pipeline gas, tightens limits on contract amendments, enhances anti-circumvention and origin-tracking rules, and strengthens enforcement with significant penalties. Member…

The distinctive features that set a luxury brand’s products apart aren’t created only on the factory floor. For example, a company’s sketches from Paris, R&D in Milan, and artisanal prototypes perfected in Tokyo all flow into the production line. These upstream inputs (known as assists) must be carefully managed to avoid issues when the final…

As global trade barriers rise and regulatory frameworks grow more complex, data centers must implement robust legal strategies to address customs valuation, origin rules, import/export controls, and maintenance-related trade challenges.

In a recent post, published as part of our Data Centers: Bytes and Rights series, we highlight and examine five key compliance areas that…

In a time of escalating tariff tensions, companies are investing heavily in analyzing the impact of tariff changes on their business and adapting to the shifting trade landscape. To mitigate tariff impacts and maintain competitiveness, many explore supply chain adjustments, such as alternative sourcing or relocating production. While “tariff engineering” is becoming an increasingly popular…

In 2024, the Department of Justice saw a record number of qui tam actions under the False Claims Act (FCA), with total settlements and judgments exceeding $2.9 billion. Throughout this next year, we expect to see this uptick in enforcement continue, especially in light of the Trump administration’s crackdown on diversity, equity, and inclusion policies…

With U.S. President Donald Trump’s recent return to the White House, major regulatory changes are on the horizon for 2025. On Thursday, January 23rd, we gathered a group of regulatory attorneys from across Reed Smith to provide a one-hour CLE that outlined the key trends to watch for this year. In their latest…

After various delays, on 19 February 2024 the EU Commission issued its FAQ guidance on Article 3q of Council Regulation (EU) No. 833/2014 (as amended). The FAQ document provides some key clarifications sought by the market. However, some uncertainties remain…
Continue Reading EU Clarifies Article 3q for Tanker S&P Market