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Treasury Proposes Broader Outbound Investment Controls, Extending Restrictions to Biotechnology

U.S. Treasury Building, Washington
The Treasury Department has proposed expanding restrictions on U.S. investment in sensitive foreign technologies, with consequences for technology companies, private investment funds, multinational businesses and drug developers. The October 22 proposal would broaden existing controls on semiconductors, artificial intelligence and quantum technologies while adding biotechnology, hypersonic systems and additional high-performance computing activities. 
Kaja Kallas, High Representative for Foreign Affairs and Security Policy/Vice-President of the European Commission
The proposed EU action would shield European banks, technology companies and other service providers from U.S. sanctions targeting the International Criminal Court, potentially creating conflicting legal obligations for firms operating in both jurisdictions. Brussels is preparing to extend its blocking statute as Washington presses the court to amend the Rome Statute to protect President Trump and other U.S. officials from prosecution.

Aid and Comfort

President Trump issued an executive order on October 16 implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 while waiving its tariff provisions and numerous sanctions and restrictions.

Russian diesel deal challenges congressional sanctions policy and divides allies

The diesel agreement puts the administration’s drive to lower fuel prices before the midterms at odds with Congress’s effort to deny Moscow revenue for its war against Ukraine and Britain’s commitment to maintaining sanctions pressure.

Welcome to Your WTTL

The Washington Tariff and Trade Letter introduces a web-based format for easier review, research and sharing.  Clicking on a story in the newsletter will now bring you to the full text on our new web site. A .pdf version of the newsletter is available below.   For any questions about website access and your subscription, please contact us at Info@TradeRegs.com – Or call the Editor, Frank Ruffing, at +1.703.283.5220

The latest news

China Expands Reporting Requirements for Overseas Investments

China’s National Development and Reform Commission has revised its outbound investment rules to require immediate reporting of certain foreign demands for technology, data or divestitures. The Measures for the Administration of Outbound Investment, announced October 22, take effect December 1, 2026, replacing the 2017 measures.

Importer Challenges Trump’s Section 338 Tariffs on Canadian Goods

A U.S. food importer has filed the first legal challenge to President Donald Trump’s use of a dormant provision of the Smoot-Hawley Tariff Act to impose 50 percent duties and import restrictions on …
More trade & tariff news

Trump Reshuffles 50% Canada Tariffs

The reshuffling provides targeted relief to politically sensitive industries without reducing the broader tariff burden or easing the U.S.-Canada trade conflict. It also reinforces concerns that the administration views Section 338 as a flexible tariff power that permits rapid product changes without ordinary procedural safeguards—an interpretation now facing its first court challenge.

China Sets Review Deadlines for Dual-Use Exports

China’s revised procedures offer greater predictability when suppliers’ shipments face scrutiny over potential dual-use export controls, along with a way to seek separate clearance of unrelated goods.

UK Proposes Updates to Strategic Export Controls, Including Advanced Technology Restrictions

The proposed amendments would update UK military and dual-use controls, including those covering semiconductor manufacturing equipment, advanced computing and specialised materials; revise country listings for Haiti and the Central African Republic; and phase out GEA001 in Great Britain.

Extradition Advances U.S. Prosecution of Cryptocurrency Scam Network

U.S. prosecutors have brought an alleged cryptocurrency scam money launderer from the Netherlands to a California courtroom, advancing a case involving more than $36.9 million in victim funds routed through U.S. bank accounts, a Bahamian bank, and stablecoin wallets to Cambodian scam operators.
The Office of the U.S. Trade Representative announced separate developments under the United States–Mexico–Canada Agreement’s Rapid Response Labor Mechanism: successful resolution of the Amphenol Optimize México case and a remediation plan for Newmont’s Minera Peñasquito mine. Both matters concern interference with union activity and retaliatory dismissals.
The Bureau of Industry and Security’s Affiliates Rule remains scheduled to return on November 10, 2026. The reported extension of the U.S.–China Busan trade agreement through January 10, 2027, could prolong the suspension, but Commerce has not confirmed that the extension covers the rule. Once reinstated, the rule will extend specified Export Administration Regulations restrictions to unlisted foreign entities owned at least 50 percent, directly or indirectly, individually or in the aggregate, by covered parties on the Entity List, Military End-User List or SDN List under sanctions programs identified in EAR § 744.8(a)(1).
 The proposed GAO investigation would extend oversight of the $166 billion IEEPA tariff refund program beyond compliance with court orders to examine whether CBP is accurately distributing refunds, preventing improper payments and accounting for the economic benefits.
A Miami-area cryptocurrency broker faces a federal money laundering conspiracy charge over his alleged role in a Russian network that converted drug proceeds into cryptocurrency and bank payments through an international system of brokers and cash couriers.
The Federal Communications Commission is seeking comment on whether satellite and earth station applicants should certify compliance with U.S. export controls, maintain supporting records, and disclose related federal reviews in transactions involving foreign ownership. The proposals would expressly connect FCC licensing with obligations under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR).
Wind turbines, IJsselmeer, Netherlands

Tilting at Windmills

President Trump directed Commerce Secretary Howard Lutnick and U.S. Trade Representative Jamieson Greer to negotiate agreements addressing wind-turbine imports, adding a trade measure to his administration’s efforts to restrict wind development.

Who’s on First? Stablecoin AML Rules Remain a Work in Progress

The OCC has completed its prudential rule, but Treasury and banking regulators are still defining the new illicit-finance framework. Existing obligations remain enforceable.

OFAC Removes Chinese Cartoon Firm and another Belarusian from SDN List

The removals unwind sanctions imposed in 2021 on Chinese animation businesses and an intermediary accused of supporting North Korea’s SEK Studio, and on a Belarusian executive designated for acting on behalf of state oil and chemical concern Belneftekhim.

Final Stablecoin Rules: Eases Restrictions, AML Still Unsettled

The OCC’s final rule establishes reserve, capital, redemption and supervisory standards for stablecoin issuers but drops proposed restrictions on indirect yield payments, raising banking industry concerns over deposit competition. Separate FinCEN-OFAC proceedings leave key anti-money laundering and sanctions requirements unresolved ahead of the January 18, 2027, effective date.