USA Law and Practice Contributed by: Bruce G. Paulsen, Brian Maloney and Hannah Thibideau, Seward & Kissel LLP
Seward & Kissel LLP One Battery Park Plaza New York, NY 10004 USA Tel: +1 212 574 1200 Fax: +1 212 480 8421 Email: marketing@sewkis.com Web: www.sewkis.com
1. Trends and Overview 1.1 Sanctions Market
lion plan for Iran’s “reconstruction”, and the United States terminating sanctions on Iran. The agreement calls for an end to hostilities and started a 60-day negotiating clock to reach a final deal on the future of Iran’s nuclear programme. It is uncertain whether this agreement will result in a more permanent resolution and, even if it does, whether it will end the Trump administration’s campaign of maximum pressure on Iran in the year to come. In Venezuela, the Trump administration has issued several licences that permit specific oil, gas, petro - chemical, electricity, and minerals sector activities that were previously prohibited, apparently encour - aging industry back into the country. Lastly, the US Congress passed the Comprehen - sive Outbound Investment National Security Act (the “COINS” Act) as part of the National Defense Authori - zation Act (NDAA) in December 2025. The COINS Act broadens many aspects of the restrictions currently in place as a result of the Outbound Investment Security Program, including expanding the covered technolo - gies to include high performance/supercomputing and hypersonic systems, while also widening the geo - graphic scope to include Cuba, Iran, North Korea, and Venezuela. This expansion of the Outbound Program will likely lead to more enforcement efforts. Overall, existing US sanctions laws and regulations continue to expand and be vigorously enforced against both US and non-US persons and entities alike, across the full range of the more than three
The field of economic sanctions in the past several years has been characterised by dynamic and rapid growth and development, particularly with respect to the Russia and Iran sanctions programmes, among other country, industry and policy initiatives, including legislation and regulations directed at China, Vene - zuela, the fintech/virtual currency, shipping and trans - portation industries, the area of cybersecurity, and a long-standing commitment to counter global human rights violations. Sanctions regulation and enforce - ment show no signs of abating as the US government continues to employ these tools to address current national security and foreign policy priorities. 1.2 Key Trends In 2026, there has been a notable shift in political messaging and tone from the Trump administra - tion, together with certain adjustments in emphasis regarding US national security and foreign policy pri - orities. At the time of publication, this is reflected in the memorandum of understanding between Iran and the United States in the wake of the war, updated leg - islation regarding the Outbound Investment Security Program, and the easing of enforcement of traditional sanctions programmes against Venezuela. On 17 June 2026, President Trump and President Masoud Pezeshkian of Iran signed a memorandum of understanding, aiming to end the war between the two countries. The agreement included terms regard - ing reopening the Strait of Hormuz, a USD300 bil -
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