Week of 14 to 20 September 2026
Legislative, regulatory and case-law review
International sanctions: France blocks renewal of the Russia regime, OFAC hits VTB Bank
On 14 September 2026, France, joined by Slovakia, vetoed the six-monthly renewal of the EU’s individual sanctions regime against Russia, demanding that the Russian-Uzbek businessman Alisher Usmanov be removed from the blacklist. Paris cites a national security concern that several media outlets link to negotiations on the release of French nationals detained in Azerbaijan. Since individual sanctions must be renewed unanimously every six months, the refusal of two states is enough to block the whole regime. Coreper obtained only a seven-day technical extension, moving the deadline to midnight on 22 September; failing unanimous agreement, the restrictive measures applying to some 3,000 persons and entities would temporarily cease to have effect. The Nordic and Baltic countries and Ukraine firmly oppose any lifting of sanctions.
On the US side, OFAC announced on 14 September, under « Operation Economic Outcast », the addition to the SDN list of VTB Bank, Russia’s largest bank by assets, for establishing correspondent banking relationships with sanctioned Iranian institutions.
What it means for businesses: cut ties with VTB Bank immediately given the risk of secondary sanctions; follow the outcome of the deadlock before 22 September, failing which all asset freezes, apart from Usmanov’s, would temporarily lapse.
US tariffs: first IEEPA refunds, the « forced labour » litigation intensifies
On 18 September 2026, CBP announced that the next phase of the refund programme for IEEPA duties struck down by the Supreme Court in February would open on 6 October, covering shipments liquidated more than ninety days earlier. Meanwhile, the litigation over the 10 to 12.5% surcharge imposed by the USTR under Section 301 on forced-labour grounds, applicable to sixty partners including the EU, is intensifying: importers and Democratic-led states argue that the investigation was merely a « pretext » to recreate the invalidated IEEPA duties, the surcharge having taken effect on the very day the Section 122 duties expired. The Court has set the hearing on the merits for 30 September.
What it means for businesses: prepare refund claims for entries liquidated more than ninety days ago; follow the 30 September hearing, on which the survival of the surcharge depends.
EU case law: the General Court treats two sanctioned Russian nationals differently
In two judgments of 16 September 2026, the General Court clarified the evidentiary requirements on the Council when renewing sanctions. In Trotsenko v Council (T-459/24, ECLI:EU:T:2026:569), it dismisses all the pleas and upholds the continued listing of this coal, energy and infrastructure operator, a substantial source of revenue for the Russian government. In a second case, concerning the singer Polina Gagarina, it upholds the initial 2024 listing but annuls its 2025 renewals, as the Council had not updated its evidence file.
What it means for businesses: at each six-monthly renewal, the Council must produce up-to-date evidence of the ground relied on; a challenge is better aimed at outdated evidence for the contested renewal than at the initial listing.
Customs regulation: the European Parliament gives final approval to the Customs Code reform
On 16 September 2026, the European Parliament adopted at second reading the reform of the Union Customs Code, following the Council’s final approval on 3 September: the most significant reform since 1968. The text makes e-commerce platforms based outside the EU the importers of goods sold to European consumers, introduces penalties of up to 6% of the annual value of imports, creates the EU Customs Authority in Lille, operational in 2027, and a customs data hub that becomes mandatory for e-commerce on 1 July 2028 and for all operators on 1 March 2034. Handling fees on small parcels will apply from 1 November 2026. The text must now be signed and published in the Official Journal.
In France, the export-followed-by-transit procedure based on DELTA T was rolled out on 15 September, with DELTA X Import fully decommissioned: requests for invalidation and correction now go through the paper forms DI2D and DR2D.
What it means for businesses: prepare for platforms’ new status as importers; switch without delay to the paper procedure for any requests still pending in DELTA X Import.
Trade agreements, CBAM and investment screening: matters on hold
No notable development this week on the EU-Mercosur agreement, whose ratification remains suspended pending the Court of Justice’s opinion, nor at the WTO, nor on the CBAM or foreign investment screening, Regulation (EU) 2026/1386 still being in its national implementation phase.
The firm advises on international trade law, including sanctions compliance and customs law.
Previous edition: Weekly Digest: International Trade Law (7-13 September 2026)
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