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6.17.26
Key U.S. Import Developments, June 2026
With new and novel tariffs yielding to court decisions rendering those tariffs unlawful (only to be replaced with newer tariffs—and more litigation about the newer tariffs), and with the Section 122 temporary import surcharge of 10 percent nearing expiration in a matter of weeks, businesses have faced extraordinary uncertainty in navigating trade policy.
Alerts
6.02.26
China’s Enhanced National Security “Great Wall”– Supply Chain Security, Red Lines, and Blocking Rules
Recently, the People’s Republic of China (PRC or China) introduced further unprecedented national security measures spanning sanctions, supply chain security, and data security, in addition to blocking rules to protect the internal market from the extraterritorial effects of certain foreign regulatory measures. These developments build on the PRC’s already well-established national security framework, and underscore China’s determination to construct a fortified system designed to shield its supply chains and legal order from foreign influences it deems unjustified. These measures increasingly create potential conflicts of law and pose complex compliance, governance, and commercial challenges for businesses striving to navigate multiple major regulatory regimes worldwide.
Client Highlights
6.01.26
Wilson Sonsini Advises Credo on Regulatory Matters Related to Acquisition of DustPhotonics
On May 28, 2026, Credo Technology Group Holding Ltd (Credo), an innovator in providing connectivity at scale through fast, reliable, and energy-efficient system solutions, announced that it has completed its acquisition of DustPhotonics in a transaction valued up to $1.3 billion. DustPhotonics brings industry-leading silicon photonics photonic integrated circuit (SiPho PIC) technology for optical connectivity, deepening Credo’s optical interconnect portfolio across 800G, 1.6T, and 3.2T near-packaged optics (NPO) and co-packaged optics (CPO). Wilson Sonsini Goodrich & Rosati advised Credo on regulatory matters related to the transaction.
Alerts
5.27.26
Proposed Department of Defense Rule Requires FOCI Mitigation for Unclassified Contracts Valued at More than $5 Million
On May 7, 2026, the Department of Defense (DoD) proposed changes to the Defense Federal Acquisition Regulation Supplement (DFARS) that, when finalized, will impact nearly 38,000 defense contractors and subcontractors. The proposed changes will require companies to disclose foreign ownership, control, or influence (FOCI), which they must mitigate before the contracting officer can award, modify, or extend a contract.
Alerts
5.18.26
The “Friendly Buyer” Fallacy: Why U.S. Ownership Is No Longer a Regulatory Safe Bet
Over the past decade, the number of countries with foreign direct investment (FDI) screening regimes has more than doubled. What was once a niche, rarely-used regulatory tool has become a standard feature of global deal-making and a routine consideration in cross-border M&A, including U.S. to U.S. transactions that involve the indirect acquisition of foreign subsidiaries. As jurisdictions continue to strengthen their FDI screening regimes, parties are seeing more U.S.-led deals encounter longer and more intrusive reviews and increasingly complex conditions as a condition of approval.
Alerts
5.08.26
FCC Sets New Satellite Spectrum Sharing Framework
On April 30, 2026, the Federal Communications Commission (FCC) adopted an Order fundamentally revising how satellite systems share spectrum in the Ku and Ka bands, replacing the decades-old Equivalent Power Flux Density (EPFD) limits with a performance-based coordination framework for managing interference between geostationary (GSO) and non-geostationary (NGSO) satellite systems. By reforming the EPFD regime, the FCC has removed a longstanding regulatory constraint that was developed to protect GSO systems but has arguably limited NGSO operators’ ability to deliver high-speed, low-latency broadband services.
Client Advisories
5.07.26
North Korea-Linked Schemes to Obtain Employment in U.S. Tech Companies: What You Need to Know and How to Respond
During the past few years, operatives associated with the Democratic People’s Republic of Korea (North Korea or the DPRK) have reportedly infiltrated hundreds of U.S. companies by fraudulently posing as legitimate remote IT workers. The perpetrators, together with accomplices across multiple jurisdictions (including inside the U.S.), funnel wages back to North Korea in violation of economic sanctions, and in many cases steal company data, source code, and trade secrets. In a smaller subset of cases, after being discovered and terminated, perpetrators have released, or threatened to release, sensitive company data and attempted to extort ransom payments.
Alerts
4.17.26
SBIR/STTR Program Restarted with New Features
On April 13, 2026, the Small Business Innovation and Economic Security Act (the Act) was signed into law, reauthorizing the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs through September 30, 2031. First and foremost, this ends the six-month program pause in new awards. But it also introduces several important changes aimed at improving the effectiveness of the SBIR program and at strengthening national security. Some of the key provisions are detailed here.
Press Releases
4.07.26
Wilson Sonsini Adds Partner Jocelyn Chow to National Security and Antitrust Practices in Hong Kong
Contact:
Troy Green
202-378-9053
troy.green@wsgr.com
Troy Green
202-378-9053
troy.green@wsgr.com
Alerts
4.06.26
Double Dose of New Tariffs: President Prescribes New Pharmaceuticals and Metals Tariffs
On April 2, 2026, President Trump issued two presidential proclamations: a proclamation imposing Section 232 tariffs on certain branded pharmaceutical products and associated active pharmaceutical ingredients (APIs) (the Pharmaceuticals Proclamation), and a proclamation modifying the Section 232 steel, aluminum, and copper tariffs (the Metals Proclamation).