Critical regulatory changes, compliance deadlines, and law updates that directly affect Turkish businesses operating in or entering the U.S. market. Updated daily.
July 20, 2026
DHS issued a final rule replacing indefinite "duration of status" admission for F academic students, J exchange visitors, and I foreign-media representatives with fixed expiration dates, effective September 15, 2026. F and J admissions will generally be limited to the program period, with a maximum of four years, after which an extension-of-stay application or readmission will be required. The rule also reduces the F-1 post-program departure period from 60 to 30 days, restricts graduate-level program changes and school transfers, introduces additional extension procedures, and generally limits I-media admissions to 240 days. Transitional protections apply to individuals properly maintaining status when the rule takes effect.
Impact on Your Business
U.S. employers, universities, research institutions, media organizations, and companies hiring international graduates should update immigration calendars and onboarding procedures. Employment, OPT, STEM-OPT, and exchange-program arrangements must account for extension-processing time, fixed I-94 expiration dates, and possible employment interruptions. Employers should not rely solely on Forms I-20 or DS-2019 to establish continued lawful stay.
July 18, 2026
The U.S. Department of Commerce initiated antidumping (AD) and countervailing duty (CVD) investigations covering stainless steel sheet and strip from Türkiye, India, and the United Arab Emirates, following petitions filed by domestic producers. The investigations cover HTSUS subheadings 7219.11–7219.90 and 7220.11–7220.90. Commerce will issue preliminary CVD determinations within approximately 65 days and preliminary AD determinations within approximately 140 days of initiation. The International Trade Commission (ITC) will conduct parallel injury investigations. If preliminary duties are imposed, cash deposits will be required on all covered entries from the effective date of the preliminary determination.
Impact on Your Business
Turkish stainless steel producers, U.S. importers, distributors, service centers, fabricators, and end-users in construction, automotive, food processing, chemical, and energy sectors must act immediately: map all open purchase orders and in-transit shipments against the covered HTS subheadings; model potential cash deposit rates based on petition margins (which can be used as a proxy for preliminary rates); review import contracts for antidumping duty allocation, importer-of-record responsibility, price escalation, and retroactive assessment provisions; and consider whether to accelerate or defer shipments ahead of the preliminary CVD determination.
July 17, 2026
USTR finalized Section 301 action against Brazil covering digital-trade restrictions, electronic-payment barriers, IP enforcement gaps, ethanol market access, anti-corruption issues, and illegal-deforestation practices. An additional 25% tariff applies to covered Brazil-origin goods entered for consumption from 12:01 a.m. ET on July 22, 2026. Exemptions include goods already covered by Section 232 measures and listed categories such as certain aircraft and parts, energy products, pharmaceuticals, pig iron, scrap, instant coffee, seafood, hides, wood products, and aluminum hydroxide. Covered merchandise admitted to a U.S. foreign-trade zone must generally enter under privileged foreign status.
Impact on Your Business
Importers, exporters, manufacturers, customs brokers, distributors, and commodity traders must urgently map HTS classifications against the annexes, recalculate landed costs, verify origin and foreign-trade-zone treatment, and review open purchase orders. Contracts should clearly allocate additional duties through tariff-adjustment, change-in-law, Incoterms, reimbursement, termination, and supplier-indemnity provisions.
July 15, 2026
OFAC designated seven individuals and entities supporting Iranian Revolutionary Guard Corps (IRGC) weapons procurement through aviation companies, transportation firms, financial channels, and travel coordination. The network includes parties in Iran, Nigeria, Italy, and Russia, designated under Executive Order 13382. U.S.-connected property must be blocked; the 50-percent ownership rule applies; civil liability may be imposed on a strict-liability basis; and foreign financial institutions facilitating significant transactions face secondary-sanctions exposure.
Impact on Your Business
Banks, insurers, freight forwarders, aviation and drone-parts suppliers, travel coordinators, and cross-border traders must immediately rescreen counterparties, beneficial owners, intermediaries, and payment chains. Transactions involving Nika Jet Company, Vanguard Tactical Supply Limited, Avratek OOO, or their affiliates require enhanced sanctions review — particularly where U.S.-dollar clearing, U.S. goods, or U.S. persons are involved.
July 6, 2026 — DEADLINE
Two separate federal proceedings reach their comment/hearing deadlines on July 6, 2026: (1) USTR's Section 301 public hearing on Brazilian trade practices (digital trade, payments, IP, ethanol, deforestation) — businesses with Brazilian supply-chain exposure may submit testimony or written statements; (2) SEC's comment deadline on the proposed Form 10-S semiannual reporting rule replacing quarterly 10-Q filings.
Impact on Your Business
Missing these windows forfeits your right to shape the final rules. Turkish companies importing Brazilian-origin goods or listed on U.S. exchanges should file comments or retain counsel to do so before 5:00 PM ET on July 6.
August 1, 2026 — DEADLINE
Following the Supreme Court's June 2026 ruling upholding the Corporate Transparency Act, FinCEN has set August 1, 2026 as the hard deadline for all existing U.S. entities to file Beneficial Ownership Information (BOI) reports. Every LLC, C-Corp, S-Corp, LP, and similar entity registered in any U.S. state must report its beneficial owners — including Turkish parent companies and individual owners holding 25%+ or exercising substantial control.
Impact on Your Business
Civil penalty: $591 per day per violation. Criminal penalty: up to $10,000 fine and 2 years imprisonment for willful non-filers. With 30 days remaining, entities that have not yet filed must act immediately — FinCEN processing can take several business days.
July 10, 2026 — IN EFFECT
The 90-day pause on country-specific reciprocal tariff rates expired on July 9, 2026. Turkey's originally announced reciprocal tariff rate — set at 10% under Executive Order 14257 and the subsequent pause order — is now reinstated at the country-specific level above the 10% universal baseline. No bilateral U.S.–Turkey trade agreement has been announced. Turkish exporters shipping goods to the U.S. on or after July 10 are subject to the reinstated rate. Goods that were in transit or entered U.S. customs before July 9 under the paused rate may be subject to different treatment depending on entry date and CBP guidance.
Impact on Your Business
Turkish exporters must immediately recalculate landed costs using the reinstated country-specific rate. U.S. buyers under existing contracts should review tariff-adjustment and force majeure clauses. Companies with goods in transit should confirm entry dates with customs brokers. Any pending U.S. import contracts should be repriced to reflect the current rate environment.
September 15, 2026 — DEADLINE
USTR's Section 301 investigation into Turkish trade practices in steel, aluminum, and textile sectors reaches its final determination deadline on September 15, 2026. Preliminary findings indicate additional tariffs of 15–25% on select Turkish goods. Affected companies have until August 15 to submit rebuttal comments and request exclusions for specific product categories.
Impact on Your Business
Turkish exporters in steel, aluminum, and textiles face potentially significant cost increases in the U.S. market from mid-September. Product exclusion requests filed before August 15 are the primary mitigation tool — exclusions granted before the final determination take effect immediately.
Comment Deadline: July 6 — Hearings: July 7, 2026
USTR has determined that 60 economies — including Türkiye, China, the UK, UAE, South Korea, Japan, India, and Brazil — failed to impose or effectively enforce forced-labor import prohibitions. USTR proposed additional duties of 10% for certain economies and 12.5% for others. Written comments were due July 6, 2026; public hearings are scheduled for July 7, 2026. For Türkiye–U.S. trade, the proposed duties are especially relevant to textiles, apparel, manufacturing inputs, consumer goods, and products with layered or offshore supply chains.
Impact on Your Business
Turkish exporters to the U.S. and importers from affected economies must act immediately: review forced-labor due diligence, supplier warranties, origin documentation, audit rights, tariff-change clauses, and indemnity provisions. If additional duties are imposed, cost structures, pricing, and contract economics for Türkiye–U.S. trade flows could change materially.
July 1, 2026
The Department of Government Efficiency has finalized sweeping changes to federal procurement rules effective July 1, 2026. Foreign-owned entities bidding on U.S. government contracts now face enhanced FOCI (Foreign Ownership, Control, or Influence) disclosure requirements and accelerated security clearance reviews.
Impact on Your Business
Turkish defense industry companies with U.S. subsidiary structures must immediately review their FOCI mitigation agreements. Non-compliance can result in contract suspension within 30 days.
July 1, 2026
IRS regulations increasing the FIRPTA withholding rate on U.S. real property dispositions by foreign persons from 15% to 20% took effect July 1, 2026. Withholding certificates and reduced-rate applications must be filed at least 90 days before closing.
Impact on Your Business
Turkish investors selling U.S. real estate must plan for higher withholding and file for certificates well in advance. Buyers acting as withholding agents are equally affected.
June 28, 2026
Following the Supreme Court's June 2026 ruling upholding the Corporate Transparency Act, FinCEN has set August 1, 2026 as the final deadline for all existing U.S. entities to file Beneficial Ownership Information (BOI) reports. New entities formed after July 1 have 30 days to file.
Impact on Your Business
Every Turkish-owned LLC, C-Corp, or LP registered in the U.S. must file. Penalties: $591/day civil fine + potential criminal liability for willful non-filers.
April 9, 2026
President Trump's April 2, 2026 executive order imposing a 10% universal baseline tariff on all imports took effect April 9. Turkey's originally announced reciprocal rate of 10% was confirmed at the baseline level following the 90-day pause on higher country-specific rates. The pause expires July 9, 2026, after which Turkey's rate may be reassessed.
Impact on Your Business
All Turkish goods exported to the U.S. are subject to a minimum 10% tariff. Sectors including textiles, steel, machinery, and automotive parts face the highest exposure. The July 9 pause expiry is a critical date requiring immediate planning.
January 24, 2026
The Fifth Circuit Court of Appeals lifted the nationwide injunction blocking the Corporate Transparency Act on January 23, 2026. FinCEN immediately resumed enforcement and set a 30-day grace period (until February 28, 2026) for entities that missed the original January 1, 2026 deadline due to the injunction.
Impact on Your Business
Turkish-owned U.S. entities that had not yet filed BOI reports were required to file by February 28, 2026. Entities still not in compliance face $591/day civil penalties and potential criminal prosecution.
July 20, 2026
New York Executive Order No. 62 directs the Department of Environmental Conservation to hold in abeyance pending and incomplete applications for discretionary state permits for data centers capable of consuming 50 MW or more. The pause continues until the Department of Public Service completes a statewide Generic Environmental Impact Statement addressing energy demand, water, air quality, noise, and environmental-justice impacts. Local zoning and permitting authority is not suspended. Manufacturing, academic research, medical-care, and certain other primarily non-data-center facilities are excluded. The order also contemplates upfront developer contributions for grid improvements, dedicated generation or battery storage, community-investment funds, prevailing-wage commitments, and project labor agreements.
Impact
Data-center developers, foreign investors, landowners, lenders, utilities, and construction contractors should reassess permitting and closing schedules, entitlement contingencies, power-delivery commitments, and outside dates. Purchase, lease, development, and financing agreements should allocate the risk of state-permit delay, grid-upgrade contributions, community-benefit obligations, and potential tax-incentive withdrawal. The State is separately considering repeal of sales-tax exemptions for very large data centers.
July 20, 2026
A DHS final rule published for July 20, 2026 rescinds most of the 2022 public-charge regulatory framework and restores broader, case-by-case discretion under the "totality of the circumstances" standard. The rule becomes effective September 18, 2026 and applies to admissions made, and adjustment-of-status applications filed, on or after that date. For benefits received on or after the effective date, officers may consider a broader range of means-tested public benefits as part of the applicant's assets, resources, and financial status. Benefits previously excluded under the 2022 framework generally will not be retrospectively considered when received before September 18, except under the prior rule's standards. Benefit receipt alone is not automatically determinative.
Impact
Foreign investors, executives, employees, and family members pursuing permanent residence should document income, assets, insurance coverage, employment prospects, education, and sponsor support more comprehensively. EB-5, employer-sponsored, and family-linked adjustment strategies should be reviewed before the effective date, particularly where filing timing or receipt of means-tested benefits may affect the evidentiary record.
July 18, 2026
New York Governor signed legislation imposing an 18-month moratorium on new large-scale data center construction permits statewide, effective July 18, 2026. The moratorium covers facilities exceeding 100 MW of planned power capacity and applies to new permit applications; projects with permits already issued before the effective date are grandfathered. The legislation directs the Department of Environmental Conservation and the Public Service Commission to conduct a comprehensive review of data center energy consumption, grid impact, water usage, and carbon emissions before any new large-scale permits may be issued.
Impact
Turkish technology companies, data center investors, real estate developers, cloud infrastructure funds, and construction contractors with New York data center projects must immediately assess whether their projects are grandfathered or subject to the moratorium. Existing purchase agreements, development agreements, financing commitments, and construction contracts should be reviewed for change-in-law, force majeure, permit-condition, and material adverse change provisions. Projects in the pipeline that have not yet received permits face an 18-month delay at minimum.
July 18, 2026
USCIS issued a policy memorandum effective July 18, 2026 tightening the "specialty occupation" standard for H-1B petitions in information technology, management consulting, financial analysis, and related fields. The memo instructs adjudicators to scrutinize whether the specific position — not merely the general occupational category — requires a bachelor's degree in a specific specialty as a minimum requirement. Third-party placement arrangements, itinerant work, and positions with broad or generalist job descriptions face heightened scrutiny. The memo also expands the grounds on which USCIS may issue Requests for Evidence (RFEs) and Notices of Intent to Deny (NOIDs).
Impact
Turkish companies sponsoring H-1B workers in IT, consulting, finance, and related fields must immediately audit pending and recently filed petitions for specialty occupation documentation gaps. Employers should review job descriptions, degree requirements, and employer-employee relationship evidence for third-party placements. Petitions filed after July 18 should include enhanced specialty occupation support letters, detailed position analyses, and robust employer-employee relationship documentation. Companies with large H-1B populations should conduct a portfolio review with immigration counsel.
July 18, 2026
The SEC Division of Corporation Finance issued updated staff guidance on July 18, 2026 clarifying how public companies must apply the cybersecurity incident disclosure rules under Item 1.05 of Form 8-K (and Form 6-K for foreign private issuers). Key clarifications: (1) the materiality determination must be made "without unreasonable delay" and cannot be deferred pending forensic investigation completion; (2) the 4-business-day disclosure clock begins when the company determines the incident is material, not when the incident is discovered or fully investigated; (3) disclosure may not be delayed solely because law enforcement has been notified — the national security/public safety exception requires a formal written determination; (4) the guidance addresses ransomware payments, supply-chain incidents, and third-party service provider breaches.
Impact
Turkish companies listed on U.S. exchanges (NYSE, NASDAQ, OTC) and foreign private issuers filing Form 20-F/6-K must update their cybersecurity incident response plans, materiality determination procedures, and disclosure escalation protocols immediately. Incident response retainers, cyber insurance policies, and vendor contracts should be reviewed to ensure they support the accelerated disclosure timeline. Board-level cybersecurity oversight documentation should be updated to reflect the new guidance.
July 18, 2026
The Department of Labor published a proposed rule on July 18, 2026 that would adopt a federal "ABC test" for determining independent contractor status under the Fair Labor Standards Act, replacing the current multi-factor economic reality test. Under the ABC test, a worker is presumed to be an employee unless the hiring entity can demonstrate all three prongs: (A) the worker is free from control and direction in performing the work; (B) the work is outside the usual course of the hiring entity's business; and (C) the worker is customarily engaged in an independently established trade, occupation, or business. Comments are due 60 days after Federal Register publication.
Impact
Turkish companies operating in the U.S. that use independent contractors, freelancers, gig workers, staffing agencies, or consulting arrangements must immediately audit their contractor relationships against the ABC test. Misclassification exposure includes back wages, overtime, benefits, payroll taxes, and civil penalties. Service agreements, consulting contracts, staffing arrangements, and platform agreements should be reviewed and potentially restructured. Companies in technology, construction, logistics, healthcare, and professional services face the highest reclassification risk.
July 18, 2026
FinCEN issued expanded Geographic Targeting Orders (GTOs) effective July 18, 2026, requiring title insurance companies, settlement agents, and certain real estate professionals to collect and report beneficial ownership information for all-cash residential and commercial real estate transactions above $300,000 in all 50 states and the District of Columbia. The previous GTOs covered only select metropolitan areas and higher thresholds. Covered transactions include purchases by legal entities (LLCs, corporations, partnerships, trusts) and certain individual purchases. Reports must be filed within 30 days of closing using FinCEN Form 8300 or the BSA E-Filing System.
Impact
Turkish investors, family offices, holding companies, and real estate funds making all-cash U.S. real estate purchases above $300,000 must ensure their title companies and settlement agents are collecting beneficial ownership information. Sellers, brokers, and attorneys acting in covered transactions must verify that reporting obligations are being met. Purchase agreements and closing checklists should be updated to address GTO compliance. Failure to report or providing false information carries civil and criminal penalties.
July 17, 2026
The national emergency declared under Executive Order 13936 expired on July 14, 2026. OFAC removed persons sanctioned solely under that authority from the SDN List. However, the Hong Kong Human Rights and Democracy Act and Hong Kong Autonomy Act remain operative; persons still subject to Hong Kong Autonomy Act restrictions have been moved or added to OFAC's Non-SDN Menu-Based Sanctions List. Property blocked before July 14 does not become automatically unblocked merely because the relevant person was removed from the SDN List. OFAC has indicated that implementing regulations and guidance will be updated.
Impact
Banks, real estate funds, corporate service providers, trading companies, escrow agents, and businesses using Hong Kong holding companies must immediately refresh screening databases. Each apparent delisting must be analyzed to determine whether the party was fully removed, remains subject to menu-based restrictions, or controls an entity affected by continuing sanctions. Previously blocked payments or assets should not be released without a transaction-specific OFAC analysis.
July 17, 2026
The FDIC filed proposed information-collection forms for FDIC-supervised permitted payment stablecoin issuers under its GENIUS Act implementation framework. The proposal is scheduled for Federal Register publication on July 20, 2026, followed by a 60-day comment period. Issuers with at least $1 billion in outstanding stablecoins or at least $100 million in average daily transaction volume during the preceding month would submit a detailed weekly report. Smaller issuers could use an abridged weekly form, while all covered issuers would submit quarterly financial and operational reports resembling regulatory call reports. Required information includes reserves, redemptions, issuance activity, major holders and exchanges, Treasury and cash positions, derivatives, capital, custody arrangements, operational backstops, and balance-sheet data.
Impact
Stablecoin issuers, sponsoring banks, custodians, exchanges, fintech companies, auditors, and institutional counterparties should begin assessing whether existing treasury, reserve, reconciliation, and transaction-monitoring systems can produce weekly regulator-ready data. Agreements with custodians, reserve managers, technology vendors, and exchanges may need enhanced data-access, audit, record-retention, and regulatory-reporting provisions.
July 15, 2026
A presidential proclamation grants stationary sources specifically identified in Annex I a two-year extension from applicable compliance deadlines under the Clean Air Act section 112 portions of EPA's 2024 Hazardous Organic NESHAP (HON) Rule. During the exemption period, listed facilities remain subject to pre-HON emissions and compliance standards. The relief is facility-specific — not an industry-wide suspension.
Impact
Listed chemical manufacturers may revise capital-expenditure plans, construction schedules, environmental-compliance milestones, and financing forecasts. Purchasers, lenders, EPC contractors, and investors must verify that the particular facility appears in Annex I and identify which HON obligations were issued under section 112. State permit requirements, contractual environmental covenants, and other federal obligations may continue independently.
July 15, 2026
DOE has filed a final rule amending 2 CFR part 910, scheduled for Federal Register publication on July 16. Non-federal entities applying for or receiving DOE grants, cooperative agreements, or other financial assistance must establish procedures to identify, evaluate, mitigate, disclose, and report conflicts of interest, conflicts of commitment, and organizational conflicts of interest. The rule becomes effective 30 days after publication and replaces DOE's interim policy. Requirements reach significant financial relationships, competing domestic or foreign commitments, certain outside employment, sponsored support, in-kind resources, and affiliate-related procurement conflicts.
Impact
Clean-energy developers, technology companies, universities, grant-funded construction projects, contractors, and subrecipients should update written policies, employee and investigator disclosure forms, affiliate-procurement controls, foreign-support questionnaires, subaward terms, training, and escalation procedures before the effective date.
July 15, 2026
The NRC has filed a 507-page proposed rule undertaking a broad revision of reactor licensing, safety oversight, and siting requirements, scheduled for Federal Register publication on July 16. Comments are due 45 days after publication. Key proposals include: permitting reactor sites in areas of greater population density where applicants demonstrate site-specific societal benefits outweigh additional risks; facilitating reuse of existing infrastructure including retired fossil-fuel power-plant sites; and issuing early site permits without a fixed expiration date, while generally limiting the finality of time-sensitive safety and environmental findings to 20 years unless updated.
Impact
Nuclear and advanced-reactor developers, utilities, landowners, infrastructure funds, lenders, and construction contractors may gain access to a broader range of viable sites and longer-term site-banking opportunities. Due diligence should address population-risk analysis, transmission access, environmental review, permit-update obligations, land-use restrictions, decommissioning security, and change-in-law allocation.
July 15, 2026
Commerce preliminarily calculated a 35.79% antidumping margin for Zhejiang Dingli Machinery, Hunan Sinoboom Intelligent Equipment, and Terex (Changzhou) Machinery in its administrative review of Chinese mobile-access equipment and subassemblies. The China-wide rate remains 165.14%. These are preliminary results subject to verification, comments, and final determination.
Impact
U.S. importers, equipment dealers, rental fleets, developers, and construction contractors using aerial work platforms or related equipment should verify the exporter-producer combination and model possible assessment and cash-deposit exposure. Purchase, rental, and distribution contracts should allocate antidumping duties, retroactive assessments, price escalation, importer-of-record responsibility, documentation duties, and supplier indemnification.
July 6, 2026
The U.S. Department of Commerce, through BIS, initiated a Section 232 investigation into whether imports of anthracite coal and metallurgical bituminous coal (HTSUS 2701.11.0000 and 2701.12.0010) threaten U.S. national security. The investigation covers steel production, industrial processes, defense, and infrastructure supply chains. Public comments are due 14 days after Federal Register publication — if published July 7, the practical deadline is July 21, 2026.
Impact
Importers, steel producers, construction-material suppliers, infrastructure contractors, and cross-border commodity traders should review tariff/quota exposure, alternative sourcing, and force majeure, tariff-adjustment, and price-escalation clauses in existing contracts. Contracts involving steel, coal, infrastructure inputs, or industrial supply chains should include trade-remedy risk allocation.
July 6, 2026
EPA proposed revisions to Clean Air Act minor New Source Review (NSR) public-participation requirements for State Implementation Plan programs. The proposal would give state and local air agencies greater discretion over whether, when, and how much public participation is required for minor stationary-source construction and minor modifications. Comments are due 45 days after publication — if published July 7, the likely deadline is August 21, 2026.
Impact
This could materially affect permitting timelines for warehouses, manufacturing facilities, industrial expansions, energy-related facilities, and construction projects involving minor emissions sources. Developers may see faster approvals in some states, but local variance will increase significantly. Environmental-permit due diligence in M&A and real estate transactions should become more state-specific.
July 6, 2026
DOE proposed to revise its rulemaking methodology for new or revised energy-conservation standards and test procedures for consumer products and certain commercial/industrial equipment. The proposal would make Appendix A binding for certain DOE actions, define "significant energy savings," reinstate comparative "walk up" analysis, include economic thresholds, and restore elements of the 2020 Process Rule. Comments are due 30 days after publication — if published July 7, the likely deadline is August 6, 2026. DOE will hold a public webinar on July 15, 2026.
Impact
Manufacturers, importers, distributors, real estate developers, building-equipment suppliers, HVAC/appliance vendors, and construction counsel should monitor this closely. It may affect future compliance obligations, product specifications, procurement warranties, energy-performance representations, and supply contracts for commercial buildings.
July 6, 2026
The Nuclear Regulatory Commission proposed revisions to streamline and modernize its NEPA regulations. The proposal would narrow NEPA review to effects within NRC's statutory authority, revise definitions, update procedures for determining the level of review, create new categorical exclusions, provide more flexibility for applicants/licensees/petitioners submitting environmental information, and remove outdated requirements. Comments are due 45 days after publication — if published July 7, the likely deadline is August 21, 2026.
Impact
This matters for nuclear power, advanced reactors, uranium/fuel-cycle projects, energy infrastructure, and investors evaluating U.S. energy projects. If finalized, it may reduce environmental-review friction and improve schedule certainty, but project contracts should still address litigation risk, permitting delays, environmental-information obligations, and change-in-law provisions.
July 6, 2026
The U.S. International Trade Commission submitted an information-collection plan for its 2027 USMCA Automotive Rules of Origin report. The questionnaire will collect data from North American motor vehicle producers with U.S. production operations. The 2027 report is due to the President and Congress by July 1, 2027.
Impact
Automotive and parts manufacturers, suppliers, logistics companies, and Turkey–U.S.–Mexico/Canada supply-chain participants should treat this as an early signal for future USMCA rules-of-origin scrutiny. Companies should preserve origin documentation, labor-value-content calculations, steel/aluminum sourcing records, and supplier certifications now — before the questionnaire is issued.
July 6, 2026 — 150-Day Judicial Review Deadline: December 4, 2026
FHWA and FTA announced final federal agency actions for the proposed Interstate Bridge Replacement Program between Portland, Oregon and Vancouver, Washington — granting licenses, permits, and approvals for the multimodal I-5 corridor project. Judicial-review claims will be barred unless filed within 150 days after Federal Register publication; if published July 7, the practical deadline is December 4, 2026.
Impact
Material for infrastructure, construction, procurement, public-private contracting, engineering, environmental compliance, and suppliers. Contractors and investors should monitor bid packages, procurement schedules, labor requirements, environmental commitments, and claim/litigation deadlines. The December 4 judicial-review bar date is a hard cutoff — parties with standing who fail to file by that date permanently lose the right to challenge the federal approvals.
September 1, 2026 — DEADLINE
Turkish financial institutions that received IRS FATCA compliance notices in May 2026 must meet updated U.S. account holder reporting standards by September 1, 2026. Institutions failing to comply will be subject to 30% withholding on all U.S.-source payments — including correspondent banking transfers, securities income, and loan repayments.
Impact
Turkish businesses and individuals receiving U.S.-source payments through non-compliant Turkish banks face payment disruptions starting September 1. Verify your bank's FATCA compliance status now and consider alternative banking arrangements if needed.
December 31, 2026 — DEADLINE
All LLCs registered or doing business in New York State that were formed before June 1, 2026 have until December 31, 2026 to file beneficial owner disclosure with the NY Department of State under the NY LLC Transparency Act. The disclosure must identify all individuals who own 25%+ of the LLC or exercise substantial control, including foreign (Turkish) parent entities and their ultimate beneficial owners.
Impact
Non-compliance results in LLC dissolution proceedings and $250/day civil penalties. Turkish companies with New York LLCs should begin the disclosure process now — identifying all beneficial owners across complex corporate structures can take weeks.
October 15, 2026 — DEADLINE
U.S. persons (citizens, green card holders, and residents) with financial interest in or signature authority over foreign bank accounts — including Turkish bank accounts — exceeding $10,000 at any point in 2025 must file FinCEN Form 114 (FBAR) by October 15, 2026. The automatic extension from the April 15 original deadline expires on this date with no further extensions available.
Impact
Civil penalty for non-willful violations: up to $16,117 per violation. Willful violations: up to $161,166 or 50% of account balance per violation, whichever is greater. Turkish-American dual citizens and U.S. residents with Turkish business or family accounts are particularly exposed.
September 15, 2026 — DEADLINE
Foreign-owned U.S. corporations and single-member LLCs with a foreign owner (including Turkish parent companies) must file IRS Form 5472 (Information Return of a 25% Foreign-Owned U.S. Corporation) by September 15, 2026 — the extended deadline for calendar-year filers that requested an extension. Form 5472 must report all reportable transactions between the U.S. entity and its foreign owner or related parties.
Impact
Penalty for failure to file or maintain required records: $25,000 per Form 5472 per tax year, with an additional $25,000 for each 90-day period of continued non-compliance after IRS notice. Turkish companies with U.S. subsidiaries that missed the April 15 deadline must file immediately.
August 1, 2026 — DEADLINE
Turkish investors and companies operating under active CFIUS mitigation agreements (National Security Agreements, Letters of Assurance, or Proxy Agreements) must submit their annual compliance certifications to the CFIUS monitoring agency by August 1, 2026. Certifications must confirm adherence to all agreement terms, including security protocols, board composition, data handling, and facility access restrictions.
Impact
Failure to submit annual certifications on time can trigger CFIUS enforcement proceedings, including mandatory divestiture orders and civil penalties up to the value of the original transaction.
September 30, 2026
The Department of Labor's Wage and Hour Division has announced a Q3 2026 targeted audit initiative focusing on H-1B employers in the technology, financial services, and consulting sectors. Audits will verify that H-1B workers are being paid at least the 2026 prevailing wage levels (updated February 2026, averaging 8–12% above 2025 levels) and that Labor Condition Applications accurately reflect actual job duties and work locations.
Impact
Turkish companies sponsoring H-1B workers in the U.S. should conduct an internal wage audit now, update LCAs for any workers whose job duties or locations have changed, and ensure payroll records are audit-ready before September 30.
July 2, 2026 — Comment Deadline August 31
DHS/USCIS published a proposed rule on July 2, 2026 to implement the EB-5 Reform and Integrity Act of 2022. The rule would substantially reorganize EB-5 regulations, strengthen fraud and national-security controls, and clarify requirements for investors, regional centers, new commercial enterprises, and job-creating entities. Public comments are due August 31, 2026.
Impact
Foreign investors, real estate developers, hotel projects, regional centers, and EB-5-funded developments should immediately review: offering documents, source-of-funds analysis, promoter agreements, escrow arrangements, indemnities, investor disclosures, and compliance covenants. The proposal also increases the importance of sanctions, revocation, debarment, and project-compliance due diligence in EB-5-linked real estate and construction deals.
August 4, 2026 — Hearing & Comment Deadline
NYC HPD proposed amendments to allow certain rental projects applying for 421-a(16) benefits to change approved Workbooks in limited circumstances. The proposed change targets projects that originally selected Affordability Option C or G but now seek to amend to Option A, B, E, or F — potentially aligning the project with the extended completion deadline of June 15, 2031 rather than the earlier June 15, 2026 deadline. Hearing and written comment deadline: August 4, 2026.
Impact
NYC developers, lenders, purchasers, and counsel for multifamily projects should immediately review whether any stalled or delayed 421-a(16) projects can preserve tax-benefit eligibility by amending Workbooks. This affects project valuation, financing assumptions, closing risk, affordable-housing compliance, and purchase agreement representations.
July 2026
USTR announced that the United States will not automatically renew USMCA in its current form. The agreement remains in force, but the U.S. is seeking to renegotiate with Canada and Mexico on trade deficits, enforcement gaps, automotive rules of origin, agriculture, energy, and cross-border services. The outcome of renegotiation could materially alter tariff rates, rules of origin, and market access conditions for goods and services moving across North American borders.
Impact
Turkish companies with North American supply chains, manufacturing, distribution, or service contracts should immediately review: price adjustment and tariff change clauses, rules of origin and certificate of origin requirements, force majeure and material adverse change provisions, and delivery/delay terms. New supply or distribution agreements should include a "trade-law change / tariff adjustment" clause.
July 6–7, 2026
USTR held public hearings on July 6–7, 2026 on proposed Section 301 measures against Brazil covering: digital trade and electronic payment services, preferential tariffs, anti-corruption enforcement, intellectual property protection, ethanol market access, and illegal deforestation. Proposed measures could include tariffs or other trade restrictions on Brazilian-origin goods and services.
Impact
Turkish companies with Brazil-linked digital services, fintech, payment infrastructure, IP licensing, agriculture/ethanol, or commodity trade face elevated tariff and countermeasure risk. Brazil-linked contracts should be reviewed for: tax/tariff change provisions, sanctions-like trade restriction clauses, and payment system compliance terms.
June 29, 2026
A Presidential Proclamation published in the Federal Register on June 29, 2026 authorizes the Treasury and Commerce Departments to temporarily suspend collection of customs duties and estimated tax deposits on phosphate fertilizer imports from Morocco, citing emergency conditions. The authorization runs for 8 months from the proclamation date or until the emergency ends.
Impact
Importers of Moroccan phosphate fertilizer should verify Moroccan origin, product classification, and anti-dumping/countervailing duty exposure. Supply and logistics contracts should reflect the temporary nature of the duty suspension and include provisions for the risk of duty reinstatement at the 8-month expiry. Fertilizer, agriculture, food production, and related logistics chains may see cost and supply planning changes.
July 2026 — Comment Deadline August 10
USDA published a proposed rule modernizing and strengthening Agricultural Foreign Investment Disclosure Act (AFIDA) reporting requirements for foreign persons acquiring, transferring, or holding U.S. agricultural land. Key changes: electronic filing, internet database, CFIUS data sharing, "foreign adversary" and controlled foreign entity definitions, expanded land definitions, and stronger enforcement. Comment period closes August 10, 2026.
Impact
Foreign investors — including Turkish nationals and entities — considering U.S. agricultural land, rural land, forestry/timber, energy-linked land, agri-tech, or food supply chain investments face increased reporting and national security review risk. AFIDA + CFIUS analysis should be a separate workstream in due diligence. Businesses wishing to comment on the proposed rule must do so before August 10.
July 1, 2026 — EFFECTIVE
The NYC Department of Buildings confirmed that as of July 1, 2026, roll-down security grille systems facing the sidewalk in commercial buildings under Occupancy Groups B and M must provide at least 70% visibility when closed. Non-compliance triggers OATH summons and major violation risk. Exceptions exist for landmark and historic district properties.
Impact
New York property owners and commercial tenants — including Turkish-owned stores, showrooms, offices, restaurants, markets, and commercial leases — must verify lease compliance, alteration approval, DOB permit status, and violation risk. New lease agreements should clearly allocate security grille and facade equipment responsibility between landlord and tenant.
July 2026 — Comment Deadline July 31
The FTC published a proposed policy statement indicating that AI companies manipulating system outputs in ways that violate consumers' reasonable expectations of accuracy and objectivity may constitute "unfair or deceptive" conduct under FTC Act Section 5. The statement targets AI products, chatbots, SaaS, legal-tech, fintech, and decision-support systems. Public comment deadline: July 31, 2026.
Impact
Companies offering AI products, chatbots, SaaS, legal-tech, fintech, or decision-support systems should review: marketing copy and accuracy representations, disclaimers, model behavior documentation, output reliability standards, and liability limitations in customer contracts. Businesses wishing to comment on the proposed policy must do so before July 31.
July 2026
DOJ and FTC released the FY2025 Hart-Scott-Rodino annual report: 2,006 reportable transactions filed, approximately 31.8% valued above $1 billion, and 18 merger enforcement actions taken in healthcare, technology, energy, defense, consumer goods, labor markets, and manufacturing. The report signals continued aggressive antitrust enforcement posture heading into 2026.
Impact
Turkish companies involved in U.S.-connected M&A should conduct antitrust risk analysis early — even when HSR thresholds are not met. Transactions in defense, technology, healthcare, energy, and labor-market-affecting sectors face heightened scrutiny. Deal documentation should include carefully drafted "deal certainty" provisions: reverse termination fees, antitrust efforts covenants, and closing condition language.
July 1, 2026
Welsh, Carson, Anderson & Stowe led a consortium including company founders Robert A. Ortenzio and Martin F. Jackson to acquire Select Medical Holdings Corporation at $16.50 per share in cash (~$3.9B). The merger became effective July 1, 2026; Select Medical was delisted from NYSE. J.P. Morgan and Wells Fargo arranged debt financing; Goldman Sachs and Skadden advised the special committee. The transaction is a landmark management-led take-private in U.S. healthcare infrastructure.
Impact
Key M&A practice issues: special committee process, management rollover structure, go-private mechanics, NYSE delisting, debt financing, healthcare reimbursement risk, patient service continuity, regulatory compliance, and conflict-of-interest management. Turkish companies pursuing U.S. healthcare acquisitions or PE-backed buyouts should study this transaction structure.
July 2, 2026
Securitize Corp., a SEC-registered broker-dealer, transfer agent, and ATS operator in the tokenized securities space, completed its business combination with Cantor Equity Partners II (CEPT) on July 1, 2026. Shares began trading on NYSE under "SECZ" on July 2. The transaction valued Securitize at $1.25B with ~$400M gross proceeds. The deal represents a SPAC business combination at the intersection of regulated fintech infrastructure and tokenized equity.
Impact
Critical M&A and regulatory issues: SPAC business combination mechanics, PIPE financing, redemption rates, NYSE listing requirements, SEC disclosure obligations, digital securities regulation, tokenized share structure, broker-dealer/ATS licensing, and regulated fintech due diligence. Turkish fintech and capital markets companies planning U.S. listings should analyze this transaction.
July 2, 2026
On June 30, 2026, the DOJ Antitrust Division and 17 state attorneys general filed a civil lawsuit against major egg producers, alleging coordinated manipulation of benchmark price quotations used in wholesale pricing. Proposed settlements prohibit competitor communications about bidding strategies, prices, and supply/demand data shared with benchmark publications, and require antitrust compliance programs.
Impact
This enforcement action signals heightened DOJ scrutiny of benchmark-based, index-based, or market-publication-based pricing across all sectors — not just food. Turkish companies operating in commodities, energy, financial services, or any industry using shared pricing benchmarks should immediately audit competitor-information protocols and document independent pricing decisions.
July 2, 2026
The SEC has proposed allowing Exchange Act reporting companies to file a new Form 10-S semiannual report instead of quarterly Form 10-Q reports, with corresponding amendments to Regulation S-X. Comments are due July 6, 2026. A company's interim reporting election would generally be made annually and could not be changed mid-year.
Impact
Turkish companies listed on U.S. exchanges or planning a U.S. IPO should evaluate how semiannual reporting would affect investor relations, financing covenants, M&A due diligence, and underwriting timelines. The comment window closes July 6 — submit views now if your business is affected.
July 1, 2026
USTR has determined that Brazilian policies on digital trade, electronic payments, IP protection, ethanol market access, and illegal deforestation are actionable under Section 301. Written comments were due July 1, 2026; a public hearing is scheduled for July 6. Proposed tariffs target Brazilian goods across fintech, e-commerce, timber, furniture, agricultural, and biofuel sectors.
Impact
Turkish companies with supply chains that include Brazilian raw materials, timber, agricultural products, or biofuels — or that compete with Brazilian goods in the U.S. market — should assess tariff exposure and consider alternative sourcing or tariff-change clauses in contracts.
June 25, 2026
USTR has initiated a Section 301 investigation into Turkish trade practices in the steel, aluminum, and textile sectors. Preliminary findings suggest additional tariffs of 15–25% on select Turkish goods, with final determination expected by September 15, 2026.
Impact
Turkish exporters in affected sectors should immediately review their U.S. distribution agreements and consider tariff engineering strategies before the September deadline.
June 20, 2026
USCIS has issued updated policy guidance raising the informal "substantial investment" benchmark for E-2 treaty investor visas from $100,000 to $150,000 for service-sector businesses. Processing times at the Istanbul consulate have extended to 8–12 months for standard applications.
Impact
Turkish investors planning E-2 applications should reassess their investment structures and consider premium processing to avoid the extended queue.
June 15, 2026
The New York LLC Transparency Act took full effect June 1, 2026. All LLCs registered or doing business in New York must disclose beneficial owners to the NY Department of State. Existing LLCs have until December 31, 2026 to comply; new LLCs must file at formation.
Impact
Turkish companies with New York LLCs must file disclosure forms. Non-compliance results in LLC dissolution proceedings and $250/day penalties.
June 5, 2026
The DOJ has updated Hart-Scott-Rodino (HSR) filing thresholds for 2026: the base threshold rises to $119.5M. CFIUS has simultaneously expanded mandatory filing requirements to cover Turkish companies in the semiconductor, AI, and critical infrastructure sectors.
Impact
Turkish companies pursuing U.S. acquisitions above $119.5M must file HSR. Those in tech sectors should conduct a CFIUS risk assessment before signing any LOI.
May 22, 2026
Congress reauthorized the EB-5 Regional Center Program through 2030 with updated minimum investment thresholds: $1.05M standard / $800K for Targeted Employment Areas. Critically, USCIS has cleared the Turkish visa quota backlog, meaning Turkish nationals can now receive EB-5 visas without multi-year waits.
Impact
Turkish high-net-worth individuals seeking U.S. permanent residency through investment now have a clear, backlog-free pathway. The window is competitive — act before new backlogs form.
May 15, 2026
The IRS has issued new compliance notices to Turkish banks and financial institutions under FATCA (Foreign Account Tax Compliance Act), citing gaps in U.S. account holder reporting. Turkish institutions that fail to meet updated reporting standards by September 1, 2026 face 30% withholding on U.S.-source payments.
Impact
Turkish businesses and individuals with U.S. bank accounts or receiving U.S.-source income must ensure their Turkish financial institutions are FATCA-compliant to avoid payment disruptions.
May 8, 2026
The U.S. Treasury and Turkish Ministry of Finance have formally launched renegotiation of the 1996 U.S.–Turkey Tax Treaty. Key proposed changes include updated permanent establishment definitions for digital businesses, revised dividend/interest/royalty withholding rates, and new anti-abuse provisions targeting treaty shopping.
Impact
Turkish companies with U.S. operations and U.S. companies with Turkish subsidiaries should model the impact of proposed changes on their current tax structures before the treaty is finalized.
April 3, 2026
OFAC has issued updated compliance guidance specifically addressing Turkish companies that facilitate transactions with sanctioned Russian entities. The guidance clarifies that Turkish intermediaries in energy, metals, and financial services sectors face secondary sanctions exposure even without direct U.S. nexus.
Impact
Turkish companies with any exposure to Russian counterparties must conduct an immediate OFAC risk assessment. U.S. banks are increasingly refusing to process payments for Turkish entities flagged in OFAC screening.
March 31, 2026
USCIS has announced changes to the H-1B cap registration process for FY2027: employer registration fees increase from $215 to $480 per beneficiary, and new wage level attestation requirements mandate that H-1B workers be paid at least Level II prevailing wages. The registration window opens April 1, 2026.
Impact
Turkish companies sponsoring H-1B workers for U.S. operations must budget for higher fees and review compensation structures to meet new wage attestation requirements.
March 15, 2026
The SEC has finalized amendments to Form 20-F and Form 6-K requirements for foreign private issuers, including Turkish companies listed on U.S. exchanges. New mandatory disclosures cover material cybersecurity incidents (within 4 business days), annual climate risk assessments, and board-level oversight of AI systems.
Impact
Turkish companies listed on NYSE, NASDAQ, or OTC markets must update their disclosure programs and board governance structures to comply with the new SEC rules by their next annual report.
February 20, 2026
CFIUS has issued final rules expanding mandatory pre-closing filing requirements to cover investments in U.S. companies operating in artificial intelligence, biotechnology, quantum computing, and energy infrastructure. Turkish investors acquiring any stake in these sectors must file with CFIUS before closing, regardless of deal size.
Impact
Any Turkish company or individual acquiring a U.S. business in the covered sectors without filing faces mandatory divestiture orders and civil penalties up to the deal value.
February 10, 2026
The Department of Labor has published updated prevailing wage determinations for 2026, with average increases of 8–12% across most occupational categories. The increases directly affect the minimum salaries required for H-1B, L-1B, and PERM labor certification applications filed after February 1, 2026.
Impact
Turkish companies sponsoring U.S. work visas must review and potentially increase salaries for sponsored employees to maintain compliance with updated wage requirements.
January 20, 2026
On January 20, 2026, the Trump administration issued a series of executive orders with immediate impact on Turkish businesses: a 60-day pause on new visa issuances for certain categories, initiation of a comprehensive trade deficit review targeting major trading partners including Turkey, and suspension of several Biden-era regulatory rules affecting foreign investment.
Impact
Turkish nationals with pending U.S. visa applications experienced delays. Companies with pending regulatory approvals for U.S. market entry faced uncertainty. Immediate legal review of all pending U.S. applications was advised.
January 1, 2026
New York State's minimum wage increased to $17.00/hour in New York City and Long Island effective January 1, 2026, with a further increase to $17.50 scheduled for January 1, 2027. The increases apply to all employees, including those on work visas, and carry strict enforcement by the NY Department of Labor.
Impact
Turkish-owned businesses operating in New York City must update payroll systems and employment contracts. Non-compliance carries back-pay liability, civil penalties, and potential license revocation.
Our attorneys monitor U.S. federal and state law changes daily. Schedule a consultation to understand how current developments affect your specific situation.
Sends a formatted email to [email protected] (or CONTACT_FORM_RECIPIENT_EMAIL). Set LEGAL_ALERTS_NOTIFY_SECRET in Settings → Secrets to protect this endpoint.