As of July 25, 2026, 15:00 Istanbul time.

The broad 10% temporary import surcharge imposed under Section 122 of the Trade Act of 1974 expired by its own terms at 12:01 a.m. EDT on July 24, 2026. The presidential proclamation permitted continuation beyond 150 days only through an Act of Congress; no extension was identified in the official materials reviewed.

Practical implications: Importers and customs brokers should ensure that goods entered for consumption, or withdrawn from warehouse, after the cutoff are not charged the expired surcharge. Landed-cost models, purchase orders, and tariff-adjustment invoices should be revised. This expiration does not eliminate separately applicable ordinary duties, Section 232 tariffs, Section 301 tariffs — including the new forced-labor-related tariffs — AD/CVD deposits, or other trade measures.

Turkey–U.S. trade context: Turkish exporters and U.S. importers of Turkish goods who adjusted pricing, contract terms, or supply-chain routing in response to the Section 122 surcharge should reassess those arrangements. The expiration may restore competitiveness for certain product categories, but the full tariff picture — including any applicable Section 301 or AD/CVD measures — must be evaluated before revising commercial terms.

The FCC's final rule, scheduled for Federal Register publication on July 27, creates a licensing regime for owners and operators of submarine line terminal equipment connecting cables to the United States. Qualifying existing and future operators receive blanket licensing but must comply with reporting, cybersecurity, and physical-security risk-management obligations. The rules generally become effective September 25, 2026, although several information-collection provisions are delayed pending further notice.

The rule restricts principal equipment and service providers controlled by foreign adversaries and prohibits certain indefeasible rights of use and capacity leases involving FCC Covered List entities where the counterparty can install, own, or manage terminal equipment. Applications meeting ten national-security standards may qualify for expedited treatment without referral to Executive Branch security agencies.

Practical implications: Submarine-cable investors, telecommunications operators, cloud and data-center companies, capacity purchasers, and infrastructure funds should review ownership chains, equipment suppliers, operating contractors, IRUs, and capacity leases. M&A and project-finance due diligence should specifically address FCC licensing status, foreign-adversary exposure, Covered List counterparties, and cybersecurity-plan compliance.

Cross-border investment note: The FCC's foreign-adversary framework operates alongside — and in some respects overlaps with — CFIUS review. Transactions involving submarine-cable infrastructure with any Turkish, European, or other non-U.S. ownership component should be assessed for both CFIUS and FCC licensing implications before signing. The September 25 effective date creates an immediate compliance deadline for existing operators.

The OCC released proposed application forms implementing the GENIUS Act licensing framework. Comments are due September 25, 2026. Applicants seeking permission to issue payment stablecoins must provide detailed business plans, reserve and redemption policies, risk-management programs, and information regarding directors, officers, and principal shareholders.

Foreign stablecoin issuers seeking U.S. market access must demonstrate, among other matters, a Treasury determination that their home-country regime is comparable, adequate U.S.-operational resources, regulator access to relevant information, consent to U.S. jurisdiction, and acceptable financial-stability and illicit-finance risk.

Practical implications: Foreign issuers, fintech companies, sponsoring banks, exchanges, and custodians should begin preparing ownership, governance, reserves, redemption, AML, cybersecurity, and regulatory-information files. Cross-border structures should also assess whether the home jurisdiction is likely to receive the required comparability determination before relying on U.S. distribution or exchange access.

Turkey context: Turkish fintech companies, payment institutions, and banks exploring stablecoin issuance or U.S. market access should monitor whether Turkey's regulatory framework — currently under development by BDDK and CMB — will receive a Treasury comparability determination. The September 25 comment deadline is an opportunity to engage with the OCC on the standards applicable to Turkish-regulated entities.

For Turkey-connected M&A and deal activity from the same period, see our Turkey–U.S. M&A Daily Digest: July 25, 2026.

ULF New York monitors U.S. legal and regulatory developments affecting Turkish and cross-border business. This update is prepared for informational purposes and does not constitute legal advice. For matter-specific analysis, contact ULF New York.