Q3 2026 Regulatory Roundup: Key Developments for Turkish-US Business

The third quarter of 2026 (July–September) produced a significant volume of regulatory activity across the agencies that most affect Turkish companies and individuals with US operations. This roundup summarizes the most important developments and their practical implications.

USCIS processing times for key visa categories in Q3 2026:

• H-1B extensions: 3–6 months (regular); 15 business days (premium processing)
• L-1A/L-1B: 3–5 months (regular); 15 business days (premium)
• O-1: 2–4 months (regular); 15 business days (premium)
• EB-1A/EB-1C: 12–18 months (regular); 15 business days (premium)
• EB-2 NIW: 18–24 months (regular)
• I-485 (adjustment of status): 18–30 months

Recommendation: Turkish nationals with pending or upcoming immigration filings should consider premium processing where available to reduce uncertainty.

The FY2027 H-1B cap season concluded with:

• Registration period: March 2026
• Selection results: Late March 2026
• Petition filing deadline: June 30, 2026

Turkish employers whose FY2027 H-1B petitions were approved should ensure employees maintain valid status and begin planning for FY2028 if additional H-1B workers are needed.

E-2 visa processing at US consulates in Turkey has stabilized following the post-pandemic backlog. Current processing times at the US Consulate in Istanbul: approximately 4–8 weeks from application to interview scheduling.

USCIS continues to apply the 2022 public charge rule, which focuses on cash assistance programs and long-term institutionalization. The rule does not affect most Turkish business visa applicants.

The Section 232 tariffs on Turkish steel and aluminum remain in effect. Turkish steel exporters should monitor any developments in the US-Turkey trade relationship that could affect tariff rates or quota arrangements.

The Bureau of Industry and Security (BIS) updated the Entity List and expanded controls on certain advanced technologies in Q3 2026. Turkish companies that source US technology or have US technology partners should review updated export control classifications.

The US-Mexico-Canada Agreement (USMCA) continues to affect Turkish companies with North American supply chains. Turkish manufacturers supplying US or Mexican companies should understand USMCA rules of origin requirements that may affect their customers' ability to claim preferential tariff treatment.

The SEC's Q3 2026 enforcement priorities included:

• Cybersecurity disclosure compliance
• Insider trading involving AI-related companies
• SPAC-related disclosure violations
• Foreign corrupt practices (FCPA) enforcement

Turkish companies with US-listed securities should ensure their disclosure practices comply with current SEC requirements.

The FinCEN Corporate Transparency Act beneficial ownership registry continues to be enforced. Turkish-owned US entities that have not yet filed their beneficial ownership information (BOI) reports face civil penalties of $500/day and criminal penalties. Deadline reminder: Existing entities formed before January 1, 2024 had a filing deadline of January 1, 2025. New entities formed in 2024 or later must file within 90 days of formation.

FinCEN issued updated guidance on anti-money laundering (AML) program requirements for certain non-bank financial institutions. Turkish companies operating in financial services in the US should review updated AML requirements.

The FTC's rule banning most non-compete agreements remained subject to litigation in Q3 2026. Turkish employers should monitor court decisions and be prepared to adjust their non-compete practices if the rule is upheld.

The Department of Labor's updated overtime salary threshold (effective July 1, 2024) continues to apply. Employees earning less than $844/week ($43,888/year) must receive overtime pay for hours over 40 per week, regardless of their job duties. Turkish employers should audit their exempt employee classifications.

New York State expanded paid leave provisions in 2026. Turkish employers with New York employees should review updated leave requirements and ensure their policies comply.

The IRS continued its focus on international tax compliance in Q3 2026, with particular attention to:

• Transfer pricing documentation for related-party transactions
• FBAR and FATCA compliance
• Cryptocurrency reporting
• High-income individual audits

Turkish companies with US operations and Turkish individuals with US tax obligations should ensure their international tax compliance is current.

The OECD's Pillar Two global minimum tax framework continues to be implemented by countries worldwide. While the US has not enacted Pillar Two legislation, Turkish companies with US subsidiaries may be subject to Pillar Two top-up taxes in Turkey or other jurisdictions where they operate. Turkish companies should assess their Pillar Two exposure.

• October 15: Extended individual tax returns; FBAR extended deadline
• November: H-1B cap registration planning for FY2028 begins
• December 31: Year-end tax planning deadline; corporate estimated tax payments

Our attorneys monitor regulatory developments across immigration, trade, securities, employment, and tax to keep Turkish clients informed and compliant. We provide quarterly regulatory updates and on-demand guidance on specific compliance questions.

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements are subject to change; please consult qualified counsel for current obligations specific to your situation.