As of 8:00 a.m. EDT / 3:00 p.m. Türkiye time on September 18, 2026. This brief reviews developments from September 17 through September 18.

The USDA Farm Service Agency issued updated enforcement guidance on the Agricultural Foreign Investment Disclosure Act (AFIDA) on September 17, announcing a 90-day amnesty period for foreign investors who have not previously filed required AFIDA disclosures. The amnesty period runs through December 15, 2026. After the amnesty period, the FSA will impose civil penalties of up to 25% of the fair market value of unreported agricultural land holdings.

Turkish investors and Turkish-controlled entities that hold agricultural land in the United States — including farmland, ranchland, timberland, and land used for agricultural purposes — must file AFIDA Form FSA-153 within 90 days of acquisition and annually thereafter. The form requires disclosure of the investor's identity, the location and acreage of the land, the purchase price, and the intended use.

The amnesty period provides an important opportunity for Turkish investors who may have acquired agricultural land through U.S. holding companies or trusts without recognizing the AFIDA disclosure obligation. Counsel should review the beneficial ownership chain of any U.S. agricultural land holdings to identify whether a foreign person or entity with 10% or more ownership interest triggers the AFIDA disclosure requirement.

MasTec, the Miami-based infrastructure construction and services company, completed its acquisition of a regional utility construction and maintenance services company in the Pacific Northwest on September 17. The target provides electrical transmission and distribution construction, maintenance, and emergency response services to investor-owned utilities and rural electric cooperatives in Washington, Oregon, and Idaho. The transaction value was approximately $285 million.

The acquisition expands MasTec's utility services footprint in the Pacific Northwest, a region experiencing significant grid modernization investment driven by renewable energy integration and wildfire mitigation requirements. Post-closing integration should address the target's existing utility master service agreements, union labor agreements, and equipment fleet management.

Hometown Financial Group and its subsidiary Hometown Bank completed their merger with FSC Bancshares and Farmers State Bank on September 17, following the earlier Hawthorn Bancshares transaction. The combined institution will operate under the Hometown Bank brand with approximately $1.8 billion in total assets and 22 branch locations across Missouri and Kansas.

Community bank mergers of this type require careful attention to core banking system conversion planning, BSA/AML program integration, and the treatment of the acquired bank's loan portfolio under purchase accounting. The timing of the core banking conversion — typically 6-12 months after legal close — is a critical operational risk that should be managed with dedicated project management resources.

The AFIDA enforcement update is the most immediately actionable development for Turkish investors with U.S. agricultural land holdings. The 90-day amnesty period through December 15, 2026 provides a limited window to come into compliance without penalty. Turkish investors should act promptly to assess their AFIDA disclosure obligations.

This publication is for general informational purposes only and does not constitute legal advice.