Four developments meet the materiality threshold for cross-border business, commercial lending, tax/compliance and financial-sector investment.

A bipartisan group in the House introduced the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 on August 10. This is particularly significant because the House text is identical to the version already passed by the Senate 86–11. The legislation is not yet law and therefore imposes no new sanctions or tariffs today.

The legislation would establish a broad mandatory sanctions architecture targeting Russian senior officials and oligarchs, defense-industrial actors, major Russian financial institutions, certain foreign financial institutions conducting significant transactions with sanctioned Russian banks, and Russia's "shadow fleet," including vessels, owners, operators, insurers, ports and other knowing facilitators. It would also restrict new U.S. investment in Russia and Russian energy, prohibit purchases of Russian sovereign debt, and target financial-messaging mechanisms used to evade sanctions.

The trade provisions are unusually consequential. The bill would authorize duties of up to 500% on goods imported from Russia and targeted duties of up to 100% on goods from countries that are among the largest purchasers of Russian-origin crude oil or natural gas or leading facilitators of Russian oil sanctions evasion. It would also extend the Iran Sanctions Act of 1996 through 2031.

Practice considerations: Banks, commodity traders, oil and gas companies, shipping companies, freight forwarders, insurers and multinational manufacturers should begin scenario-mapping now rather than waiting for enactment. Particular attention should be given to indirect payments to Russian banks, vessels and insurers in Russian-energy supply chains, and procurement from third countries that could become subject to the bill's secondary tariff mechanism. Cross-border sale, distribution, shipping and financing agreements should contain robust sanctions/change-in-law provisions, alternative-payment mechanisms, tariff allocation clauses, compliance representations and termination rights. Because the House bill is identical to the Senate-passed text, passage without amendment would remove the need to reconcile different House and Senate versions before presidential consideration.

Primary source: U.S. House announcement and detailed summary of the legislation.

The OCC/FDIC proposal to revise the Community Reinvestment Act regulations was formally filed for Federal Register publication on August 11 and is scheduled for publication on August 12, 2026. The proposal is not yet a final rule; comments will be accepted for 60 days after publication.

The proposal would significantly alter how OCC- and FDIC-supervised banks are categorized and evaluated. The "small bank" asset threshold would increase from $412 million to $1 billion, while the intermediate-bank threshold would increase from $1.65 billion to $10 billion. Banks newly falling within the $1.65–10 billion intermediate category would be relieved from certain data-collection and reporting requirements and receive more flexible supervision.

Substantively, CRA evaluation would become more lending-focused. Deposit services would generally be excluded from the retail-banking-services analysis, community-development activities would need a clearer nexus to lending or statutory community-development objectives, and community-development grants would receive CRA consideration only where they are directly used for a qualifying plan, project or initiative. Banks with assets above $10 billion would also have to document that recipients of qualifying community-development grants do not have overhead costs exceeding 15%.

Practice considerations: Banks, affordable-housing developers, real-estate funds, CDFIs, nonprofit development entities and sponsors relying on CRA-motivated capital should reassess how transactions are structured and documented. Real-estate projects seeking CRA consideration may benefit from making the connection between the bank financing, affordable-housing/community-development purpose and actual deployment of funds much more explicit. At the same time, regional and community banks moving below the proposed $10 billion threshold could face materially lighter CRA data and reporting burdens. Federal branches and agencies of foreign banking organizations subject to the OCC CRA framework should also assess the proposal.

Primary sources: OCC Bulletin 2026-35 and the August 11 Federal Register public-inspection docket.

Treasury and the IRS published proposed regulations on August 11, 2026 implementing employer contributions to Trump Accounts under Internal Revenue Code §128 and revising nondiscrimination rules applicable to both Trump Account programs and dependent-care assistance programs. Employers may provide up to $2,500 per employee for 2026 and 2027 on a tax-free basis under a qualifying Trump Account contribution program; importantly, the limit is per employee, not per dependent.

A qualifying employer program would have to operate under a separate written plan, identify eligible employee classes and contribution formulas, establish designation and certification procedures, notify eligible employees, implement correction procedures and satisfy nondiscrimination requirements. The proposal also requires annual employee reporting; the IRS states that the reporting obligation may be satisfied by reporting §128 contributions in Form W-2, Box 12, code "TA."

The proposed rules contain an important cafeteria-plan distinction: a §125 salary-reduction arrangement may fund the Trump Account of an employee's dependent, but not the employee's own Trump Account. Employers generally may rely on written employee certifications concerning dependent status and age unless they have actual knowledge that the certification is incorrect, but they must independently use a reasonable method to confirm that the destination account is actually a valid Trump Account.

For dependent-care assistance plans, the regulations address the now $7,500 annual exclusion and four nondiscrimination tests covering contributions and benefits, eligibility, owner concentration and average benefits. If the nondiscrimination requirements fail, highly compensated employees may lose the income exclusion even though non-highly-compensated employees can retain it. Comments are due September 25, 2026.

Practice considerations: Employers considering the new benefit should coordinate tax, payroll, HR and benefits counsel before rollout. Plan documents, nondiscrimination testing, W-2 reporting, employee certifications, trustee interfaces and §125 cafeteria-plan documents will require deliberate implementation; treating the benefit merely as another payroll contribution could jeopardize the intended tax exclusion.

Primary sources: IRS IR-2026-90 and the published Treasury/IRS proposed regulations, 91 FR 51611.

The FDIC has adopted revised procedures for federal deposit insurance applications by proposed de novo institutions. For applications received after August 15, 2026, Phase 1 begins when the application is received and is designed to produce a contingent authorization within 120 days for applicants satisfying the applicable requirements.

A second phase can run for up to 12 additional months, during which organizers complete corporate, capital, management, operational and other organizational requirements, with the objective of obtaining final FDIC approval and an FDI Order. The FDIC also expects applicants generally to be able to pursue deposit-insurance and charter applications concurrently with the FDIC and the relevant chartering authority.

Practice considerations: This is significant for fintech promoters, payment companies, digital-asset businesses, investment groups and foreign investors contemplating formation or acquisition strategies involving a U.S. insured bank. A defined 120-day contingent-authorization target can make capital commitments, technology/vendor contracts, executive recruitment, real-estate leasing and regulatory-condition precedents easier to sequence. It does not dilute the substantive statutory requirements for deposit insurance, so business-plan viability, capital, management, BSA/AML, technology, governance and other regulatory requirements remain critical.

Primary source: FDIC FIL-48-2026, Revised Procedures for Processing Federal Deposit Insurance Applications.