This update reviews material U.S. legal and regulatory developments as of October 3, 2026.

USTR confirmed on October 2 that the preliminary determination in the Section 301 investigation covering Turkish exports of steel, aluminum, and certain manufactured goods is on track for release in late October 2026. The investigation was initiated in July 2026 following a petition from domestic industry groups alleging unfair trade practices.

Turkish exporters in the affected categories — steel products, aluminum products, and certain manufactured goods including automotive parts and textiles — should prepare for the possibility of additional tariffs ranging from 10% to 25% on U.S.-bound exports. Turkish companies should model the impact of potential tariff scenarios on their U.S. pricing, customer contracts, and supply chain economics. Companies with existing U.S. customer contracts should review force majeure and material adverse change provisions that may be triggered by tariff increases.

The Department of Justice filed a complaint on October 1 seeking to block the proposed merger of two major U.S. digital advertising technology platforms, alleging that the combination would substantially lessen competition in the programmatic advertising market. The complaint is the first major technology merger challenge filed under the updated 2023 Merger Guidelines.

The DOJ's challenge signals continued aggressive antitrust enforcement in digital markets. Turkish technology companies with U.S. operations or U.S. market ambitions should factor the current antitrust enforcement environment into their M&A strategy, particularly for transactions that consolidate data assets or market positions in digital advertising, e-commerce, or platform markets.

The SEC announced a settled enforcement action on October 2 against a registered investment adviser for deploying an AI-powered trading algorithm that made investment decisions based on material non-public information obtained through web scraping of corporate communications platforms. The adviser agreed to pay $12 million in disgorgement and penalties.

Turkish investment managers and family offices with U.S. registered investment adviser status or U.S. investor relationships should review their AI-powered investment tools for compliance with SEC insider trading regulations. The use of AI to process alternative data sources — including web-scraped corporate communications, satellite imagery, and social media sentiment — raises complex questions about the boundary between legitimate alternative data and material non-public information.

The FDIC issued updated guidance on the review of bank merger applications on October 2, clarifying the factors the agency considers in assessing the competitive effects, financial stability, and community reinvestment implications of proposed bank mergers. The guidance updates the FDIC's 2024 policy statement and reflects the agency's experience with the wave of community bank consolidation in 2025-2026.

Turkish banks and financial institutions evaluating U.S. bank acquisitions should review the updated FDIC guidance carefully. The guidance's emphasis on community reinvestment and financial stability — in addition to traditional competitive analysis — means that Turkish acquirers must demonstrate a credible plan for maintaining or improving the target bank's community lending and deposit-taking activities.

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