This update reviews material U.S. legal and regulatory developments as of September 12, 2026.

The SEC confirmed the phased compliance schedule for its climate-related disclosure rules following the resolution of the consolidated legal challenges in the Eighth Circuit. Large accelerated filers must begin disclosing Scope 1 and Scope 2 greenhouse gas emissions for fiscal years beginning on or after January 1, 2027. Accelerated filers follow one year later. Smaller reporting companies and non-accelerated filers have extended timelines through 2029.

Turkish companies listed on U.S. exchanges — including those with American Depositary Receipts — should assess their current GHG emissions measurement and reporting infrastructure against the SEC's requirements. The rules require disclosure of material climate-related risks, governance, and strategy in addition to emissions data. Companies that have not yet established a GHG inventory methodology aligned with the GHG Protocol should begin that process now to meet the 2027 effective date for large accelerated filers.

The Department of Justice Antitrust Division published updated supplemental guidance on the application of the 2023 Merger Guidelines to technology platform markets, addressing multi-sided platforms, data network effects, and the treatment of nascent competition. The guidance clarifies that the Division will assess platform acquisitions not only on current market share but on the acquisition's effect on potential competition and the foreclosure of future competitive entry.

Turkish companies acquiring U.S. technology platforms or digital marketplaces should expect heightened DOJ scrutiny of transactions that eliminate potential competitors or consolidate data assets. The guidance's emphasis on nascent competition means that even acquisitions of small, early-stage companies can attract review if the target operates in a market adjacent to the acquirer's core business.

OFAC designated 14 additional entities and individuals under the Iran Sanctions Regulations on September 11, targeting a network of front companies facilitating the procurement of dual-use components for Iran's ballistic missile program through intermediaries in the UAE, Türkiye, and Central Asia.

Turkish companies engaged in trade with the UAE and Central Asian markets should review their customer and counterparty screening procedures against the updated SDN list. The designation of Türkiye-linked intermediaries underscores the enforcement risk for Turkish exporters and financial institutions that process transactions involving sanctioned networks, even when the Turkish party is not itself the ultimate end-user.

The Department of Commerce initiated a new antidumping investigation on steel reinforcing bar (rebar) from Türkiye on September 11, following a petition filed by the domestic steel industry. The petition alleges dumping margins of 15–35% for major Turkish producers.

Turkish rebar producers and U.S. importers should monitor the investigation timeline carefully. Commerce will issue a preliminary determination within approximately 140 days of initiation. During the investigation period, importers may be required to post cash deposits at the preliminary dumping margin rate. Turkish producers that have not previously participated in U.S. antidumping proceedings should engage U.S. trade counsel immediately to assess whether participation in the investigation as a mandatory or voluntary respondent is in their commercial interest.

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