This update reviews material U.S. legal and regulatory developments as of September 26, 2026.

OFAC published updated guidance on the application of secondary sanctions to non-U.S. persons who provide material support to Russia's military-industrial complex on September 25. The guidance clarifies the evidentiary standard for "material support" determinations and identifies specific categories of goods and services — including machine tools, electronics, and financial services — that OFAC considers to constitute material support regardless of the transaction value.

Turkish financial institutions, exporters, and logistics companies that process transactions involving Russian counterparties should review the updated guidance carefully. The clarification of the "material support" standard increases the risk that routine commercial transactions with Russian entities could be characterized as sanctionable conduct. Turkish companies should implement enhanced due diligence procedures for Russian-related transactions and consider whether existing compliance programs adequately address the updated guidance.

The Federal Trade Commission announced a consent order on September 24 against a major U.S. technology company for deploying AI-powered employee monitoring software without adequate disclosure to employees or compliance with applicable state biometric privacy laws. The consent order requires the company to obtain explicit employee consent before deploying AI monitoring tools, provide employees with access to data collected about them, and implement a data retention and deletion policy.

Turkish companies with U.S. employees that use AI-powered productivity monitoring, attendance tracking, or performance management tools should review their compliance with applicable state biometric privacy laws — particularly Illinois BIPA, Texas CUBI, and Washington's My Health MY Data Act — and their employee disclosure and consent practices. The FTC's enforcement action signals increased regulatory scrutiny of AI-powered workplace surveillance tools.

The SEC adopted final rules on September 25 updating the beneficial ownership reporting requirements under Sections 13(d) and 13(g) of the Securities Exchange Act. The final rules shorten the initial Schedule 13D filing deadline from 10 days to 5 days after crossing the 5% ownership threshold, and require amendments within 2 business days of a material change. The rules also clarify the treatment of cash-settled derivatives and security-based swaps in the beneficial ownership calculation.

Turkish investors and investment funds that hold or may acquire 5% or more of a U.S. public company's equity securities should update their compliance calendars to reflect the shortened filing deadlines. The clarification of derivative treatment is particularly relevant for Turkish investors who use total return swaps or other cash-settled instruments to gain economic exposure to U.S. equities without formal ownership.

The Financial Crimes Enforcement Network published updated guidance on the application of civil penalties for willful and non-willful FBAR violations on September 24. The guidance clarifies the factors FinCEN considers in determining whether a violation is willful, including the account holder's level of sophistication, the duration of the violation, and whether the account holder sought professional advice.

Turkish individuals and entities with U.S. tax obligations who hold foreign financial accounts with aggregate balances exceeding $10,000 at any point during the calendar year must file an FBAR. Turkish nationals who have become U.S. tax residents — including green card holders and individuals who meet the substantial presence test — should review their FBAR compliance and consider whether any prior non-compliance should be addressed through the IRS Streamlined Filing Compliance Procedures.

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