The International Enforcement Law Reporter

The International Enforcement Law Reporter is a monthly print and online journal covering news and trends in international enforcement law.

Since September 1985, the International Enforcement Law Reporter has analyzed the premier developments in both the substantive and procedural aspects of international enforcement law. Read by practitioners, academics, and politicians, the IELR is a valuable guide to the difficult and dynamic field of international law.

130 Human Rights Experts Call for States and Others to End Transnational Repression

Friday, October 9, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
11
Abstract: 

                On September 23, 2026, more than 130 human rights experts issued a joint statement calling for states and other actors to end transnational repression.  UN Special Procedures mandate holders and Treaty Body members, including the UN’s Special Rapporteurs on Iran, Russia, Belarus and North Korea all support the joint statement.  It calls for measures for governments, businesses, Interpol and international organizations to prevent and respond to transnational repression.

U.S. Senate Subcommittee Releases Report on Iranian Shadow Banking and Money Laundering

Friday, October 9, 2026
Author: 
Gavin Neff
Volume: 
42
Issue: 
11
Abstract: 

               On September 28, 2026, the U.S. Senate Permanent Subcommittee on Investigations released a 28-page report detailing the Iranian government’s use of Tether, a stabilized cryptocurrency, for avoiding sanctions and money laundering. The report found that since 2023, the Iranian government and its proxies, Hezbollah, Hamas and the Houthis have used various cryptocurrencies to move funds.  Tether emerged as the primary method of moving money.

U.S. Applies to Intervene in X Case to Annul Decision by European Commission

Friday, October 9, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
11
Abstract: 

                On September 24, 2026, the United States (U.S.) Department of Justice (DOJ) announced that the U.S. government has filed an application to intervene in the case brought by X and Elon Mask against the European Commission in the General Court of the Court of Justice of the European Union (GCEU) in Luxembourg in support of the applications to annul the decision of the European Commission finding the plaintiffs liable for violations of the European Union ‘s Digital Services Act (DSA).  The Commission imposed a fine of €120,000,000 jointly and severally, based on “the total worldwide annual turnover of the single economic unit ultimately controlled by Elon Musk or that of X Holdings Corp.”

Appeals Court Rejects Third-Country Deportation Policy, Supreme Court Grants Cert and Stays Requirements

Friday, October 2, 2026
Author: 
Austin Wahl
Volume: 
42
Issue: 
11
Abstract: 

            On September 18, 2026, the U.S. Court of Appeals for the First Circuit ruled that the Trump administration’s policy of deporting immigrants to third countries without adequate notice and an opportunity to object violates due process.  The decision largely affirmed a ruling in February by U.S. District Judge Brian Murphy, who had ruled that the Department of Homeland Security’s (DHS) third-country removal policy was unlawful.

EU Notifies 18 Members to Comply with AML Directive on Access to Beneficial Ownership Information

Friday, October 2, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
11
Abstract: 

                On September 24, 2026, the European Commission started infringement procedures by sending a letter of formal notice to Austria, Belgium, Bulgaria, Czechia, Germany, Estonia, Greece, Spain, Finland, France, Croatia, Cyprus, Lithuania, Luxembourg, the Netherlands, Poland, Portugal, and Romania for failing to fully notify national measures transposing certain provisions of the sixth Anti-Money Laundering (AML) Directive (Directive (EU) 2024/1640).

18 Suspects in Haitian Presidential Assassination Extradited to U.S. for Trial

Friday, October 2, 2026
Author: 
Gavin Neff
Volume: 
42
Issue: 
11
Abstract: 

                On September 20, 2026, U.S. Attorney for the Southern District of Florida, Jason Quinones announced that 18 suspects were extradited from Haiti to Miami on a military aircraft. The extradition comes as part of a broader sweep of arrests relating to the assassination of Haitian President Jovenel Moïse in 2021. Of the 30 arrests made, 12 others were detained in various other locations.

Council of Europe Takes Action to Counter Threats to the International Criminal Court

Friday, October 2, 2026
Author: 
Michael Plachta
Volume: 
42
Issue: 
11
Abstract: 

                At its 33rd meeting held on September 30, 2026, the Parliamentary Assembly of the Council of Europe (PACE) adopted its resolution and recommendation on threats to the International Criminal Court. The debate as well as recommendation and resolution were based on a Report prepared by the Committee on Legal Affairs and Human Rights.  The Assembly, meeting in plenary session in Strasbourg, expressed its concern regarding attempts “to threaten and intimidate international judges and prosecutors of the International Criminal Court (ICC)”, by subjecting them to coercive measures for undertaking their functions as part of the international criminal justice system.

U.S. Court Rules No Advance Notice Required for Foreign Tax-Related IRS Summonses

Friday, September 25, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
11
Abstract: 

            On September 17, 2026, the United States District Court for the Northern District of California in an opinion by Judge Vice Chhabria ordered the enforcement of IRS summonses issued to banks at the request of the South Korean National Tax service, holding that the IRS properly relied on the South Korean government’s representations and that the individual under investigation was not entitled to advance notice since the summonses related to foreign taxes.

U.S. Escalates Iran Sanctions While Further Easing Syria Restrictions

Friday, September 25, 2026
Author: 
Michelle Roberts and Daniel Klingenberg
Volume: 
42
Issue: 
10
Abstract: 

                 The Treasury Department’s Office of Foreign Assets Control (“OFAC”) has expanded the sectors of the Iranian economy subject to secondary sanctions, suspended several longstanding general licenses and other authorizations, imposed additional sanctions targeting Iran’s civil aviation sector, and adopted a presumption of denial for Iran-related specific license applications. At the same time, the United States has continued to ease restrictions on Syria, including rescinding its designation as a State Sponsor of Terrorism, but the full implementation of that change is yet to come.

 

When INTERPOL Notices Overlap: Joint CCF Review in Family-Related Cases[1]

Friday, September 25, 2026
Author: 
Anatoly Kleymenov
Volume: 
42
Issue: 
10
Abstract: 

               INTERPOL cases arising from family disputes may generate several forms of data at once: a Red or Blue Notice concerning a parent and a Yellow Notice concerning a child.  Although each Notice remains subject to its own legal test, reviewing the files in isolation may conceal the common factual basis and the continuing purpose of the data. This article examines the procedural basis for linked review before the Commission for the Control of INTERPOL’s Files, analyses three published CCF decisions, and describes an anonymized matter in which requests concerning a mother and child were presented as a connected factual group.  It argues that coordinated applications can improve the accuracy of the CCF’s assessment without creating any presumption of deletion.

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