KevinZhang

On May 29, 2026, the Office of Management and Budget (OMB), joined by federal grantmaking agencies, issued a lengthy proposed rule[1] covering many aspects of federal financial assistance, including:

On March 31, 2026, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance (“Guidance”) on “Sham Transactions and Sanctions Evasion.” This Guidance confirms and formalizes what a series of recent enforcement actions has made clear: while OFAC’s long-standing 50% Rule is still in place, it is a floor, not a ceiling, to corporate diligence. According to the Guidance, it is important to look “beyond legal formalities to underlying practical and economic realities.” T

After a year of significant upheaval for higher education institutions, additional changes are on the horizon in 2026. The most recent Unified Agenda, the One Big Beautiful Bill Act, and other developments mean additional changes for—as outlined below—civil rights enforcement, admissions, foreign gift reporting, accreditation, visa requirements and eligibility, grant funding, student loans, patent revenue, and student privacy. Understanding and anticipating these developments will help position