🔎 Reliable mediator? Check out a new memo from FDD’s Natalie Ecanow scrutinizing Qatar’s record of brokering deals from Gaza to Afghanistan. While diplomacy is a cornerstone of Qatari foreign policy, Ecanow finds that “too often, Doha’s mediation succeeds to the detriment of American interests.” Doha either empowers groups like Hamas, al-Qaeda, and the Taliban or simply reinforces harmful dynamics, negotiating brief respites in perennial conflicts that soon grind on.
A U.S. Navy MH-60R Sea Hawk helicopter launches from the flight deck of USS Rafael Peralta (DDG 115) while enforcing the U.S. blockade against Iran, n.d. (@CENTCOM via X)
1. President Trump shot down another bad-faith Iranian ceasefire proposal over the weekend as U.S. economic leverage continues to mount. Washington should now close the remaining enforcement gaps and stand with the Iranian people.
- Deal, rejected: Sent to U.S. negotiators last week, the proposal would have included a seven-day pause in fighting and required Washington to lift its naval blockade and sanctions on Iranian oil exports, and to unfreeze Iranian assets. In exchange, Iran would have opened the Strait of Hormuz and begun negotiations on its nuclear program. But Trump rejected the deal on Saturday, explaining, “They want to make a deal, and I think that’s fine, I like making a deal, too, but that deal would not be acceptable.” Indeed, decades of U.S. pressure have left the Iranian regime increasingly isolated, and the United States does not need a deal that would front-load relief and eliminate American leverage.
- Iran’s dire straits: Operation Economic Fury is biting Tehran hard, write FDD’s Mark Dubowitz and Miad Maleki. Since the U.S. Navy reimposed its blockade in July, Iran’s oil loadings have collapsed by 85%, and a lack of imports has reportedly left the country with only two months of fuel. This has forced the regime into costly overland trade, with thousands of trucks sitting idle for weeks at border crossings, the pair explain. Dubowitz and Maleki recommend that Washington extend the blockade overland, “putting every trucking firm, freight forwarder and dry port handling Iranian cargo at risk of losing access to the dollar.”
- Closing the skies, mostly: Washington is ratcheting up pressure on Tehran with new secondary sanctions on the Iranian aviation sector, which took effect last week. Enforcement, however, has been uneven. Although most of Iran’s neighbors have fallen in line with the new restrictions, Turkey remains only partially compliant. Ankara has barred Iran’s Mahan Air, and Turkish air carriers have stopped flying to Iran, yet dozens of U.S.-sanctioned Iranian flights have still landed in Turkey since the sanctions took effect, explain FDD’s Ahmad Sharawi and Sinan Ciddi. To put Ankara on notice, the pair recommend that Treasury consider designating FUGO, a Turkish ground-handling company that has serviced these flights. “Washington could also press Ankara to halt landings by the U.S.-sanctioned Iranian carriers,” they add.
- And then there’s China: Beijing is another major enforcement gap in Washington’s campaign against Iran’s aviation sector. Last week, China declared its opposition to the sanctions, and Tehran’s main airport confirmed that flights to China continue. “Washington should give Beijing the chance to comply quietly by presenting Chinese aviation authorities with flight-level evidence and a private deadline,” advises Maleki. He also recommends that the State Department engage directly with the fuel and ground-service providers assisting Iranian airlines in China to warn them of the risk. Furthermore, Treasury should expand its existing alert directing banks to flag suspicious purchases of aircraft parts to cover payments for fuel, ground handling, and ticketing. And “if the flights continue, the next designations should reach the providers themselves,” Maleki concludes.
- Next stop, the streets: With Iran’s economy crumbling and the regime backed into a corner, Washington should stand with the Iranian people when protesters take to the streets again, explain Dubowitz and Maleki. That means “securing internet access, providing strike funds for workers and merchants, and targeting every commander who orders his men to fire on demonstrators,” they add. Congress can help by passing the Iran Human Rights, Internet Freedom, and Accountability Act of 2026 (H.R. 7622 / S. 3900) and the Feasibility Review of Emerging Equipment for Digital Open Media (FREEDOM) Act (H.R. 6469 / S. 3360). These bills would put the tools and coordination in place to ensure that any attempt by the regime to mask violence behind a near-total internet shutdown fails and cannot be repeated.
United Nations Headquarters (United Nations Photo, CC BY-NC-ND 2.0)
2. The UN and several European governments have launched economic warfare against Israel, targeting Israeli communities in the West Bank, also known as Judea and Samaria, through actions that ultimately threaten the entire Israeli economy and American companies.
- UN and Europe escalate: Last week, the UN’s Office of the High Commissioner for Human Rights (OHCHR) expanded its database, or “blacklist,” of companies it alleges are tied to activities in “illegal” Israeli settlements in the West Bank/Judea and Samaria. Most are Israeli, but some American and European firms also appear. Separately, on September 28 – days after the Netherlands barred settlement imports – travelers arriving from Israel faced “intrusive” baggage checks by Dutch customs. On September 29, three weeks after the British government announced its own ban, airline passengers from Israel reported similar extra screening by UK Border Force. Luxembourg’s financial authority also recently said it would stop approving the prospectuses that EU law requires for selling Israeli government bonds.
- Why does this matter? “These developments demonstrate that the architecture of sanctions and other punitive measures traditionally aimed at the adversaries of western democracies are now being applied to the State of Israel,” explains FDD’s Ben Cohen. Moreover, Israel’s supply chains are so closely intertwined with those of the West Bank/Judea and Samaria that tracing which side of the Green Line – the boundary separating Israel from the disputed territories – a product comes from is nearly impossible. As a result, measures purportedly aimed at a narrow set of targets actually harm the entire Israeli economy, regardless of where a given product was made, warns Cohen.
- European consequences: The UN’s database aims to galvanize governments and businesses but lacks legal force, notes Cohen. He adds, however, that the same is not true of the three European countries taking action against Israel. Dutch law punishes importing goods from the West Bank/Judea and Samaria or the Golan Heights with up to six years’ imprisonment and fines up to €1.1 million. Britain may impose comparable penalties once it implements its ban. Although Luxembourg envisions no penalties, Cohen explains that blocking Israel bond sales signals the EU is “ready to take measures punishing Israel on both sides of the Green Line.” Such a step may encourage states hostile to Israel to seek the suspension of the EU-Israel Association Agreement, he warns.
- Washington must respond: The United States should act immediately to counter this economic warfare, advises Cohen, because it harms American companies, which conduct more than $54 billion in trade with Israel annually. He recommends that the Trump administration make the payment of the $4 billion it owes the United Nations contingent on verifiably ending OHCHR’s pressure campaign against Israel. Washington should also “seek to protect U.S. entities from exposure to the campaign, if necessary through reciprocal measures against participating UN entities and foreign governments,” Cohen adds.
The table at high-level U.S.-China trade negotiations, hosted at the residence of the Swiss Ambassador to the United Nations, Geneva, Switzerland, May 11, 2025.
3. As China helps Russia complete Arctic LNG 2 – a project that will transfer millions of barrels of liquefied natural gas (LNG) primarily to China – Washington must improve sanctions enforcement against the Russian companies behind it and undermine Beijing’s “Polar Silk Road.”
- Impending arrival: As soon as this week, a pair of U.S.-sanctioned vessels from China will arrive in Russia’s far north to complete a major section of Arctic LNG 2, which Moscow is positioning as a key hub for its energy exports. This development comes as China remains the top buyer of Russia’s sanctioned Arctic-derived LNG and is investing in additional Arctic LNG import capacity. While it is unclear when the modules may arrive, “the voyage reflects a negative and inexplicable shift in how the United States is enforcing sanctions against Russia’s still-developing Arctic energy infrastructure,” explain FDD’s Max Meizlish and Emmerson Overell.
- Washington changing course: In years past, the United States took a stand against China’s efforts to help Russia build out its Arctic LNG operation. In 2023, the State Department told Congress that Washington intended to “kill” Arctic LNG 2, Meizlish and Overell note. That was followed by a Chinese-flagged vessel aborting a voyage to deliver a different pair of modules to the project and by Washington sanctioning the Chinese firm that had made them. However, those modules eventually reached Arctic LNG 2 in July 2026 after the Trump administration apparently shifted toward non-enforcement in the Arctic, Meizlish and Overell conclude.
- Beijing’s angle: China’s support for Arctic LNG 2 advances its efforts to build a “Polar Silk Road” of shipping routes and supporting infrastructure, explain Meizlish and Overell. The project deepens Chinese access to Russian ports and builds Chinese experience operating along the Northern Sea Route. These commercial ties could eventually support Chinese naval and coast guard operations, they add. At the same time, China has mapped the seabed north and west of Alaska, collecting data that the Defense Department says can aid submarine operations and seabed weapons placement. Meizlish and Overell warn that “although commercial, Arctic LNG 2 could support a more persistent Chinese presence near NATO’s northern flank.”
- Improve sanctions enforcement: The recently enacted Lindsey O. Graham Sanctioning Russia and Iran Act requires the President to review and potentially sanction principal shareholders with controlling or majority stakes in Russia’s Arctic energy projects, note Meizlish and Overell. This includes Novatek, Russia’s largest privately held natural gas company and the majority shareholder in Arctic LNG 2. The sanctions also reach foreign port owners and operators that service the vessels helping Russia evade sanctions, creating risk for Chinese logistics nodes linked to these voyages, such as the Beihai and Longkou terminals. “The Trump administration should aggressively enforce these sanctions — and Congress should demand accountability if enforcement remains weak,” Meizlish and Overell advise.
In other Russian sanctions evasion news…
- Good old-fashioned money laundering: A7, a Kremlin-backed group set up as an alternative to the Western payments system, laundered more than $6.9 billion through the international banking system despite sanctions on Russia, according to a new Financial Times report. The group relied on a network of front companies and existing businesses to access the SWIFT system – an international financial messaging service that is used to send and receive wire transfer instructions between bank accounts – and forged invoices at an industrial scale to obscure the transactions. Some of the payments involved highly sensitive war-related goods, including military equipment and purchases for Russia’s security services. The Treasury Department took action against A7 yesterday, designating the group’s network as a significant transnational criminal organization and alerting financial institutions to report related suspicious activity.
- What now? These revelations underscore that sanctions evasion is inherently transnational, exploiting gaps between jurisdictions, regulators, and enforcement regimes, Meizlish tells us. Combating it requires not only action against Russian actors but also sustained engagement with foreign regulators and financial centers. “As the principal steward of the dollar-based financial system, the United States has both the tools and the responsibility to address the illicit actors, financial intermediaries, and regulatory gaps that allow these networks to flourish,” Meizlish advises.
President Trump hosts a luncheon on Super AI in the East Room of the White House, Sept. 29, 2026. (Official White House Photo by Daniel Torok)
1. President Trump hosted top AI industry leaders this week for an event aimed at balancing AI innovation with oversight. The event comes amid rising AI safety concerns and Chinese advances that threaten America’s lead.
- The AI meeting: At the event, Trump and several AI leaders signed a voluntary agreement built around a “Joint Commitment on Frontier Responsibilities.” It asserts that every company is responsible for developing its own technology safely and calls on each to implement “four layers of controls and audits.” These include monitoring models’ capabilities and alignment, empowering internal teams, engaging external auditors, and establishing an independent board to oversee safety compliance. Although Trump described the accord only as “morally binding,” the agreement notes that these provisions could eventually be codified into law.
- Getting out of hand: AI is becoming more powerful and moving faster than our ability to control it, warns FDD’s Leah Siskind. Hundreds of OpenAI’s own agents recently coordinated to hack another company, breaking into systems and trying to cover their tracks. “That is the core problem,” explains Siskind. “AI isn’t naturally aligned with democratic values. It has to be trained to be. And that takes time we might not have.” The technology is also improving at developing and executing cyberattacks faster than defenses can keep up. Recent threat reports from leading AI companies have found that terrorists, state-linked hackers, and authoritarian regimes are using AI to run surveillance and influence operations at an unprecedented scale. “These are threats that we have to disrupt now, not later,” Siskind adds.
- Beat China safely: The underlying risks of AI are well documented, and the public’s fears are justified, notes Siskind. But regulating AI does not have to mean ceding ground to China. “The United States can pace development of the most powerful systems while slowing China’s progress through chip controls and preventing theft of our tech secrets,” she adds. Congress can help by passing the Deterring American AI Model Theft Act of 2026 (H.R. 8283). This bill would require an assessment of which foreign entities of concern are extracting capabilities from American closed-source AI models. It would also create a public “AI Model Extraction Attackers List” and make perpetrators eligible for the Commerce Department’s Entity List and for blocking sanctions.
U.S. Army Soldiers assigned to Task Force Nighthawk, 4th Combat Aviation Brigade, 4th Infantry Division receive their Shoulder Sleeve Insignia during a patching ceremony at Erbil Air Base, Iraq, Oct. 23, 2025. (U.S. Army photo by Spc. Doniel Kennedy)
2. President Trump touted the September 30 withdrawal of U.S. troops from Iraq, but what comes next remains uncertain after Iraqi PM Ali al-Zaidi delayed disarming Iran-backed militias.
- A mixed bag: On Wednesday, Trump declared the withdrawal “a victory for the United States, it’s a victory for Iraq and a decisive victory over ISIS, which has been completely decimated.” But the pullout was meant to coincide with Baghdad’s disarmament of Iran-backed militias. Instead, al-Zaidi pushed that deadline from September 30 to June 2027, with the first phase only beginning this week. His new timeline opens with a 90-day ceasefire between the United States and the militias. It also tasks the Popular Mobilization Forces (PMF), a security organization founded in 2014 to fight ISIS, with documenting and storing militia weapons. This is despite the PMF being dominated by the very militias it is meant to corral.
- Why it matters: “This delay reflects both the militia resistance and the limited government capacity to accomplish a challenging and controversial task,” notes FDD’s Bridget Toomey. Still, slow progress beats abandoning the effort, she adds. The militias’ demands remain maximalist: one group, Kataib Hezbollah, has demanded that U.S. forces withdraw, American influence be removed, Turkish forces leave northern Iraq, and the Kurdish Peshmerga be disbanded. Other militias echo these demands and are unlikely to concede as long as the United States and Iran are at war. Some also want the PMF preserved, even though the group has “become a vehicle for Iranian influence in the country and to siphon funds from the state,” Toomey explains.
- Raising the pressure: The PMF “will never be a reliable disarmament partner without a near-complete overhaul,” advises Toomey, including the removal of Iranian and militia-affiliated commanders. The Trump administration should therefore insist on the involvement, or at least oversight, of other Iraqi security institutions. The Treasury Department’s sanctions have highlighted concerns about the PMF, including its funding of militias designated as terrorist groups. If disarmament stalls, Toomey recommends that Treasury consider sanctioning the PMF financial elements that make these payments. Furthermore, any U.S. commitment not to strike the militias should be “contingent not only on their adherence to a ceasefire, but also compliance with disarmament,” she concludes.
✔︎ Endorsed Legislation:
Supporting the Rule of law, Building Institutional Justice, and Accountability (SRBIJA) Act (H.R. 10183 / S. 5611) – Introduced by Reps. Joe Wilson (R-SC) and Bill Keating (D-MA) in the House and by Sens. Chuck Grassley (R-IA) and Richard Blumenthal (D-CT) in the Senate, this bipartisan legislation addresses democratic backsliding in Serbia. It also opposes the Serbian government’s pursuit of a foreign policy that prioritizes political, economic, and security ties with Iran, Russia, and China over deeper engagement with the United States. Specifically, it directs the Secretary of State to stop participating in the U.S.-Serbia Strategic Dialogue unless the issues raised in the bill are addressed and to withhold additional assistance to Serbia until the country takes steps to address them.
✔︎ Endorsed Legislation:
A bill to provide for an audit and mitigation of covered cellular modules in the Department of Defense systems and infrastructure (S. 5598) – Introduced by Sen. Jim Banks (R-IN), this legislation is currently included in the Senate version of the FY27 NDAA (§ 819). Smart devices rely on cellular modules to connect to the internet, but China dominates the global market for these modules. This provision would address that supply chain risk by requiring regular DOD-wide audits to identify the Chinese-made cellular modules and mitigate the associated risks.
✔︎ Endorsed Legislation:
A bill to establish a War Reserve Stock Program for Taiwan (S. 5595) – Introduced by Sen. Jim Banks (R-IN), this legislation is currently included in the Senate version of the FY27 NDAA (§ 1250). Modeled on the decades-old stockpile prepositioned in Israel, the stockpile this provision would establish in Taiwan addresses concerns that the island could be cut off from resupply during a Chinese blockade.
✔︎ Endorsed Legislation:
A bill to require the Secretary of Defense to submit a plan to identify, prioritize, and remediate the presence of certain equipment and computational facilities owned or controlled by a foreign adversary in the electric grid of the United States (S. 5590) – Introduced by Sen. Jim Banks (R-IN), this legislation is currently included in the Senate version of the FY27 NDAA (§ 2872). It would require the Department of Defense to identify equipment and systems owned or controlled by adversary nations in critical U.S. electric infrastructure and create a plan with timelines and resource requirements to remove them.
NATO flags flying in Rotterdam, The Netherlands. (NATO, CC BY-NC-ND 2.0)
Invest in NATO cybersecurity and military mobility infrastructure.
Europe’s military mobility corridors are critically vulnerable to cyberattacks and operational disruption because of fragmented and insufficient digital and physical infrastructure. NATO determines its infrastructure and mobility capability needs, but it cannot mandate member-state spending or priorities. Moreover, NATO depends on a small number of third-party technology providers and civilian infrastructure that it does not directly regulate. Adversaries already target logistics and transportation systems to disrupt movement. Absent investments to address these physical and digital vulnerabilities, they could impede NATO’s ability to move forces when it matters most.
In a recent monograph, FDD’s Jiwon Ma recommends steps for NATO members to align spending with reinforcement requirements and to ensure that Europe’s military mobility corridors remain operational under attack:
- Show how investments contribute to collective defense. NATO should require allies to show how their defense-related investments address shortcomings identified in regional defense and reinforcement plans. It should also maintain a prioritized list of gaps that would delay reinforcement if left unaddressed and provide the EU with military requirements to guide its funding decisions.
- Establish a pooled multinational rail mobility capability. The Movement Coordination Centre Europe (MCCE), an independent multinational military organization, coordinates rail capacity that participating nations offer voluntarily but lacks command authority. These nations should jointly procure or designate, in coordination with the MCCE, a minimum pool of dual-use heavy-lift wagons with pre-agreed access in a crisis.
- Operationalize the NICC around NATO battle plans. NATO established its Integrated Cyber Defence Centre (NICC) to inform commanders about cyber threats to NATO and allied networks, including privately owned critical infrastructure. The NICC should organize that mission around the ports, railways, airports, energy networks, and technology providers that NATO reinforcement plans depend on. This includes distinguishing cyber incidents that impose primarily commercial costs from those that threaten NATO’s ability to execute a defense plan.
No relevant reports due to Congress next week…
Child paints a pumpkin during the USDA Farmers Market, which celebrates the close of its 22nd season in Washington, DC, Oct. 27, 2017 (USDA Photo by Lance Cheung.)
🍂 Hello October, goodbye heatwave: Washington has finally felt a breeze in the air, so it’s time to kick off fall with some local festivities. We put together a list of the most fun, interesting, and maybe even a little weird celebrations happening in the DMV this season.
- Chainsaw Manassas: Historic Manassas, VA, is hosting its annual Fall Jubilee this Saturday, featuring a fan favorite: chainsaw carving. But if woodworking isn’t your thing, there will also be kids’ activities and 100+ craft and community booths to explore. Then again, nothing says fall quite like watching a guy named Paul use his trusty chainsaw to carve a bear out of a giant piece of wood.
- Quacktoberfest: If you’re a Jeep owner or just happen to enjoy a rubber ducky in the bath, grab those duckies and hurry to downtown Fredericksburg, VA, for its Duck Derby! Thousands of rubber ducks will race down the Rappahannock River for a chance to win prizes. Racing can get intense, so calm those pre-race nerves or celebrate a big win at the biergarten with live music and local food.
- Traditional Festivities: Frederick County, MD, is hosting a genuine harvest festival this weekend, with agricultural demonstrations, hayrides, food, and crafts for the whole family to enjoy. So head north of D.C. for some relaxation outside the city, but maybe bring that competitive spirit with you (just in case). We hear there will be an Agriculture Olympics on Saturday.
- For our Fall Fanatics: One weekend of celebrating isn’t enough for some folks – that’s why Purcellville, VA, has a full week full of events sure to complete everyone’s fall bucket list. Play along all week for prizes by collecting passport stickers at various events, which give you clues for the town-wide scavenger hunt, and by answering the nature trivia questions along the Chapman DeMary Trail. If you’re truly committed to fall, this celebration is for you!