For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.

On March 4, 2026, the U.S. Court of International Trade (“CIT”) issued an order (the “Order”) directing the U.S. government to refund tariffs imposed by the Trump Administration under the International Emergency Economic Powers Act of 1977, 50 U.S.C. 1701, et seq. (“IEEPA”) that recently were struck down by the Supreme Court of the United States (“SCOTUS”) in Learning Resources, Inc. v. Trump on February 20, 2026.[1] The Order has immediate implications for importers seeking refunds for the so-called “Trafficking Tariffs” previously imposed on Canada, China, and Mexico, the “Reciprocal Tariffs” previously imposed on most U.S. trading partners, and additional tariffs imposed pursuant to IEEPA (together, the “IEEPA Tariffs”).[2]

Continue Reading U.S. Court of International Trade Orders Refunds of IEEPA Tariffs

On February 10, 2026, the provisional text[1] of the new EU FDI screening regulation was finally published (the “New Regulation”). This reflects the political agreement reached on December 11, 2025, between the European Parliament and the Council of the European Union (“Political Agreement”).[2]

Continue Reading The Rise of the New EU FDI Screening Regulation

On March 2, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) imposed sanctions on the Rwanda Defence Force (“RDF”, the military of Rwanda) and four senior RDF officials pursuant to the Democratic Republic of the Congo Sanctions Regulations (“DRCSR”) (codified at 31 C.F.R. Part 547).[1] Concurrent with the designations, OFAC issued General License No. 1 (“GL 1”) authorizing the wind down of transactions involving the RDF through April 1, 2026.[2]

Continue Reading OFAC Sanctions Rwanda Defence Force and Senior Officials in Connection with DRC Conflict

On February 20, 2026, the United States Supreme Court (the “Court”) held in Learning Resources, Inc. et al. v. Trump (“Learning Resources”) that the International Emergency Economic Powers Act of 1977, 50 U.S.C. 1701, et seq. (“IEEPA”) does not authorize the President of the United States (the “President”) to impose tariffs (the “Decision”). The Decision has significant implications, most directly for importers that have been paying duties imposed by President Trump under IEEPA on imports from most U.S. trading partners in response to trade deficits referenced by the administration and on imports from Canada, Mexico, and China in response to the alleged influx of illegal drugs from those countries.

Continue Reading Supreme Court Strikes Down IEEPA Tariffs: What To Know and Expect

On February 13, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 49 and GL 50 (since amended as 50A),[1] continuing the expansion of authorized activities in the Venezuelan oil and gas sectors. These two licenses follow five additional licenses recently issued by OFAC[2] collectively providing distinct pathways for engagement with Venezuelan energy operations while maintaining stringent controls and oversight mechanisms by the U.S. government. GL 49 authorizes negotiation of and entry into contingent contracts for certain new investments in oil or gas sector operations in Venezuela, and GL 50A authorizes transactions by BP, Chevron, Eni, Établissements Maurel & Prom SA, Repsol, and Shell related to oil or gas sector operations in Venezuela.

Continue Reading OFAC Issues General Licenses 49 and 50A Authorizing Contingent Investments and Additional Operations in Venezuelan Oil and Gas Sector

Over the past few months, the Italian FDI (the so-called “golden power”) regime has once again witnessed multiple key developments that investors and potential targets should take into due account, notably:

Continue Reading The Restless Italian FDI Landscape: a Snapshot of the Latest Developments

For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.

On February 9, 2026, the U.S. Department of Justice (“DOJ”) filed a complaint in the U.S. District Court for the District of Columbia to enforce a presidential order (the “Order”) requiring a Chinese company, Suirui Group Co., Ltd., and its Hong Kong subsidiary, Suirui International Co., Limited (collectively, “Suirui”), to divest their interest and rights in Jupiter Systems, LLC (“Jupiter”), a California-based company specializing in video processing technology.

Continue Reading DOJ Files First-Ever Complaint to Enforce CFIUS Divestment Order Against Suirui Group Co., Ltd.

On February 6, 2026, the U.S. Department of the Treasury (“Treasury”), as chair of the Committee on Foreign Investment in the United States (“CFIUS”), issued a Request for Information (“RFI”) seeking public input on a new Known Investor Program and ways to make CFIUS’s review process more efficient.[1]  Stakeholders have until March 18, 2026 to submit comments regarding how CFIUS can streamline its foreign investment review process while maintaining a rigorous national security analysis.

Continue Reading Treasury Seeks Public Input on CFIUS Known Investor Program and Additional Process Efficiencies

On February 3, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 47 generally authorizing the export, sale, and supply of U.S.-origin diluents to Venezuela. The issuance of GL 47 comes less than a week after OFAC issued GL 46 on January 29, 2026, authorizing certain transactions related to the lifting, refinement, export, and sale of Venezuelan oil.[1] GL 47 addresses a critical operational need in Venezuela’s oil sector, as diluents are essential for the processing and transport of Venezuelan heavy crude, which is viscous and dense.

Continue Reading OFAC Issues General License 47 Authorizing Sale of U.S.-Origin Diluents to Venezuela

Update: On February 10, 2026, OFAC issued GL 46A, which amended GL 46 to clarify that payments for local taxes, permits, or fees are excluded from the requirement to be deposited into Foreign Government Deposit Funds.

On January 29, 2026 the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 46 authorizing certain transactions relating to the lifting, refinement, and trade of Venezuelan-origin oil by established U.S. entities. This marks the first public action by OFAC in revising the general Venezuela sanctions regime since the U.S. apprehension of Nicolás Maduro.[1] GL 46 comes on the heels of the Venezuelan National Assembly’s passage of a new hydrocarbons law aimed at facilitating foreign investment in the Venezuelan hydrocarbon sector.[2] While the issuance of GL 46 is a significant move in easing sanctions under the new Venezuelan administration, its precise scope warrants close review as the new license continues to place strict requirements with respect to operations in the Venezuelan oil sector.

Continue Reading OFAC Eases Venezuelan Oil Sanctions Following Maduro Apprehension