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I. Introduction

On October 22, 2026, the German Federal Ministry for Economic Affairs and Energy (Bundesministerium für Wirtschaft und Energie, BMWE) published the long-anticipated ministerial draft of a new, standalone Investment Screening Act (Investitionsprüfungsgesetz, Draft IPG) and an accompanying Investment Screening Ordinance (Investitionsprüfungsverordnung, Draft IPV).

Continue Reading Germany Proposes Standalone Investment Screening Act: Familiar Foundations, New Pitfalls for Dealmakers
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On October 7, 2026, the U.S. Department of the Treasury (Treasury) announced that it had issued the first civil monetary penalty under the Outbound Investment Security Program (OISP) in July 2026.[1] Treasury penalized Amidi, LLC (Amidi), a U.S. entity, $200,000 for failing to notify Treasury of an investment by its controlled foreign entity, a Chinese fund, in a Chinese artificial intelligence (AI) and robotics company. Amidi also is the parent entity of Plug and Play Tech Center, a Silicon Valley-based global innovation platform and startup accelerator. Although the underlying investment was modest in dollar terms, the announcement is significant as the first publicly announced enforcement action under the OISP, which took effect on January 2, 2025. 

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On August 21, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued General License (GL) 61 and GL 62, respectively authorizing the provision of U.S. goods, technology, software, and services in support of telecommunications in Venezuela, and the negotiation of and entry into contingent contracts for new investment in the telecommunications sector of Venezuela. In particular, the GLs authorize transactions involving the Government of Venezuela (GoV), Comisión Nacional de Telecomunicaciones (CONATEL), Venezuela’s state-owned telecommunications agency, and Compania Anonima Nacional Telefonos de Venezuela (CANTV), Venezuela’s state-owned telephone and internet service provider, which would otherwise be prohibited. [1]

Continue Reading OFAC Issues General Licenses Authorizing Activity in Venezuelan Telecommunications Sector
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For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit U.S. Policy & Regulatory Outlook.

On August 24, 2026, the U.S. government announced “Operation Economic Outcast,” initiating a “whole-of-government campaign” centered on additional economic sanctions against Iran. Acting at the direction of President Trump, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC): (i) issued five new sectoral sanctions determinations under Executive Order (E.O.) 13902 targeting Iran’s digital assets, technology, gold, aviation, and shipping sectors; (ii) issued new guidance on the sanctions risks associated with Iranian demands related to shipping in the Strait of Hormuz; (iii) suspended several general licenses (GLs) that previously had authorized certain remittance payments and cultural and academic exchanges with Iran; and (iv) designated nearly 60 entities, individuals, and vessels across multiple jurisdictions on the list of Specially Designated Nationals and Blocked Persons (SDN List).[1] The Treasury Department’s announcement also warned of consequences for third countries that continue to do business with Iran, stating that the U.S. government has engaged counterparts in foreign governments to provide timelines for terminating existing business with Iran or face punitive measures from the U.S. government.[2]

Continue Reading U.S. Government Announces Operation Economic Outcast Targeting Iran
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For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit U.S. Policy & Regulatory Outlook.

The Committee on Foreign Investment in the United States (CFIUS or the Committee) recently published its 2025 Annual Report, which provides information regarding transactions reviewed by CFIUS during 2025.[1] Key takeaways from the 2025 Annual Report are below.

Continue Reading CFIUS Releases 2025 Annual Report: Key Takeaways
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For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit U.S. Policy & Regulatory Outlook.

On July 28, 2026, the Federal Communications Commission (FCC) added foreign-produced “advanced robotic devices” and “power inverters” to the FCC’s Covered List, effectively barring covered equipment from receiving the FCC equipment authorizations necessary for most electronic devices to be imported, marketed, or sold in the United States.[1] Separately, the FY2027 National Defense Authorization Act (NDAA), passed by the U.S. House of Representatives on July 22, 2026, includes the “Guarding Unregulated AI Robots from Deployment Act” (GUARD Act), a proposed bill that would prohibit the U.S. Department of Defense (DoD) from procuring humanoid robotic systems produced by foreign adversaries, including China.[2] The FCC’s Covered List update, in particular, represents a significant expansion of U.S. national security restrictions on mobile robotics and power inverters (which have applications in the power grid, among other uses). 

Continue Reading FCC Adds Foreign-Produced Robotics, Power Inverters to Covered List; House NDAA Targets Foreign Adversary Humanoid Robots
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For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit U.S. Policy & Regulatory Outlook.

On July 23, 2026, the Trump administration announced new tariffs (Forced Labor Tariffs) on goods from 60 economies, including the European Union (EU) and China, alleging these economies either failed to enforce forced labor prohibitions or failed to adopt a forced labor import prohibition. The new duties took effect on July 24, 2026, replacing the temporary 10% global tariff imposed by President Trump under Section 122 of the Trade Act of 1974 (Section 122 Tariffs), which expired on July 24, 2026. Section 122 Tariffs originally were imposed after the Supreme Court struck down the administration’s prior tariffs imposed under the International Emergency Economic Powers Act (IEEPA).[1] Although the Trump administration has stated that the Forced Labor Tariffs will apply to 99% of imports into the United States, the duties (ranging from 10 to 12.5%) have a number of exemptions and exclusions, including products subject to tariffs imposed under Section 232 of the Trade Expansion Act (Section 232 Tariffs).

Continue Reading Trump Administration Imposes New Section 301 Tariffs on 60 Trading Partners, New Section 338 Tariffs on Canada
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On June 18, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued General License (GL) 59, authorizing the provision of goods, technology, software, or services relating to aircraft of Venezuela’s state-owned airline, Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa). Separately, OFAC recently amended seven existing Venezuela-related GLs to ease the governing law and dispute resolution requirements applicable to contracts entered into under those licenses. In addition, on June 25, 2026, OFAC issued GL 60, authorizing transactions related to earthquake relief efforts in Venezuela until October 2026. Together, these actions reflect OFAC’s continued easing of Venezuela sanctions by expanding the scope of permissible aviation-related activities, reducing barriers to participation in authorized transactions, and facilitating humanitarian relief efforts.

Continue Reading OFAC Continues Venezuela Sanctions Relief with Authorizations for Aircraft Safety, Earthquake Relief, and Easing of General License Governing Law Requirements
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Over the last several months, Venezuela’s interim government has moved swiftly to reopen the country’s oil sector to private investment, amending the Organic Hydrocarbons Law and enacting implementing regulations just last week. There is little doubt that the reformed law includes many positive changes to encourage new investment: it ends PDVSA’s decades-long monopoly on primary oil activities, lowers the state’s minimum ownership stake in joint ventures, and formalizes a new contractual framework (CPPs) expected to be the primary vehicle for new investment. The regulations include a more streamlined fiscal regime, including a royalty ceiling of 30%, and a simplified integrated hydrocarbons tax capped at 15%, replacing the prior multi-layered tax structure.

Continue Reading Venezuela’s Oil Reform Efforts: New Opportunities, Unanswered Questions – U.S. Investor Perspective
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For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit U.S. Policy & Regulatory Outlook.

On July 8, 2026, President Trump informed Congress of his administration’s intent to rescind Syria’s designation as a State Sponsor of Terrorism (SST), giving Congress the requisite 45-day pre-notification period. The rescission of Syria’s SST designation is one of the final steps in the rollback of financial and other trade restrictions against Syria following President Trump’s June 30, 2025 Executive Order revoking executive orders that imposed sanctions and export restrictions on Syria, and directing the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), U.S. Department of State, and U.S. Department of Commerce to ease trade and finance restrictions on Syria. Syria’s designation as an SST is set to expire following a 45-day mandatory congressional review period, absent formal opposition from Congress.

Continue Reading U.S. Government Removes Syria From List of State Sponsors of Terrorism