Over the past few weeks, the Trump administration marked the latest phase in its escalation of sanctions against Cuba, the subject of the longest running U.S. sanctions program. On May 1, 2026, President Trump issued Executive Order (E.O.) 14404, establishing a new secondary sanctions regime that authorizes the imposition of sanctions on companies, individuals, and financial institutions operating in certain sectors of the Cuban economy, as well as Cuban government entities and affiliates. Although U.S. sanctions against Cuba already broadly prohibit U.S. parties and their non-U.S. subsidiaries from dealings or transactions with Cuba, the E.O. represents a broader Trump administration policy of increasing economic pressure on the Cuban government by leveraging the threat of secondary sanctions to limit Cuba’s economic engagement with other countries.
Continue Reading Trump Administration Begins to Implement New Cuba Secondary Sanctions Regime Targeting Business With CubaKerry Mullins
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OFAC Authorizes Commercial Negotiations With the Government of Venezuela and Certain Financial Services
On April 14, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued two new General Licenses (GL), GLs 56 and 57, authorizing commercial negotiations with the Government of Venezuela (GoV) and the provision of a broad range of ordinary-course financial services involving the Venezuelan central bank and three state-controlled banks or GoV individual employees and affiliates.
Continue Reading OFAC Authorizes Commercial Negotiations With the Government of Venezuela and Certain Financial ServicesOFAC Lifts Belarus Sovereign Debt Ban, Eases Sanctions on Belarusian Potash Sector
On March 26, 2026, the U.S. Department of the Treasury (Treasury), Office of Foreign Assets Control (OFAC) rescinded Directive 1 under Executive Order (E.O.) 14038, which had prohibited transactions in Belarusian sovereign debt with maturity of longer than 90 days issued since December 2, 2021. In parallel with the rescission of Directive 1, OFAC issued General License (GL) 14, authorizing transactions involving the Belarussian Bank of Development and Reconstruction Belinvestbank Joint Stock Company (Belinvestbank), among other entities. OFAC also removed several significant Belarusian potash sector entities from the Specially Designated Nationals and Blocked Persons List (SDN List).
Continue Reading OFAC Lifts Belarus Sovereign Debt Ban, Eases Sanctions on Belarusian Potash SectorOFAC Expands Authorized Activities in Venezuelan Mining Sector
On March 27, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) amended an existing General License (GL) and issued two new GLs authorizing new activity in Venezuela’s mining and minerals sectors. Since January 2026, the U.S. government has issued a series of general licenses authorizing sector- or activity-specific dealings relating to Venezuela under specified conditions. GLs 51A, 54, and 55 extend this framework — previously primarily focused on the oil and gas sector — to Venezuela’s minerals sector, including gold.
Continue Reading OFAC Expands Authorized Activities in Venezuelan Mining SectorOFAC Issues GL 52, Further Loosening Sanctions Against PdVSA
On March 18, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued General License (GL) 52, authorizing certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, PdVSA Entities) by an established U.S. entity.[1] Concurrently with GL 52, OFAC issued two new Venezuela-related Frequently Asked Questions (FAQs) addressing key aspects of GL 52. Since January 2026, the U.S. government has issued a series of general licenses authorizing sector- or activity-specific dealings relating to Venezuela (including PdVSA Entities) under specified conditions. This latest general license represents a further step by the U.S. government to encourage investment in Venezuelan oil production, as part of a broader effort to expand Venezuela’s production and export capacity.[2]
Continue Reading OFAC Issues GL 52, Further Loosening Sanctions Against PdVSAOFAC Expands Venezuela Sanctions Relief to Fertilizers and Petrochemical Products, Investment in Petrochemical and Electricity Sectors
On March 13, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued three amended General Licenses (GLs), extending authorized activities to include the export of petrochemical and fertilizer products from Venezuela, as well as new investment in the Venezuelan petrochemical and electricity sectors.
Continue Reading OFAC Expands Venezuela Sanctions Relief to Fertilizers and Petrochemical Products, Investment in Petrochemical and Electricity SectorsOFAC Eases Sanctions on Venezuelan-Origin Gold
On March 6, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 51, authorizing transactions that are ordinarily incident and necessary to the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin gold for importation into the United States, the refining of such gold in the United States, and the resale or exportation of such gold from the United States, by “an established U.S. entity.”[1]
Continue Reading OFAC Eases Sanctions on Venezuelan-Origin GoldOFAC Issues General Licenses 49 and 50A Authorizing Contingent Investments and Additional Operations in Venezuelan Oil and Gas Sector
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 SectorDOJ Files First-Ever Complaint to Enforce CFIUS Divestment Order Against Suirui Group Co., Ltd.
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.OFAC Issues General License 47 Authorizing Sale of U.S.-Origin Diluents to Venezuela
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