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

The following is part of our annual publication Selected Issues for Boards of Directors in 2026. Explore all topics or download the PDF.


In 2026, boards of directors will continue to navigate a shifting U.S. regulatory environment shaped by an assertive and transactional approach to trade and national security. Uncertainty surrounding the most significant U.S. trade development in decades continues into the new year as the U.S. Supreme Court is expected to rule in the coming weeks on the validity of the “reciprocal tariffs” imposed by the second Trump administration against most U.S. trading partners.

Continue Reading Trade Controls, Foreign Investment and National Security: New Regimes and Continuing Changes for 2026

After the apprehension of Nicolás Maduro on January 3, 2026, the White House has actively advocated for Venezuelan market access for U.S. oil companies. Although a regulatory framework under which such investment can occur remains uncertain, any such arrangement will need to account for the sweeping U.S. sanctions that have been imposed against Venezuela over the past decade in response to alleged human rights abuses, corruption, and the erosion of democratic institutions under the Maduro regime. As of writing, these sanctions remain in full-effect, generally blocking the property of the Government of Venezuela (“GoV”) and restricting U.S. persons (and non-U.S. persons to the extent they are engaging in dealings within U.S. jurisdiction) from engaging in transactions or other dealings with the GoV, entities owned or controlled by, or acting on behalf of, the GoV, including the state-owned oil company Petroleos de Venezuela, S.A. (“PdVSA”), and certain individuals in leadership of the GoV. Moreover, the U.S. government maintains discretion to impose blocking sanctions against parties determined to engage in certain activities, including operating in the defense and security, financial, oil, and gold sectors of Venezuela, as well as any other sectors as determined by the U.S. government in the future.  This note provides an overview of key Executive Orders (“E.O.”) constituting the Venezuela sanctions framework, including a description of the status of relevant General Licenses (“GL”), and considerations for the future as the White House explores potential arrangements with Venezuela for U.S. oil company market entry.

Continue Reading Navigating Venezuela Sanctions: Legal Considerations and Anticipated 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 January 2, 2026, President Trump issued an order (the “Order”) prohibiting HieFo Corporation (“HieFo”), a Delaware company, from maintaining ownership of digital chip and wafer-related assets (including a semiconductor manufacturing facility) that HieFo acquired from EMCORE Corporation (“EMCORE”). HieFo acquired the assets in April 2024 for $2.92 million, and the Committee on Foreign Investment in the United States (“CFIUS”) subsequently reviewed the transaction.

Continue Reading President Trump Issues Order Requiring Hiefo Corporation to Divest Ownership of Digital Chip and Wafer-related Assets

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 October 22, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) imposed blocking sanctions on Russia’s two largest oil producers, Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”), pursuant to Executive Order 14024 (“E.O. 14024”). Concurrently, and in the subsequent weeks, OFAC also issued several general licenses authorizing certain transactions with Rosneft, Lukoil, and certain subsidiaries, including negotiations and entry into an agreement for the divestment of certain Lukoil international assets, contingent on OFAC approval.

Continue Reading OFAC General Licenses Open Door for Lukoil Divestment and Other Limited Activities Following Rosneft and Lukoil Sanctions