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 PdVSA
Enforcement
OFAC Issues Temporary Reprieve for Certain Russian-Origin Crude Oil Shipments
On March 12, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued Russia-related General License 134 (GL 134) authorizing, until April 11, 2026, transactions relating to the sale, delivery, and offloading of Russian-origin crude oil and petroleum products loaded on vessels as of March 12, 2026. The general license follows recent disruptions to global oil supply arising from the ongoing conflict in the Middle East.Continue Reading OFAC Issues Temporary Reprieve for Certain Russian-Origin Crude Oil Shipments
OFAC 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 Gold
U.S. Court of International Trade Orders Refunds of IEEPA Tariffs
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
The Rise of the New EU FDI Screening Regulation
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
Supreme Court Strikes Down IEEPA Tariffs: What To Know and Expect
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
DOJ 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.
Trade Controls, Foreign Investment and National Security: New Regimes and Continuing Changes for 2026
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
Italy Introduces New Criminal Offenses and Corporate Liability for Breaches of EU Sanctions
Legislative Decree No. 211/2025 (the “Sanctions Decree”), effective as of January 24, implements EU Directive 2024/1226 (the “Directive”) on violations of EU restrictive measures (the “EU Sanctions”) and introduces new criminal offenses, thereby significantly reshaping the applicable sanctions framework. Importantly, these offenses are now included among those triggering corporate liability under Legislative Decree No. 231/2001 (the “Decree 231”).Continue Reading Italy Introduces New Criminal Offenses and Corporate Liability for Breaches of EU Sanctions
New Guidance Issued and Changes Underway for U.S. Outbound Investment Regime as 2026 NDAA Defense Bill Introduces Outbound Investment, Sanctions, and Biotech Updates
On December 18, 2025, President Trump signed the 2026 National Defense Authorization Act (“NDAA”), a sweeping defense spending bill that brings a number of changes to the U.S. outbound investment security program, U.S. economic sanctions, and biotechnology restrictions relating to federal procurement. First, the NDAA includes the Comprehensive Outbound Investment National Security (“COINS”) Act, which provides a statutory basis for the U.S. Outbound Investment Security Program (“OISP”) and directs the U.S. Department of the Treasury (“Treasury”) to issue new regulations that expand the relevant “countries of concern” and covered sectors, as well as certain exceptions. On December 23, 2025, Treasury also issued new FAQs clarifying the scope of the publicly traded securities exception and confirming that the current OISP rules will remain in effect until Treasury issues regulations to implement the COINS Act.Continue Reading New Guidance Issued and Changes Underway for U.S. Outbound Investment Regime as 2026 NDAA Defense Bill Introduces Outbound Investment, Sanctions, and Biotech Updates