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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

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 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

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.

Shortly after publication of this post, the Trump administration filed a petition for a writ of certiorari to the U.S. Supreme Court, which has expedited its review with oral arguments scheduled for November 5, 2025. The tariffs will remain in effect pending the Supreme Court’s review.

On August 29, 2025, the U.S. Court of Appeals for the Federal Circuit (the “Federal Circuit”) issued a 7-4 decision upholding the U.S. Court of International Trade’s (the “CIT”) May 28, 2025 ruling striking down President Trump’s fentanyl trafficking-related tariffs imposed on Canada, Mexico, and China (referred to by the Federal Circuit as “Trafficking Tariffs”), and the broad reciprocal tariffs announced on April 2, 2025 (referred to by the Federal Circuit as “Reciprocal Tariffs”).[1] The Federal Circuit’s opinion held that President Trump exceeded his authority under the International Emergency Economic Powers Act of 1977, 50 U.S.C. 1701, et seq. (“IEEPA”) in imposing the challenged Trafficking Tariffs and Reciprocal Tariffs. In a concurrent order, the Federal Circuit stayed the effects of its opinion until October 14, 2025, while the U.S. government appeals the ruling to the U.S. Supreme Court.Continue Reading U.S. Court of Appeals for the Federal Circuit Rules Against Trump’s 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.

The Trump administration issued a series of executive orders in late July and early August 2025, implementing substantial tariff increases on imports from numerous countries.  These developments represent an escalation from the initial reciprocal tariff framework established in April 2025 (discussed here), with new measures targeting specific countries for distinct policy reasons.  The comprehensive nature of these orders, affecting approximately 70 countries with reciprocal tariff rates ranging from 10% to 41%, alongside varying country-specific tariffs reaching as high as 40% for Brazil, 35% for Canada, and 25% for India, likely will have a major impact on global supply chains and international commerce.Continue Reading President Trump Expands Global Reciprocal Tariffs and Imposes Additional Tariffs on Brazil, Canada, and India

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 April 2, 2025, President Trump issued an executive order imposing sweeping reciprocal tariffs pursuant to the International Emergency Economic Powers Act, 50 U.S.C. 1701, et seq. (“IEEPA”), after previously imposing tariffs on certain items of Mexican and Canadian origin, effective April 2, under IEEPA.[1]  On April 9, 2025, President Trump announced a 90-day pause on the imposition of reciprocal tariff rates above 10% for most countries to allow for trade deal negotiations.  On July 7, 2025, President Trump signed an Executive Order extending the pause on the imposition of reciprocal tariff rates above 10% for most countries to August 1, 2025, if trade negotiations are not completed by that date. Continue Reading President Trump Announces Plans to Impose Modified Reciprocal Tariffs and New Tariffs on Canada and Mexico on August 1

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 May 23, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”), titled “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons.”  Effective immediately, GL 25 suspends nearly all OFAC sanctions on Syria, in line with President Trump’s prior announcement that he intended to lift sanctions on Syria following the ouster of former Syrian President Bashar al-Assad and the establishment of a new government under Syrian President Ahmed al-Sharaa.Continue Reading U.S. Government Suspends Economic Sanctions on Syria; EU and UK Take Similar Actions

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 May 28, 2025, the U.S. Court of International Trade (“CIT”) issued a decision holding that President Trump exceeded his authority under the International Emergency Economic Powers Act of 1977, 50 U.S.C. 1701, et seq. (“IEEPA”) in imposing fentanyl trafficking-related tariffs on Canada, Mexico, and China (referred to by the CIT as “Trafficking Tariffs”), and the broad reciprocal tariffs announced on April 2, 2025 (referred to by the CIT as “Worldwide and Retaliatory Tariffs”).[1]  In a Per Curium opinion, the three-judge panel granted summary judgment to a group of private plaintiffs and state attorneys general who had challenged the Trump administration tariffs imposed under IEEPA, vacated the Executive Orders imposing the tariffs, and enjoined collection of the tariffs.[2]  On May 29, 2025, the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) temporarily stayed the CIT’s order, keeping the relevant tariffs in effect while the Federal Circuit considers the case. Continue Reading U.S. Court of International Trade Strikes Down Trump’s IEEPA Tariffs