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
Sanctions
OFAC 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 Sectors
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
OFAC Sanctions Rwanda Defence Force and Senior Officials in Connection with DRC Conflict
On March 2, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) imposed sanctions on the Rwanda Defence Force (“RDF”, the military of Rwanda) and four senior RDF officials pursuant to the Democratic Republic of the Congo Sanctions Regulations (“DRCSR”) (codified at 31 C.F.R. Part 547).[1] Concurrent with the designations, OFAC issued General License No. 1 (“GL 1”) authorizing the wind down of transactions involving the RDF through April 1, 2026.[2]Continue Reading OFAC Sanctions Rwanda Defence Force and Senior Officials in Connection with DRC Conflict
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
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
OFAC Eases Venezuelan Oil Sanctions Following Maduro Apprehension
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
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