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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

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

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

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

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

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 Sector

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.

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

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

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