On August 21, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued General License (GL) 61 and GL 62, respectively authorizing the provision of U.S. goods, technology, software, and services in support of telecommunications in Venezuela, and the negotiation of and entry into contingent contracts for new investment in the telecommunications sector of Venezuela. In particular, the GLs authorize transactions involving the Government of Venezuela (GoV), Comisión Nacional de Telecomunicaciones (CONATEL), Venezuela’s state-owned telecommunications agency, and Compania Anonima Nacional Telefonos de Venezuela (CANTV), Venezuela’s state-owned telephone and internet service provider, which would otherwise be prohibited. [1]
Continue Reading OFAC Issues General Licenses Authorizing Activity in Venezuelan Telecommunications SectorU.S. Trade
U.S. Government Announces Operation Economic Outcast Targeting Iran
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 August 24, 2026, the U.S. government announced “Operation Economic Outcast,” initiating a “whole-of-government campaign” centered on additional economic sanctions against Iran. Acting at the direction of President Trump, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC): (i) issued five new sectoral sanctions determinations under Executive Order (E.O.) 13902 targeting Iran’s digital assets, technology, gold, aviation, and shipping sectors; (ii) issued new guidance on the sanctions risks associated with Iranian demands related to shipping in the Strait of Hormuz; (iii) suspended several general licenses (GLs) that previously had authorized certain remittance payments and cultural and academic exchanges with Iran; and (iv) designated nearly 60 entities, individuals, and vessels across multiple jurisdictions on the list of Specially Designated Nationals and Blocked Persons (SDN List).[1] The Treasury Department’s announcement also warned of consequences for third countries that continue to do business with Iran, stating that the U.S. government has engaged counterparts in foreign governments to provide timelines for terminating existing business with Iran or face punitive measures from the U.S. government.[2]
Continue Reading U.S. Government Announces Operation Economic Outcast Targeting IranTrump Administration Imposes New Section 301 Tariffs on 60 Trading Partners, New Section 338 Tariffs on Canada
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 July 23, 2026, the Trump administration announced new tariffs (Forced Labor Tariffs) on goods from 60 economies, including the European Union (EU) and China, alleging these economies either failed to enforce forced labor prohibitions or failed to adopt a forced labor import prohibition. The new duties took effect on July 24, 2026, replacing the temporary 10% global tariff imposed by President Trump under Section 122 of the Trade Act of 1974 (Section 122 Tariffs), which expired on July 24, 2026. Section 122 Tariffs originally were imposed after the Supreme Court struck down the administration’s prior tariffs imposed under the International Emergency Economic Powers Act (IEEPA).[1] Although the Trump administration has stated that the Forced Labor Tariffs will apply to 99% of imports into the United States, the duties (ranging from 10 to 12.5%) have a number of exemptions and exclusions, including products subject to tariffs imposed under Section 232 of the Trade Expansion Act (Section 232 Tariffs).
Continue Reading Trump Administration Imposes New Section 301 Tariffs on 60 Trading Partners, New Section 338 Tariffs on CanadaU.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 TariffsOFAC 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 VenezuelaTrade 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 2026OFAC 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.
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 SanctionsU.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.
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 TariffsPresident 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.
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 IndiaPresident Trump Announces Plans to Impose Modified Reciprocal Tariffs and New Tariffs on Canada and Mexico on August 1
Posted in International Trade, U.S. Trade
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