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The Committee on Foreign Investment in the United States (CFIUS or the Committee) recently published its 2025 Annual Report, which provides information regarding transactions reviewed by CFIUS during 2025.[1] Key takeaways from the 2025 Annual Report are below.

Continue Reading CFIUS Releases 2025 Annual Report: Key Takeaways

On July 28, 2026, the Federal Communications Commission (FCC) added foreign-produced “advanced robotic devices” and “power inverters” to the FCC’s Covered List, effectively barring covered equipment from receiving the FCC equipment authorizations necessary for most electronic devices to be imported, marketed, or sold in the United States.[1] Separately, the FY2027 National Defense Authorization Act (NDAA), passed by the U.S. House of Representatives on July 22, 2026, includes the “Guarding Unregulated AI Robots from Deployment Act” (GUARD Act), a proposed bill that would prohibit the U.S. Department of Defense (DoD) from procuring humanoid robotic systems produced by foreign adversaries, including China.[2] The FCC’s Covered List update, in particular, represents a significant expansion of U.S. national security restrictions on mobile robotics and power inverters (which have applications in the power grid, among other uses). 

Continue Reading FCC Adds Foreign-Produced Robotics, Power Inverters to Covered List; House NDAA Targets Foreign Adversary Humanoid Robots

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 Canada

On June 18, 2026, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued General License (GL) 59, authorizing the provision of goods, technology, software, or services relating to aircraft of Venezuela’s state-owned airline, Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A. (Conviasa). Separately, OFAC recently amended seven existing Venezuela-related GLs to ease the governing law and dispute resolution requirements applicable to contracts entered into under those licenses. In addition, on June 25, 2026, OFAC issued GL 60, authorizing transactions related to earthquake relief efforts in Venezuela until October 2026. Together, these actions reflect OFAC’s continued easing of Venezuela sanctions by expanding the scope of permissible aviation-related activities, reducing barriers to participation in authorized transactions, and facilitating humanitarian relief efforts.

Continue Reading OFAC Continues Venezuela Sanctions Relief with Authorizations for Aircraft Safety, Earthquake Relief, and Easing of General License Governing Law Requirements

Over the last several months, Venezuela’s interim government has moved swiftly to reopen the country’s oil sector to private investment, amending the Organic Hydrocarbons Law and enacting implementing regulations just last week. There is little doubt that the reformed law includes many positive changes to encourage new investment: it ends PDVSA’s decades-long monopoly on primary oil activities, lowers the state’s minimum ownership stake in joint ventures, and formalizes a new contractual framework (CPPs) expected to be the primary vehicle for new investment. The regulations include a more streamlined fiscal regime, including a royalty ceiling of 30%, and a simplified integrated hydrocarbons tax capped at 15%, replacing the prior multi-layered tax structure.

Continue Reading Venezuela’s Oil Reform Efforts: New Opportunities, Unanswered Questions – U.S. Investor Perspective

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 8, 2026, President Trump informed Congress of his administration’s intent to rescind Syria’s designation as a State Sponsor of Terrorism (SST), giving Congress the requisite 45-day pre-notification period. The rescission of Syria’s SST designation is one of the final steps in the rollback of financial and other trade restrictions against Syria following President Trump’s June 30, 2025 Executive Order revoking executive orders that imposed sanctions and export restrictions on Syria, and directing the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), U.S. Department of State, and U.S. Department of Commerce to ease trade and finance restrictions on Syria. Syria’s designation as an SST is set to expire following a 45-day mandatory congressional review period, absent formal opposition from Congress.

Continue Reading U.S. Government Removes Syria From List of State Sponsors of Terrorism

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 June 8, 2026, the U.S. Department of Defense (DOD) published an updated list of “Chinese military companies” operating in the United States as required by Section 1260H of the National Defense Authorization Act (NDAA) for Fiscal Year 2021 (the 1260H List), which was last published on January 7, 2025.[1] The updated list adds dozens of entities, including some of the largest publicly traded companies in China, spanning the automotive and electric vehicle, e-commerce, artificial intelligence, robotics, semiconductors, solar technology, and biotechnology sectors. These additions continue the trend of a steady expansion of the 1260H List from traditional defense and state-owned enterprises.[2] The updated 1260H List now identifies nearly 200 entities, including a number of subsidiaries listed alongside their parent companies. Notable new additions include BYD, NIO, Alibaba, Baidu, Unitree, TP-Link, and WuXi AppTec.[3] The update also removed 10 entities from the prior list.

Continue Reading Department of Defense Adds Major Technology, Automotive, and Biotechnology Firms to 1260H Chinese Military Companies List

On May 7, 2026, the U.S. Department of Defense (DoD) published a proposed rule (the Proposed Rule) that would, for the first time, require companies performing unclassified work for DoD to disclose whether they are subject to foreign ownership, control, or influence (FOCI), a screening process that historically has been required primarily for contractors with access to classified information.[1] DoD estimates that the Proposed Rule would affect an estimated 37,740 contractors and subcontractors. The Proposed Rule would implement statutory mandates under the National Defense Authorization Acts (NDAAs) for Fiscal Years 2020 and 2021, as well as elements of a 2024 DoD policy instruction on FOCI risk mitigation.[2] Comments on the Proposed Rule are due on July 6, 2026.

Continue Reading DoD Proposes Expanding Foreign Ownership Screening Beyond Classified Contracts

The Cleary Gottlieb CFIUS team submitted a comment on March 18, 2026 in response to the Request for Information (RFI) issued by the U.S. Department of the Treasury (Treasury), as chair of the Committee on Foreign Investment in the United States (CFIUS), regarding a new Known Investor Program and ways to make CFIUS’s foreign investment review process more efficient. The comment is available here. Drawing on our experience advising foreign investors and U.S. businesses across a wide range of investor profiles, transaction structures, and industry sectors, we offer practical, experience-based observations aimed at assisting CFIUS in developing the Known Investor Program into a workable, broadly available program that fosters foreign direct investment into the United States while protecting national security. Our comments are offered in the spirit of the RFI’s stated goals of increasing efficiencies in the CFIUS process to facilitate investment from allies and partners while preserving the rigor of the national security review.[1]

Continue Reading Cleary Gottlieb Comments on CFIUS Known Investor Program and Process Streamlining

On March 26, 2026, the U.S. Department of the Treasury (Treasury), Office of Foreign Assets Control (OFAC) rescinded Directive 1 under Executive Order (E.O.) 14038, which had prohibited transactions in Belarusian sovereign debt with maturity of longer than 90 days issued since December 2, 2021. In parallel with the rescission of Directive 1, OFAC issued General License (GL) 14, authorizing transactions involving the Belarussian Bank of Development and Reconstruction Belinvestbank Joint Stock Company (Belinvestbank), among other entities. OFAC also removed several significant Belarusian potash sector entities from the Specially Designated Nationals and Blocked Persons List (SDN List).

Continue Reading OFAC Lifts Belarus Sovereign Debt Ban, Eases Sanctions on Belarusian Potash Sector