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 January 2, 2026, President Trump issued an order (the “Order”) prohibiting HieFo Corporation (“HieFo”), a Delaware company, from maintaining ownership of digital chip and wafer-related assets (including a semiconductor manufacturing facility) that HieFo acquired from EMCORE Corporation (“EMCORE”). HieFo acquired the assets in April 2024 for $2.92 million, and the Committee on Foreign Investment in the United States (“CFIUS”) subsequently reviewed the transaction.

Continue Reading President Trump Issues Order Requiring Hiefo Corporation to Divest Ownership of Digital Chip and Wafer-related Assets

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

On October 14, 2025, the European Commission (“Commission”) published its fifth annual report on the screening of foreign direct investments (“FDI”) into the Union (the “Report”). Notable findings:

Continue Reading EU FDI: State of the Union (2025)

On November 1, 2025, following U.S.-China trade discussions, the White House announced that it would suspend implementation of the Affiliates Rule for one year.  Effective November 10, 2025, BIS imposed a one-year suspension of the interim final rule, expiring November 9, 2026.

On September 29, 2025, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a new interim final rule, Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities (the IFR) that, effective immediately, significantly expands the application of the Entity List and Military End-User List (MEU List) restrictions under the Export Administration Regulations (EAR) to foreign entities that are 50 percent or more owned by such listed entities (the Affiliates Rule).

Continue Reading BIS Significantly Expands Application of Export Control Restricted Party Lists with New “Affiliates Rule”

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

The Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) recently published its 2024 Annual Report, which provides information regarding transactions reviewed by CFIUS during 2024.[1] Key takeaways from the 2024 Annual Report are below.   

Continue Reading CFIUS Releases 2024 Annual Report: Key Takeaways

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 July 8, 2025, President Trump issued an order (the “Order”) requiring a Chinese company, Suirui Group Co., Ltd., and its Hong Kong subsidiary, Suirui International Co., Limited (collectively, “Suirui”), to divest its interest and rights in Jupiter Systems, LLC (“Jupiter”), a California-based company specializing in video processing technology.

Continue Reading President Trump Issues Order Requiring Chinese Company to Divest Interest in U.S. Video Processing Technology Company

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