On February 3, 2026, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule removing Cambodia from the list of U.S. arms-embargoed countries—Country Group D:5—within the Export Administration Regulations (“EAR”). This actions follows the White House’s October 2025 decision to lift the U.S. arms embargo on Cambodia, and aligns with the
OFAC Issues General License Authorizing Certain Oil Activities in Venezuela
On January 29, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil.” The general license authorizes all transactions prohibited by the Venezuela Sanctions Regulations, 31 C.F.R part 591, including those involving the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA)
President Trump Imposes Additional Tariff on Countries That Sell Oil to Cuba
On January 29, 2026, President Donald Trump issued Executive Order 14380 to impose an additional ad valorem duty on goods from countries that directly or indirectly sell or otherwise provide oil—that is, crude oil or petroleum products—to Cuba. Although the executive order, which took effect on January 30, 2026, appears broad in scope, it clarifies
OFAC Continues to Extend Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On February 2, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5U, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 20, 2026,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
President Trump Announces New 25% Section 232 Tariff on Narrow Category of Semiconductors Critical to AI
On January 14, 2026, President Donald Trump issued Proclamation 11002, announcing that, effective January 15, 2026, the United States is levying a 25% tariff on “a very narrow category of semiconductors” critical to the artificial intelligence (AI) sector, unless those semiconductors are imported “to support the buildout of the United States supply chain.” The
No Section 232 Tariff Now on Processed Critical Minerals and Their Derivative Products
On January 14, 2026, President Donald Trump issued Proclamation 11001, concluding that processed critical minerals and their derivative products (PCMDPs) would not be subject now to an additional tariff under Section 232 of the Trade Expansion Act of 1962. Section 232 authorizes the president to adjust duties on goods imported in quantities or under
OFAC Again Extends Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On January 6, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended Russia-related General License (GL) 13 by issuing a revised GL 13P, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import duties
CBP to Issue All Refunds Electronically Starting February 6, 2026
On January 2, 2026, U.S. Customs and Border Protection (“CBP”), an agency within the U.S. Department of Homeland Security, published an interim final rule announcing it will move to an all-electronic refund system beginning February 6, 2026. As a result, the agency will no longer issue paper checks for refunds—including tariff refunds—absent a waiver approved
Importers of Record Flood CIT with IEEPA Tariff Refund Complaints
- Hundreds of new cases have been filed at the U.S. Court of International Trade (“CIT”) since the November 5, 2025 oral arguments at the U.S. Supreme Court (“SCOTUS”) in the appeal challenging the legality of the International Emergency Economic Powers Act (“IEEPA”) as the statutory authority to impose tariffs and seeking to preserve
USTR Announces Section 301 Tariffs on Nicaragua
On December 10, 2025, the Office of the United States Trade Representative (USTR) issued a Federal Register notice announcing actions under Section 301 of the Trade Act of 1974 to address Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and the dismantling of the rule