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)
Francesca M.S. Guerrero
Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.
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…
United States and El Salvador Sign Agreement on Reciprocal Trade
On January 29, 2026, the Office of the U.S. Trade Representative (USTR) announced that the United States and El Salvador have signed the U.S.-El Salvador Agreement on Reciprocal Trade (Agreement). According to Ambassador Jamieson Greer, the USTR: “Today’s signing of the first Agreement on Reciprocal Trade in the Western Hemisphere will further strengthen markets for…
United States and Guatemala Sign Agreement on Reciprocal Trade
On January 30, 2026, the Office of the U.S. Trade Representative (USTR) announced that the United States and Guatemala have signed the United States–Guatemala Agreement on Reciprocal Trade (Agreement). According to Ambassador Jamieson Greer, the USTR: “Today’s signing of another Agreement on Reciprocal Trade in the Western Hemisphere addresses trade barriers facing American workers and…
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…
United States and Taiwan Sign Agreement on Trade & Investment
On January 15, 2026, the United States and Taiwan agreed to a trade deal to establish “a strategic economic partnership … to decisively strengthen U.S. domestic semiconductor supply chains and secure America’s technological and industrial leadership.” While the text and full terms of the trade deal were not released, the Department of Commerce released a…
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…
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
President Trump Delays Section 232 Tariff Increase on Wood Furniture, Cabinets and Vanities
On December 31, 2025, President Donald Trump issued a proclamation announcing that he was delaying an increase in the duty rates for imports of upholstered furniture, kitchen cabinets, and vanities. Referencing “productive negotiations of agreements with multiple countries to address the threatened impairment of the national security with respect to imports of wood products,” President…
