Timely news and analysis of the latest developments in international trade law
On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended two general licenses to continue authorizing limited transactions under previous sanctions involving Russia’s Lukoil operations.
Russia-related General License 128C, “Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia.” This amended general license extends until October 29…
On April 14, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses in the continuing relaxation of certain sanctions involving Venezuela. These new general licenses authorize certain commercial and banking transactions in the country.
Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government…
On March 12, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 134, “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026.” The general license authorizes transactions “that are ordinarily incident and necessary…
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)…
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…
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…
On November 10, 2025, the U.S. Department of State, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control, issued a Tri-Seal Advisory on sanctions and export controls relief for Syria.
The advisory provides that the United States no longer imposes comprehensive sanctions on Syria and that the…
On October 22, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed Russia’s two largest oil companies on its Specially Designated Nationals (SDN) List. This action was taken by the Treasury Department to “increase pressure on Russia’s energy sector and degrade the Kremlin’s ability to raise revenue for its war machine…
As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.
