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
Russia
OFAC Again Extends Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On September 29, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13O, “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…
President Trump Signs Law Requiring Annual Report on Export Licenses Involving Certain Entities
On August 19, 2025, President Donald Trump signed the “Maintaining American Superiority by Improving Export Control Transparency Act” (H.R. 1316), amending the Export Control Reform Act of 2018 to enhance transparency from the agency responsible for administering the Export Administration Regulations (EAR). Specifically, the amendment requires the Department of Commerce’s Bureau of Industry…
President Trump Announces Additional Tariffs on India for Russian Federation Oil Purchases
On August 6, 2025, President Donald Trump issued an Executive Order (EO) stating that it “is necessary and appropriate to impose an additional ad valorem duty on imports of articles of India, which is directly or indirectly importing Russian Federation oil.” As a result, beginning on August 27, 2025, an additional tariff of 25% will…
OFAC Continues to Extend Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On July 8, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13N, “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…
OFAC Amends Russia General License 55 Relating to the Sakhalin-2 Oil and Gas Project
On June 18, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 55D, “Authorizing Certain Services Related to Sakhalin-2.” This general license authorizes certain services that would otherwise be prohibited under OFAC’s Russia sanctions program related to Sakhalin-2 involving the maritime transport of crude oil originating from…
Section 232 Aluminum and Steel Tariffs Increased to 50% Except for UK; Significant Changes Made to Calculating and “Stacking” of Tariffs
President Donald Trump issued a Proclamation on June 3, 2025 increasing the previously imposed Section 232 tariffs on aluminum and steel products and their derivatives from 25% to 50%. These increased tariffs were effective June 4, 2025. The proclamation excluded products of the United Kingdom which stay at 25% until July 9, 2025.
U.S. Customs…
OFAC Again Continues to Extend Authorizations Under Russia General License 13
On April 7, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13M, “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…
President Trump Issues America First Investment Policy Memorandum Impacting FDI into the U.S. and Outbound Investment to Foreign Adversaries
On February 21, 2025, President Trump issued the America First Investment Policy Memorandum (“Memorandum”). The Memorandum aims to promote foreign direct investment (FDI) from “allies and partners” while restricting inbound investment from and outbound investment to “foreign adversaries,” such as China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and the Nicolás Maduro…
President Trump Announces New Tariffs on Imported Steel and Aluminum Articles and Derivatives from All Countries with No Exemptions or Exclusions
UPDATE: On February 14, the Federal Register released the formal Presidential Proclamations on the steel and aluminum tariffs that include the annexes for each Proclamation that detail the list of in-scope steel or aluminum articles and derivatives that will be subject to the 25% ad valorem tariffs. The links in this post have been updated…