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) 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 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 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…
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 March 24, 2025, President Donald Trump signed an Executive Order (EO) declaring that any country purchasing oil from Venezuela, “whether directly from Venezuela or indirectly through third parties,” will pay a 25% tariff on their exports to the United States. The EO tasks the Secretary of Commerce with determining whether a country buys Venezuelan…
On March 24, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41B extending the expiration date of Venezuela GL 41, which authorized certain transactions related to Chevron Corporation’s joint ventures in Venezuela. Previously, under GL 41A issued earlier this month, all transactions “ordinarily incident and…
On March 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5R, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 3, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
On March 4, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 41A within its Venezuela-Related Sanctions Program: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela.” The Biden Administration had issued the precursor to General License (GL) 41A, GL 41…
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…
On January 10, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and placed eight Venezuelan officials on the Specially Designated Nationals (SDN) List for “enabling Nicolas Maduro’s repression and subversion of democracy in Venezuela.” The individuals sanctioned include the president of Petroleos de Venezuela, S.A., (PdVSA), Venezuela’s state-owned oil company…
