On June 8, 2026, the US Department of Defense (“DoD”) published an update to its list of “Chinese military companies” (“CMCs”) operating directly or indirectly in the United States (the “1260H List”), pursuant to Section 1260H of the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA 2021”). The updated list is available here. The DoD press release states that this update is part of the US government’s continuing effort to highlight and counter…
On March 13, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) expanded the scope of three existing general licenses (“GLs”) and issued two amended Frequently Asked Questions (“FAQs”) related to certain imports and activities involving electricity and petrochemicals in Venezuela. On March 18, 2026, OFAC also issued a new GL authorizing transactions with Venezuelan state-owned Petróleos de Venezuela, S.A. (“PdVSA”), subject to certain conditions, and issued two new FAQs related thereto.…
On February 3, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 47 (“GL 47”) authorizing transactions related to the exportation/reexportation of US-origin diluents (i.e., diluting agents used to reduce viscosity of fluids, e.g., for use in crude oil pipelines) to Venezuela that would otherwise be prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. You can find our blog posts about developments under US…
On May 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) initiated a rescission of the Biden Administration’s AI Diffusion Rule, which was issued on January 15, 2025 and had been set to take effect on May 15, 2025. The AI Diffusion Rule had introduced additional expansive and complex export controls on certain advanced computing integrated circuits (“IC”) and on model weights for certain advanced closed-weight artificial intelligence (“AI”) models. Our…