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Alexandra Kumar (US)

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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…

On 11 February 2025, we saw the first public multi-jurisdictional coordinated sanctions action under the Trump Administration when the United States, Australia, and the UK announced joint sanctions against alleged key members of a Russian cybercrime supply chain. This action was taken by the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), Australia’s Department of Foreign Affairs and Trade, and the UK Foreign Commonwealth and Development Office (“UK FCDO”).  See the US…