On March 6, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continued its trend of selectively easing the Venezuela sanctions by (1) issuing General License No. 51 (“GL 51”), the first general license (“GL”) beyond the energy sector, and (2) publishing six new Frequently Asked Questions (“FAQs”) addressing the scope of several of the previously issued energy-related GLs. In parallel, Venezuela has begun reforming its mining sector. Background Since late…
On February 24, 2026, the US Departments of the Treasury and State announced coordinated sanctions targeting a Russia‑based cyber exploit broker network for the theft and resale of US trade secret cyber tools. These sanctions mark the first ever enforcement action under the Protecting American Intellectual Property Act (“PAIPA”) and reflect an expanded US sanctions approach to cyber‑enabled intellectual property theft. Our prior blog post on the enactment of the PAIPA is available here. Treasury…
Introduction The current geopolitical environment in Venezuela is continuing to evolve. While the legal and business environment has improved, businesses operating or looking to operate there are still continuing to analyze risks. At the same time, tangible steps are being taken to better position Venezuelan industries for foreign investment, including a recent partial reform of Venezuela’s Organic Hydrocarbons Law. On the US front, sanctions remain in place against the Venezuelan government and Specially Designated Nationals…
This week, the US relaxation of sanctions against Venezuela’s oil and gas sector entered a new phase with the publication of a general license authorizing a broad range of upstream oil and gas activities. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has been busy with Venezuela-related actions over the past few weeks. We previously blogged about general licenses authorizing oil trading and downstream activities (blog post here) and the…