On December 18, 2025, President Trump signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2026 (P.L. 119-60). A must-pass piece of legislation that funds Department of Defense (“DoD”) operations on an annual basis, the NDAA is a frequent vehicle for trade-related provisions and legislative changes affecting DoD acquisition policies with direct implications for government contractors. The NDAA includes a number of provisions relating to US sanctions, investment security, and supply chain…
We are providing a brief update on the latest developments in the US sanctions targeting Venezuela: To date, the US Department of the Treasury’s Office of Foreign Assets Control has not published any regulatory changes, general licenses, or licensing policies on its website that change current US sanctions. We continue to closely monitor Venezuela sanctions developments and will provide updates on this blog. Please reach out to the authors or any member of our US…
We are closely monitoring the developing situation in Venezuela and are focused on everyone’s safety. Since we are already receiving questions about what this means for US sanctions targeting Venezuela, we wanted to confirm that as of now, there have not been any changes to the US sanctions regime. We will share any updates on this blog both as to US sanctions changes or local Venezuelan reactions, in coordination with our local team. If you…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) – 55E and 115C – that authorize certain transactions related to crude oil originating from the Sakhalin-2 project and certain transactions with Russian entities related to civil nuclear energy. OFAC also updated several frequently asked questions (“FAQs”). Amended GLs 55E and 115C The amended GL 55E, “Authorizing Certain Services Related to Sakhalin-2,” authorizes, through 12:01 am…