The validity period of the general license authorizing certain payments with the Russian Central Bank and others has been extended. Specifically, on January 6, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued General License 13P (“GL 13P”), “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” extending the validity period until 12:01 a.m. Eastern time on April 9, 2026. GL 13P authorizes US Persons to engage…
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…