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…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) —131A and 128B—affecting (i) contingent contract negotiations for acquisition of and maintaining/winding down transactions with certain Lukoil entities and (ii) retail transactions with ex-Russia Lukoil service stations. More information regarding each GL is below and our blog post regarding prior iterations of these GLs can be found here. Amended GL 131A On December 10, 2025, OFAC…
On November 10, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) formally suspended the implementation of the “Affiliates Rule” for one year, as published in the Federal Register (linked here) on November 12, 2025. This suspension follows high-level trade negotiations between the United States and China, culminating in reciprocal concessions announced in late October and early November as discussed on our blog here and here. Background on the Affiliates Rule Originally…
Following months of negotiations and feints, on November 1, 2025, the United States and China reached a trade and economic agreement during bilateral discussions held in the Republic of Korea. The agreement outlines a series of reciprocal measures intended to address trade flows and market access between the two countries. The negotiations had already yielded significant rapprochement between the two countries, including the one-year suspension, as of November 10, 2025, of the “Affiliates Rule,” which…