On January 29, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 46 (“GL 46”) authorizing transactions related to the exportation/reexportation of Venezuelan oil prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. Our blog posts about recent developments under US sanctions targeting Venezuela can be found here, here, here, and here. Subject to certain conditions, GL 46 authorizes all transactions involving the Government of Venezuela…
Developments in Venezuela are raising new considerations for companies with operations in Venezuela and those that are considering business opportunities there, both in the energy sector and beyond. Finding the intersection of risk mitigation and opportunity requires understanding and balancing the legal, geopolitical and practical challenges that lie ahead. If you missed our first webinar on January 16, we’ve shared our key takeaways from the discussion here.
On January 12, 2026, the US House of Representatives passed the Remote Access Security Act (H.R. 2683), which would amend the Export Control Reform Act of 2018 (“ECRA”) to authorize the extension of existing export controls to the remote access of US goods, software, or technology, if a determination is made that “the use of the item could pose a serious risk to the national security or foreign policy of the United States.” The House…
On December 18, 2025, President Trump signed into law the Fiscal Year 2026 National Defense Authorization Act (“NDAA”) that contains in Title LXXXV a revised version of the previously introduced Comprehensive Outbound Investment National Security Act (“COINS Act”). The COINS Act codifies and expands the existing Outbound Investment Security Program (“OISP”) that restricts US outbound investment in certain sensitive technologies. The NDAA passed Congress with significant support reflecting bipartisan consensus to implement an outbound investment…