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…
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…
On November 14, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended two general licenses and issued two new general licenses (“GLs”)authorizing limited transactions involving Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) and entities in which they respectively own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively “Rosneft and Lukoil Entities”). Rosneft and Lukoil…
On October 21, 2025, the US Department of Commerce’s International Trade Administration (“ITA”) announced the implementation of the July 23, 2025 Executive Order (“EO”) Promoting the Export of the American AI Technology Stack (the “American AI Exports Program”). Following our earlier post addressing the White House’s AI Action Plan and the EO, this update focuses on the implementation of the EO and the ITA’s request for public feedback. As a reminder, the EO directs the Secretary…