On March 20, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Iran-related General License U (“GL U”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026.” One day earlier, on March 19, 2026, OFAC issued Russia-related General License 134A (“GL 134A”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on…
On March 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an updated FAQ 1238, providing guidance on whether OFAC would approve license applications authorizing the resale of Venezuelan‑origin oil for use in Cuba when consistent with the terms and conditions of Venezuela General License (“GL”) 46A (authorizing US entities to export, sell, deliver, etc. Venezuelan-origin oil). The FAQ is relevant for companies assessing potential transactions involving Venezuelan oil…
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule, effective January 15, 2026, revising the license review policy for exports from the United States of certain commercially available advanced computing semiconductors to end users in China and Macau—moving from a presumption of denial to case‑by‑case review under certain conditions. The case-by-case review policy is only available for exports meeting strict requirements, including various certifications as to sufficient supply…
After failing to pass in the previous Congress, a revised version of the “BIOSECURE Act” (“the Act”) was signed into law by President Trump on December 18, 2025, as Section 851 of the National Defense Authorization Act (“NDAA”) for Fiscal Year 2026 (P.L. 119-60). The new law will restrict US federal procurement and grants involving biotechnology products or services provided by “biotechnology companies of concern” (“BCC”). While amended and clarified in key areas, the Act…