On June 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a suite of updated Venezuela-related general licenses (“GLs”) that slightly ease certain licensing conditions related to governing law and dispute resolution clauses in contracts involving the Government of Venezuela, Petróleos de Venezuela S.A. (“PdVSA”), CVG Compañía General de Minería de Venezuela CA (“Minerven”), or any entity in which PdVSA or Minerven owns, directly or indirectly, a 50% or…
On May 31, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance clarifying that a license continues to be required under the Export Administration Regulations (“EAR”) for exports of advanced computing items to entities located in any country, if those entities are headquartered in Country Group D:5 (including China) or Macau, or have “an ultimate parent company” headquartered in Country Group D:5 or Macau. The BIS Guidance was prompted by…
The UK’s Office of Financial Sanctions Implementation (OFSI) has introduced The Sanctions (EU Exit) (Miscellaneous Amendment) Regulations 2026 (the “Regulations”), which came into force on 13 May 2026. The Regulations create new powers for the UK government to impose licensing requirements on exports where it considers there is a high risk of the goods or related technology being diverted to a sanctioned person or destination. For further details about the Sanctions End-Use Controls and other…
On March 31, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Sanctions Advisory to raise awareness of potential sanctions risks arising from sham transactions used to evade sanctions. The advisory presents examples and lists red flags that may indicate the presence of a sham transaction. While it is explanatory only and does not have the force of law, the advisory follows several recent enforcement actions involving blocked persons…