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…
On March 13, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) expanded the scope of three existing general licenses (“GLs”) and issued two amended Frequently Asked Questions (“FAQs”) related to certain imports and activities involving electricity and petrochemicals in Venezuela. On March 18, 2026, OFAC also issued a new GL authorizing transactions with Venezuelan state-owned Petróleos de Venezuela, S.A. (“PdVSA”), subject to certain conditions, and issued two new FAQs related thereto.…
On February 13, 2026, as part of an ongoing series of sanctions-easing measures following the capture of Venezuelan President Nicolás Maduro in January 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two general licenses authorizing certain activities related to operations in Venezuela’s oil and gas sector. As further detailed below, OFAC General License No. 49 (“GL 49”) authorizes US persons to negotiate and enter into contingent contracts for certain…
On February 3, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 47 (“GL 47”) authorizing transactions related to the exportation/reexportation of US-origin diluents (i.e., diluting agents used to reduce viscosity of fluids, e.g., for use in crude oil pipelines) to Venezuela that would otherwise be prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. You can find our blog posts about developments under US…