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Michael Amberg (UK)

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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…

On Friday, January 9, 2026, US President Donald Trump issued an Executive Order (“EO”) to exempt Venezuelan oil revenues and funds derived from diluent sales held in US Treasury accounts/funds on behalf of the Government of Venezuela (defined in the EO as “Foreign Government Deposit Funds”) from attachment or other judicial process. The White House also issued a corresponding Fact Sheet summarizing the EO and outlining the Trump Administration’s related policy objectives. The EO states…

On November 10, 2025, the US Department of the Treasury, US Department of State, and US Department of Commerce issued a Tri-Seal Advisory (see here) summarizing the current scope of US sanctions and export controls relief measures applicable to Syria. The document serves as a consolidated reference point for the actions taken so far to relax US sanctions and export controls for Syria, including those aimed at facilitating humanitarian assistance and early recovery efforts. The…

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…