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…
As summarized in our recent blog post, in response to recent threat of tariffs over the Greenland issue, the EU considered possible responses, including tariffs and triggering of the so-called Anti‑Coercion Instrument (“ACI”). Although these threats appear to have subsided for now, given trade volatility, usage of the ACI remains a live possibility and we wanted to provide a brief overview on the ACI and what companies can do to prepare in the event the…
After publishing a draft implementing decree (Atto del Governo n. 317) (see our previous blog post here), Italy has now approved final legislation (Legislative Decree No. 211 of 30 December 2025) implementing Directive (EU) 2024/1226 which enter into force on 24 January 2026, significantly changing the criminal enforcement landscape in relation to EU sanctions violations. Legislative Decree No. 211/2025 increases criminal liability risks, particularly in respect of EU sanctions compliance, for companies (under Legislative Decree…
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…