On April 8, 2026, the US Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) issued a joint proposed rule (“Proposed Rule”) to implement provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (“GENIUS Act”). The Proposed Rule implements the GENIUS Act’s anti-money laundering (“AML”) and sanctions compliance program requirements and encourages innovation in payment stablecoins while providing a regulatory regime to mitigate…
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…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) —131A and 128B—affecting (i) contingent contract negotiations for acquisition of and maintaining/winding down transactions with certain Lukoil entities and (ii) retail transactions with ex-Russia Lukoil service stations. More information regarding each GL is below and our blog post regarding prior iterations of these GLs can be found here. Amended GL 131A On December 10, 2025, OFAC…