On August 26, 2026, President Trump issued Executive Order 14420, “Declaring a National Emergency to Secure the United States Bulk-Power System” (“EO 14420”), which aims to prevent certain foreign actors from creating or exploiting vulnerabilities in foreign-produced equipment used in the US bulk-power system. EO 14420 builds on and significantly expands Executive Order 13920, “Securing the United States Bulk-Power System” (“EO 13920”), which the Trump administration issued in 2020 and formed the basis of an…
In brief On July 28, 2026, the Federal Communications Commission (FCC or “Commission”) added foreign-produced power inverters and advanced robotic devices to the Covered List. This placement bars new foreign-produced models from obtaining the equipment authorization required for lawful importation and marketing of radiofrequency devices unless the FCC grants Conditional Approval. This action effectuates two National Security Determinations (NSDs) that a White House-convened Executive Branch interagency body delivered to the FCC on July 27, 2026.1 Each NSD…
On July 1, 2026, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department imposed sanctions on several parties due to links to Brazil-based Primeiro Comando da Capital (i.e., First Capital Command, or “PCC”). This was the first round of sanctions against parties connected to PCC since the US Government’s actions in the spring designating PCC as both a Foreign Terrorist Organization (“FTO”) and a Specially Designated Global Terrorist (“SDGT”). We refer to…
Introduction The current geopolitical environment in Venezuela is continuing to evolve. While the legal and business environment has improved, businesses operating or looking to operate there are still continuing to analyze risks. At the same time, tangible steps are being taken to better position Venezuelan industries for foreign investment, including a recent partial reform of Venezuela’s Organic Hydrocarbons Law. On the US front, sanctions remain in place against the Venezuelan government and Specially Designated Nationals…