The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended Venezuela General License (“GL”) 41 to wind-down, rather than authorize, certain transactions related to the operation and management of Chevron Corporation’s joint venture with Petróleos de Venezuela, S.A. (“PdVSA”) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (“PdVSA Related Entities”). OFAC issued the original GL 41 on November 26, 2022, which authorized certain transactions…
On February 4, 2025, the White House issued a National Security Presidential Memorandum (“NSP Memo”) outlining President Trump’s intention to impose maximum economic and political pressure on the government of the Islamic Republic of Iran (“Iran”), including by enhancing enforcement efforts and modifying or rescinding any existing general license or guidance that provides Iran with “any degree of economic or financial relief.” In addition, on February 6, 2025, the US Treasury Department’s Office of Foreign…
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“IFR”) on January 15, 2025, that introduces new export controls on artificial intelligence (“AI”) model weights and advanced computing integrated circuits (“IC”) in the Export Administration Regulations (“EAR”). The new controls are intended to simultaneously restrict exports to certain countries while establishing a framework to support the diffusion and supply of certain AI model weights and advanced computing ICs…
On December 13, 2024, the US Treasury Department (“Treasury”) issued 35 new questions and answers (“FAQs”) providing guidance on the November 17, 2024 final rule outlining the US government’s Outbound Investment Security Program (“Outbound Investment Rules”). These Outbound Investment Rules, which become effective January 2, 2025, implement a targeted outbound investment compliance regime called for by Executive Order (EO) 14105 issued by President Biden on August 9, 2023. The full list of published FAQs can…