On June 22, 2026, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a new general license (Iran General License X or “GL X”) as the first step in implementing the US-Iran Memorandum of Understanding (“MOU”) to end recent hostilities in the Middle East. The MOU has not been formally or officially published by US Government agencies such as the State or Treasury Departments but its text has widely been reported and confirmed…
On April 14, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two new general licenses (“GLs”) — GL 56 and GL 57, which further ease longstanding US sanctions targeting Venezuela. OFAC also issued a new Frequently Asked Question (“FAQ”) to clarify the scope of the reporting requirements included in several Venezuela-related GLs. These GLs address certain gaps in the previous sanctions framework and removal of certain restrictions by broadening the…
On February 24, 2026, the US Departments of the Treasury and State announced coordinated sanctions targeting a Russia‑based cyber exploit broker network for the theft and resale of US trade secret cyber tools. These sanctions mark the first ever enforcement action under the Protecting American Intellectual Property Act (“PAIPA”) and reflect an expanded US sanctions approach to cyber‑enabled intellectual property theft. Our prior blog post on the enactment of the PAIPA is available here. Treasury…
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…