On October 21, 2025, the US Department of Commerce’s International Trade Administration (“ITA”) announced the implementation of the July 23, 2025 Executive Order (“EO”) Promoting the Export of the American AI Technology Stack (the “American AI Exports Program”). Following our earlier post addressing the White House’s AI Action Plan and the EO, this update focuses on the implementation of the EO and the ITA’s request for public feedback. As a reminder, the EO directs the Secretary…
On June 30, 2025, the White House reissued National Security Presidential Memorandum-5 (“2025 NSPM-5”) focused on Cuba policy that it published in largely the same form in the first Trump Administration (see the “2017 NSPM-5”). As acknowledged in Section 4(a) of the reissued document, much of the contents of the 2025 NSPM-5 was already implemented in the first Trump Administration pursuant to the 2017 NSPM-5. Along with 2025 NSPM-5, the White House issued a related…
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 PetrĂłleos 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…