On December 15, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued Belarus General License 13 (“GL 13”), “Authorizing Transactions Involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, and Belaruskali OAO.” GL 13 authorizes all transactions involving the following entities that are otherwise prohibited by the Belarus Sanctions Regulations (“BSR”): GL 13 does not authorize the unblocking of any blocked property or any transactions involving any other blocked persons…
The US Department of State has issued a final rule amending the International Traffic in Arms Regulations (“ITAR”) at 22 CFR § 126.1 to remove the embargo on defense trade with Cambodia, following its announcement effective October 26, 2025 that it would review ITAR license applications for Cambodia on a case-by-case basis (see here and here). Cambodia had been subject to a US arms embargo since December 2021, as discussed in our previous blog post. …
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…