On March 13, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) expanded the scope of three existing general licenses (“GLs”) and issued two amended Frequently Asked Questions (“FAQs”) related to certain imports and activities involving electricity and petrochemicals in Venezuela. On March 18, 2026, OFAC also issued a new GL authorizing transactions with Venezuelan state-owned Petróleos de Venezuela, S.A. (“PdVSA”), subject to certain conditions, and issued two new FAQs related thereto.…
On February 13, 2026, the US Treasury Department’s (“Treasury”) Financial Crimes Enforcement Network announced the launch of a new dedicated webpage for the confidential submission of whistleblower tips on fraud, money laundering, and sanctions violations. Based on the press release, The new initiative follows President Trump’s recent efforts to combat the government benefits fraud schemes in Minnesota. Treasury has encouraged whistleblowers to submit tips as soon as possible and to include specific, well-documented information to…
On December 18, 2025, President Trump signed into law the Fiscal Year 2026 National Defense Authorization Act (“NDAA”) that contains in Title LXXXV a revised version of the previously introduced Comprehensive Outbound Investment National Security Act (“COINS Act”). The COINS Act codifies and expands the existing Outbound Investment Security Program (“OISP”) that restricts US outbound investment in certain sensitive technologies. The NDAA passed Congress with significant support reflecting bipartisan consensus to implement an outbound investment…
The Office of Foreign Assets Control (“OFAC”) designated Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) on October 22, 2025, in response to the ongoing war in Ukraine. In announcing the designations under Executive Order (“EO”) 14024, Secretary of the Treasury Scott Bessent stated that the actions were taken to advance the administration’s goal of ending the war in Ukraine by targeting two of Russia’s largest oil…