On Friday, January 9, 2026, US President Donald Trump issued an Executive Order (“EO”) to exempt Venezuelan oil revenues and funds derived from diluent sales held in US Treasury accounts/funds on behalf of the Government of Venezuela (defined in the EO as “Foreign Government Deposit Funds”) from attachment or other judicial process. The White House also issued a corresponding Fact Sheet summarizing the EO and outlining the Trump Administration’s related policy objectives. The EO states…
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 August 25, 2025, the US Department of Defense (“DoD”) issued a Final Rule amending the Defense Federal Acquisition Regulation Supplement (“DFARS”) to prohibit DoD contracting officers from awarding certain consulting services contracts to contractors where they or their subsidiaries or affiliates hold contracts and subcontracts that involve providing “consulting services” to “covered foreign entities” (“CFEs”) unless they implement a conflict-of-interest mitigation plan. The prohibition applies specifically to contracts assigned a North American Industry Classification…
On March 24, 2025, the White House issued Executive Order 14245 (“EO 14245”) to implement potential tariffs for countries importing Venezuelan oil as well as a Fact Sheet that summarizes EO 14245 at a high level. On the same date, the US Treasury Department’s Office of Foreign Assets Control issued General License (“GL”) No. 41B extending the wind down period of certain transactions related to Chevron Corporation joint ventures (“JVs”) in Venezuela. EO 14245 This…