On June 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a suite of updated Venezuela-related general licenses (“GLs”) that slightly ease certain licensing conditions related to governing law and dispute resolution clauses in contracts involving the Government of Venezuela, Petróleos de Venezuela S.A. (“PdVSA”), CVG Compañía General de Minería de Venezuela CA (“Minerven”), or any entity in which PdVSA or Minerven owns, directly or indirectly, a 50% or…
On April 28, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took a series of Iran-related actions as part of the Administration’s “Economic Fury” campaign of exerting maximum pressure against Iran. Specifically, OFAC (1) issued an alert warning of the sanctions risks of dealing with Chinese “teapot” oil refineries that process Iranian crude oil and (2) published FAQ 1249, which warns that “toll” payments to the Government of Iran (“GoI”)…
On February 13, 2026, as part of an ongoing series of sanctions-easing measures following the capture of Venezuelan President Nicolás Maduro in January 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two general licenses authorizing certain activities related to operations in Venezuela’s oil and gas sector. As further detailed below, OFAC General License No. 49 (“GL 49”) authorizes US persons to negotiate and enter into contingent contracts for certain…
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…