On April 17, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia‑related General License 134B (“GL 134B”), extending the duration of General License 134A, which authorized certain transactions involving crude oil and petroleum products of Russian Federation origin that had already been loaded onto vessels. As with GL 134A, GL 134B authorizes transactions that are ordinarily incident and necessary to the sale, delivery, or offloading of Russian‑origin crude oil…
On April 14, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License Nos. 128C and 130A (“GL 128C” and “GL 130A”, respectively), further extending prior authorizations relating to certain transactions involving certain subsidiaries of Public Joint‑Stock Company Oil Company Lukoil (“Lukoil”). As with earlier iterations, these general licenses permit limited, time‑bound transactions to proceed notwithstanding the designation of Lukoil and certain affiliates as Specially Designated Nationals (“SDNs”). We…
On March 27, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) significantly expanded the scope of authorizations available for the Venezuelan minerals sector by amending an existing general license and issuing two new general licenses covering a broad range of mining operations in Venezuela involving the Government of Venezuela (“GOV”) and CVG Compania General de Mineria de Venezuela CA (“Minerven”), or any entity in which Minerven owns, directly or indirectly,…
On March 30, 2026, the US Department of Justice (“DOJ”) National Security Division (“NSD”) announced updated guidance clarifying how companies should report voluntary self-disclosures (“VSDs”) of potential criminal violations of US national security laws, including export controls and sanctions, under DOJ’s new department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”). The announcement reflects NSD’s transition away from its prior division-specific VSD policy in favor of the department-wide CEP released on March 10, 2026 (covered in…