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…
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…
In less than two weeks, we have seen Syria go from one of the most heavily sanctioned countries on the planet to a country well on the road to establishing normal trade relations with the Western world. The latest flurry of developments started on May 13, 2025, when President Trump caught much of the world by surprise when he said in a speech in Riyadh: “I will be ordering the cessation of sanctions against Syria…
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…