Following the Trump Administration’s removal of tariffs on products of India for “buying Russian oil” in February, the Office of Foreign Assets Control (“OFAC”) has issued a temporary general license to authorize transactions that are “ordinarily incident and necessary to the sale, delivery, or offloading of” Russian crude oil and petroleum products to companies in India. General License 133 authorizes certain transactions involving the sale, delivery or offloading of Russian crude oil or petroleum products…
On March 6, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continued its trend of selectively easing the Venezuela sanctions by (1) issuing General License No. 51 (“GL 51”), the first general license (“GL”) beyond the energy sector, and (2) publishing six new Frequently Asked Questions (“FAQs”) addressing the scope of several of the previously issued energy-related GLs. In parallel, Venezuela has begun reforming its mining sector. Background Since late…
On March 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an updated FAQ 1238, providing guidance on whether OFAC would approve license applications authorizing the resale of Venezuelan‑origin oil for use in Cuba when consistent with the terms and conditions of Venezuela General License (“GL”) 46A (authorizing US entities to export, sell, deliver, etc. Venezuelan-origin oil). The FAQ is relevant for companies assessing potential transactions involving Venezuelan oil…
On February 24, 2026, the US Departments of the Treasury and State announced coordinated sanctions targeting a Russia‑based cyber exploit broker network for the theft and resale of US trade secret cyber tools. These sanctions mark the first ever enforcement action under the Protecting American Intellectual Property Act (“PAIPA”) and reflect an expanded US sanctions approach to cyber‑enabled intellectual property theft. Our prior blog post on the enactment of the PAIPA is available here. Treasury…