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On November 14, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended two general licenses and issued two new general licenses (“GLs”)authorizing limited transactions involving Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) and entities in which they respectively own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively “Rosneft and Lukoil Entities”). Rosneft and Lukoil…

Baker McKenzie’s Global Import Blog published this post on the new trade agreement framework between Switzerland, Liechtenstein, and the United States. Under the framework, the United States will reduce these tariffs to 15%, aligning Switzerland and Liechtenstein with the treatment given to the European Union in exchange for various concessions and commitments made by Switzerland and Liechtenstein. The agreement will also enhance enforcement of trade sanctions and US export controls through closer coordination. In May…

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. …

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…