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…
On March 20, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Iran-related General License U (“GL U”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026.” One day earlier, on March 19, 2026, OFAC issued Russia-related General License 134A (“GL 134A”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on…
On March 13, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) expanded the scope of three existing general licenses (“GLs”) and issued two amended Frequently Asked Questions (“FAQs”) related to certain imports and activities involving electricity and petrochemicals in Venezuela. On March 18, 2026, OFAC also issued a new GL authorizing transactions with Venezuelan state-owned Petróleos de Venezuela, S.A. (“PdVSA”), subject to certain conditions, and issued two new FAQs related thereto.…