On March 31, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Sanctions Advisory to raise awareness of potential sanctions risks arising from sham transactions used to evade sanctions. The advisory presents examples and lists red flags that may indicate the presence of a sham transaction. While it is explanatory only and does not have the force of law, the advisory follows several recent enforcement actions involving blocked persons…
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…
Introduction The current geopolitical environment in Venezuela is continuing to evolve. While the legal and business environment has improved, businesses operating or looking to operate there are still continuing to analyze risks. At the same time, tangible steps are being taken to better position Venezuelan industries for foreign investment, including a recent partial reform of Venezuela’s Organic Hydrocarbons Law. On the US front, sanctions remain in place against the Venezuelan government and Specially Designated Nationals…
On January 29, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 46 (“GL 46”) authorizing transactions related to the exportation/reexportation of Venezuelan oil prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. Our blog posts about recent developments under US sanctions targeting Venezuela can be found here, here, here, and here. Subject to certain conditions, GL 46 authorizes all transactions involving the Government of Venezuela…