On 21 January 2026, the EU’s restrictions on the import of refined petroleum products deriving from Russian-origin crude oil entered into force. The restrictions, introduced as part of the EU’s 18th package of sanctions targeting Russia under Article 3ma of EU Regulation 833/2014 (as previously summarised in our blog post here), prohibit the direct or indirect purchase, import or transfer into the EU of refined petroleum products obtained from third countries that derive from Russian-origin…
On December 18, 2025, President Trump signed into law the Fiscal Year 2026 National Defense Authorization Act (“NDAA”) that contains in Title LXXXV a revised version of the previously introduced Comprehensive Outbound Investment National Security Act (“COINS Act”). The COINS Act codifies and expands the existing Outbound Investment Security Program (“OISP”) that restricts US outbound investment in certain sensitive technologies. The NDAA passed Congress with significant support reflecting bipartisan consensus to implement an outbound investment…
On Friday, January 9, 2026, US President Donald Trump issued an Executive Order (“EO”) to exempt Venezuelan oil revenues and funds derived from diluent sales held in US Treasury accounts/funds on behalf of the Government of Venezuela (defined in the EO as “Foreign Government Deposit Funds”) from attachment or other judicial process. The White House also issued a corresponding Fact Sheet summarizing the EO and outlining the Trump Administration’s related policy objectives. The EO states…
What should we expect in the world of sanctions, export controls, and national security in 2026? In what is sure to remain a dynamic environment, how can we look ahead and be prepared? We are excited to invite you to an event we are co-hosting with the Customs & International Trade Bar Association (CITBA) in our DC office and online. The details and registration link follow. Date: Monday, January 12 Time: 5:15 – 7:30 PM EDT Location: (Hybrid):…