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…
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…