Since August 21, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has made a series of changes to the Venezuela-related general licenses (“GLs”) issued under the Venezuela Sanctions Regulations, 31 CFR part 591 (“VSR”). OFAC removed the US governing-law condition from the GLs that included it and updated the associated Frequently Asked Questions (“FAQs”). It issued two new GLs, (General License No. 61 (“GL 61”), since replaced by GL 61A,…
On August 6, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a temporary final rule (the “Rule”) that restricts exports of black mass and tungsten waste and scrap without a license. Beginning August 27, 2026, US persons that sell black mass and tungsten waste and scrap must allocate 100 percent of their monthly sales to US persons, unless they first obtain an adjustment or exception from BIS. This Rule implements…
On 23 July 2026, the European Council adopted its 21st package of Russia sanctions as well as additional measures targeting Belarus. The package concentrates on sectors with the greatest impact on Russia’s war economy, including energy, shipping, gold, financial services (including crypto), trade, and the Russian military-industrial complex. Key elements include a full-year suspension of the oil price cap adjustment, a new tool allowing transaction bans on named refineries that process Russian crude (listing one…
On June 4, 2025, the U.S. House of Representatives passed the Ukraine Support Act (H.R. 2913) (the “Act”), a broad measure that would, if enacted, (1) impose new Russia-related sanctions, (2) codify and tighten existing U.S. export controls, (3) impose duties of at least 500% on Russian imports and taxation of blocked assets, and (4) authorize additional Ukraine-related security and reconstruction measures. The bill now moves to the Senate, where its prospects remain uncertain. If…