On September 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the expiration of the national emergency declared in Executive Order 14046 of September 17, 2021, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia” (“EO 14046”), and removed persons designated under that order from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Department of State published…
On August 20, 2026, the White House released the National Security Science and Technology Strategy (“NSSTS”), which establishes the Trump administration’s framework for maintaining US technological leadership and protecting critical and emerging technologies. The NSSTS is organized around four pillars: (1) focusing techno-strategic competition, (2) building technological resilience, (3) accelerating innovation, and (4) protecting national security science and technology. For sanctions, export controls, investment screening, and data security practitioners, Pillar 4(Protect National Security S&T) is…
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…