On February 3, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 47 generally authorizing the export, sale, and supply of U.S.-origin diluents to Venezuela. The issuance of GL 47 comes less
Cleary Foreign Investment and International Trade Watch
The Cleary Foreign Investment and International Trade Watch, published by Cleary Gottlieb Steen & Hamilton LLP, focuses on legal developments and regulatory updates related to foreign investment, international trade, and economic sanctions. The blog covers topics such as foreign direct investment screening, export controls, sanctions enforcement, international trade litigation, and government reviews of cross-border transactions. It also addresses issues involving U.S. and EU trade policies, Committee on Foreign Investment in the United States (CFIUS) reviews, and compliance with export administration regulations. The blog provides analysis of significant court rulings, regulatory changes, and policy trends affecting multinational corporations and investors engaged in global commerce.
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OFAC Eases Venezuelan Oil Sanctions Following Maduro Apprehension
Update: On February 10, 2026, OFAC issued GL 46A, which amended GL 46 to clarify that payments for local taxes, permits, or fees are excluded from the requirement to be deposited into Foreign Government Deposit Funds.
On January 29, 2026…
Trade Controls, Foreign Investment and National Security: New Regimes and Continuing Changes for 2026
The following is part of our annual publication Selected Issues for Boards of Directors in 2026. Explore all topics or download the PDF.
In 2026, boards of directors will continue to navigate a shifting U.S. regulatory environment shaped by…
Italy Introduces New Criminal Offenses and Corporate Liability for Breaches of EU Sanctions
Legislative Decree No. 211/2025 (the “Sanctions Decree”), effective as of January 24, implements EU Directive 2024/1226 (the “Directive”) on violations of EU restrictive measures (the “EU Sanctions”) and introduces new criminal offenses, thereby significantly reshaping the applicable sanctions framework. Importantly,…
New Guidance Issued and Changes Underway for U.S. Outbound Investment Regime as 2026 NDAA Defense Bill Introduces Outbound Investment, Sanctions, and Biotech Updates
On December 18, 2025, President Trump signed the 2026 National Defense Authorization Act (“NDAA”), a sweeping defense spending bill that brings a number of changes to the U.S. outbound investment security program, U.S. economic sanctions, and biotechnology restrictions relating to…
Navigating Venezuela Sanctions: Legal Considerations and Anticipated Developments
After the apprehension of Nicolás Maduro on January 3, 2026, the White House has actively advocated for Venezuelan market access for U.S. oil companies. Although a regulatory framework under which such investment can occur remains uncertain, any such arrangement will…
President Trump Issues Order Requiring Hiefo Corporation to Divest Ownership of Digital Chip and Wafer-related Assets
For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.
On January 2, 2026, President Trump issued an order (the “Order”) prohibiting HieFo…
OFAC General Licenses Open Door for Lukoil Divestment and Other Limited Activities Following Rosneft and Lukoil Sanctions
For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.
On October 22, 2025, the U.S. Department of the Treasury, Office of Foreign…
EU FDI: State of the Union (2025)
On October 14, 2025, the European Commission (“Commission”) published its fifth annual report on the screening of foreign direct investments (“FDI”) into the Union (the “Report”). Notable findings:…
BIS Significantly Expands Application of Export Control Restricted Party Lists with New “Affiliates Rule”
On November 1, 2025, following U.S.-China trade discussions, the White House announced that it would suspend implementation of the Affiliates Rule for one year. Effective November 10, 2025, BIS imposed a one-year suspension of the interim final rule, expiring November…