In an April 2, 2026 Proclamation, the Trump administration made significant changes to the implementation of the existing tariffs on steel, copper, and aluminum products and derivative articles under Section 232 of the Trade Expansion Act (“Section 232”). Since
On March 18, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 52 (GL 52). The license broadly authorizes established U.S. entities to engage in transactions with Petróleos de Venezuela, S.A. (PdVSA)—including oil
On January 29, 2026, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published its response to the consultation on “Improving civil enforcement processes for financial sanctions” (“Consultation Response”), confirming that OFSI intends to proceed with all proposals consulted on in
When some energy executives and their lawyers hear “investment protection” they think arbitration. They picture a panel in some neutral city, elaborate briefs and a damages award to be executed on some asset somewhere. In “An Integrated Approach to
On March 5, news outlets reported that the U.S. government is drafting new export control regulations for AI chips. A copy of the draft regulations is not publicly available. According to reports, the draft regulations would cover most high-end
Following its March 11 announcement of a Section 301 investigation focused on structural excess capacity, on March 12 the Office of the U.S. Trade Representative (USTR) initiated new investigations into 60 of the United States’ largest trading partners, examining
On March 11, the U.S. Trade Representative (USTR) announced the initiation of a series of Section 301 investigations under the Trade Act of 1974 into “structural excess capacity and production in manufacturing sectors.” The investigations target the following countries: China,
In recent weeks, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has greatly expanded the scope of authorized activities and transactions that U.S. persons may undertake regarding energy projects in Venezuela. The expanded authorizations align with the wider
On February 20, 2026, the U.S. Supreme Court issued a 6–3 decision (in Learning Resources v. Trump) holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs.
Continue reading →
On February 6, 2026, the U.S. Department of the Treasury (Treasury) issued a Request for Information (RFI) seeking public input on CFIUS Known Investor Program (KIP). The RFI signals Treasury’s intent to formalize and begin implementation of the KIP announced
