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Daily Compliance News: October 28, 2025, The Sleeper Issue Edition
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Episode 385 -- Five Strategies to Mitigate a New Risk Environment
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Key Takeaways: U.S. entities can now trade in Venezuelan oil without violating the Venezuela Sanctions Regulations. The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued a general license...more
The maritime shipping sector has become a key target of sanctions policymakers and enforcement agencies in the U.S., European Union and United Kingdom as government authorities in these jurisdictions seek to advance national...more
The Trump Administration has issued two new General Licenses (GLs) authorizing limited engagement in Venezuela’s oil trading sector. More licenses are anticipated in the coming days or weeks, affecting upstream and downstream...more
In the first relaxation of sanctions broadly prohibiting dealings with the Government of Venezuela, the Office of Foreign Assets Control (OFAC) issued General License 46 (the GL) on January 29, 2026, authorizing petroleum...more
How did you begin your career in the maritime industry, and what early experiences shaped your professional path? I started in the maritime industry in the early 1990s, right out of law school, as a staff attorney and...more
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued two general licenses to provide limited sanctions relief for Venezuela's oil sector after the Venezuelan National Assembly passed...more
Subject to conditions and exceptions, General License (GL) 46 authorizes—without any time limitation—all transactions that are ordinarily incident and necessary to the lifting, exportation, reexportation, sale, resale,...more
Since the day President Trump arrived at the White House, international trade policy has been at the top of his agenda, starting with the release of the “America First Trade Policy Memo,” which he released on the first day of...more
On 26 January 2026, the Office of Financial Sanctions Implementation (“OFSI”) provided its clearest guidance yet on the baseline level of due diligence it expects businesses to undertake when assessing sanctions risks. ...more
Has BRICS finally produced an alternative to the “petrodollar” after twenty years? And does it live up to the hype? Depending on where you look online, key details are being left out. So, let’s slow down and review what’s...more
Highlights from January 2026 include OFAC authorizations for certain downstream activities involving Venezuelan oil, negotiations for the eventual acquisition of Lukoil’s international assets and a counternarcotics...more
On January 29, 2026, the White House issued a new Executive Order, “Addressing Threats to the United States by the Government of Cuba” (the “Executive Order”), declaring a national emergency with respect to Cuba and...more
You may be a trading house with stakes in battery supply chains that cross continents, a commodities trader with worldwide investments and trading relationships, a mining company or investor with African assets, or have one...more
On January 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Venezuela‑related General License 46 (“GL 46”), marking the most significant easing of U.S. restrictions on the...more
Hours after the US military strike that ousted Venezuelan President Nicolas Maduro, President Trump announced that, “very large US oil companies, the biggest anywhere in the world” would “go in, spend billions of dollars, fix...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. RUSSIA SANCTIONS - UK Government updates one entry on the UK Sanctions list under the Russia regime...more
On January 29, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new Venezuela-related General License (No. 46), authorizing established US companies to engage in a broad range of...more
On Thursday, January 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new general license, General License NO. 46 (the License), “Authorizing Certain Activities Involving...more
In the month since the U.S. took custody of Venezuelan President, Nicolas Maduro, the U.S. oil industry has been buzzing with rumors and speculation on what new opportunities may lie just south of the Caribbean. Venezuela is...more
HM Treasury (HMT) has published a consultation response and blog on proposed reforms to the UK Office of Financial Sanctions Implementation's (OFSI) civil enforcement processes. The reforms aim to increase efficiency in...more
After weeks of anticipation, the Office of Foreign Assets Control is authorizing certain transactions involving Venezuelan-origin oil by “established US entities.” Likely not the broad sanctions relief the Venezuelan...more
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 46, “Authorizing Certain Activities Involving Venezuelan-Origin Oil” (General License), on January 29, 2026, permitting U.S....more
The UK Office of Financial Sanctions Implementation (OFSI) has published a blog confirming that it is working closely with UK law enforcement and regulatory partners to combat the abuse of cryptoassets and associated money...more
I. US SANCTIONS - Ukraine-Russia Peace Talks End without Agreement: According to Reuters, on January 24, Ukraine and Russia talks, brokered by the U.S., ended without a deal but with more talks expected the following...more
Trump administration authorizes transactions involving Venezuelan oil sector, but subject to detailed conditions to align with U.S. policy objectives. Companies seeking to do business with Venezuela should confirm that their...more