The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
Our International Trade team comments on additional restrictions on trade with Cuba
In early January 2026, U.S. forces captured Nicolás Maduro and brought him into U.S. custody on drug charges. In subsequent public statements, the Trump administration announced an intent to encourage private-sector...more
As Venezuela’s political environment continues to shift, the Trump Administration has authorized US persons to undertake a variety of activities involving Venezuelan-origin oil that had previously been prohibited. On...more
Last week Bracewell discussed the Trump administration’s initial easing of restrictions on Venezuelan oil with General License (GL) 46, which opened the door for US companies to revive the long-inaccessible industry. However,...more
In the span of a few days, Venezuela has moved to open its oil sector to private capital while U.S. regulators have set out a sanctions pathway for trading in Venezuelan‑origin crude. Venezuela’s amendment to its hydrocarbons...more
Subject to certain conditions and exceptions, General License (GL) 47 authorizes—without any time limitation—all transactions that are ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply,...more
On January 29, the Office of Foreign Assets Control (OFAC) took its first steps to loosen the sanctions against Venezuela following the capture and removal of Nicolás Maduro at the beginning of January....more
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 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
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
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
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
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
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
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
On January 29, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 46 (“GL 46”), authorizing certain activities for U.S. companies seeking to engage in transactions...more
In October 2025, the US, UK, and EU implemented coordinated sanctions against Russia’s two largest oil companies: Public Joint Stock Company “Rosneft Oil Company” (Rosneft) and Public Joint-Stock Company “Oil Company Lukoil”...more
Last month Bracewell highlighted the latest sets of Russia-related sanctions imposed by the United Kingdom, European Union and United States, explaining the potential far-reaching implications of what are the strongest...more
On October 22, 2025, President Trump imposed new sanctions targeting Russia’s oil and gas sector in response to a “lack of serious commitment to a peace process to end the war in Ukraine.” This is the first major escalation...more
In August, Bracewell discussed the evolving impact of UK and EU sanctions on corporations in the energy and infrastructure sectors. In a significant escalation, in October, the UK, US and EU changed the landscape again by...more
In a notable sign of enhanced U.S. pressure on Russia concerning the ongoing war in Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions on October 22,...more
On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sweeping new sanctions targeting Russia’s energy sector, citing the Kremlin’s continued refusal to engage in...more
On October 22, 2025, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury designated OJSC Rosneft (Rosneft) and Lukoil OAO (Lukoil) on the List of Specially Designated Nationals and Blocked Persons...more
On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued full blocking sanctions on Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”)...more
On October 22, 2025 the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Open Joint Stock Company Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil), placing both companies, including all...more