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
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
On January 29, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 46, authorizing “established U.S. entit[ies]” to lift, purchase, sell, and engage in...more
Following the removal of Venezuelan President Nicolás Maduro on January 3, 2026, the Trump administration has taken actions to expand Venezuela-related oil trade and investment opportunities, primarily for U.S. companies....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
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
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
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
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
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 the wake of Nicolás Maduro’s capture and transfer to the United States for prosecution on drug‑trafficking–related charges, senior U.S. officials have made clear that Venezuela‑related sanctions will remain in place for...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
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 U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the immediate imposition of full blocking sanctions pursuant to Executive Order (“E.O.”) 14024 against Russian oil...more
On August 28, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule relaxing export controls on Syria in response to the June 30, 2025 Executive Order (EO) 14312 “Providing for the...more
President Trump continued his flurry of sanctions actions with the recent revocation of the Syrian sanctions program. On June 30, 2025, President Donald Trump issued Executive Order (“EO”) 14312 “Providing for the Revocation...more
On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria in line with President Trump’s May 13, 2025...more
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on May 23, 2025, announced a significant relaxation of the comprehensive economic sanctions imposed on Syria through the issuance of General...more
President Trump announced plans to relax sanctions against Syria during his recent trip to the Middle East, where he visited with the country’s President, Ahmed al-Sharaa. ...more