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
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, 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 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 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 this weekly update, we summarise the most notable updates in the UK sanctions world....more
I. Introduction - The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) is responsible for enforcing the Export Administration Regulations (EAR) — the rules that control the export, reexport, and even...more
In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus....more
In this weekly update, we summarise the most notable updates in the UK sanctions world. ...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
UPDATE - On November 10, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its final rule staying the new Affiliates Rule, which will make any unlisted foreign entity owned, directly or...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. RUSSIA SANCTIONS - OFSI amends General Licence relating to payments made between third parties and sanctioned financial...more
I. U.S. SANCTIONS - U.S. Department of the Treasury Announces Balkans-Related Designation Removals: On October 29, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the deletion of...more
Each quarter, I send my clients a trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. In addition to a variety of ad hoc...more
Key Takeaways In a significant—but anticipated—change to the U.S. export control regime, the Bureau of Industry and Security (BIS) released an interim final rule amending the Export Administration Regulations (EAR) by...more
On September 30, 2025, the Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the Export Administration Regulations (EAR) to expand end-user controls and address diversion risks associated...more
On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a long-anticipated interim final rule (IFR) amending the Export Administration Regulations (EAR) to extend Entity List and...more
On September 29, 2025, the United States significantly expanded the reach of export controls. The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") released an interim final rule, that applies Entity List...more
The U.S. Commerce Department has expanded export control sanctions by extending them to 50% or more-owned affiliates of restricted parties. This development has a particularly significant impact on China-related export...more
The Affiliates Rule automatically extends the US Department of Commerce’s Entity List and Military End-User (MEU) List to entities owned 50% or more by entities on either list. On September 29, 2025, the US Department of...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