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
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
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
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
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
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
U.S. sanctions policy is facing a complicated year as officials navigate shifting geopolitical pressures, evolving strategies and potential legal constraints. U.S. policymakers must strike the right balance between providing...more
I. U.S. SANCTIONS - U.S. Is Prepared to Issue New Russia Sanctions if Putin Rejects Ukraine Peace Deal: According to Bloomberg and Reuters, on December 17 the United States was reported to be preparing an additional round...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
I. U.S. SANCTIONS - U.S. Department of the Treasury Imposes $4.7 Million Penalty on Real Estate Investor for Dealing in Russian Blocked Property: On November 24, the U.S. Department of the Treasury’s Office of Foreign...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
Hughes Hubbard’s “Sanctions in a Snap” is intended to provide a clear and concise summary of recent developments from the Office of Foreign Assets Control (OFAC). We hope you find it helpful in assessing U.S. economic...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
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 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 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