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
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 Trump administration issued a general license (GL) significantly relaxing the patchwork of restrictions on Syria, long a jurisdiction subject to comprehensive sanctions. This regulatory action followed a...more
Less than two weeks after President Donald Trump announced that his administration would lift U.S. sanctions on Syria, the U.S. Departments of the Treasury and State took significant first steps to provide the anticipated...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
General License 25 effectively suspends OFAC sanctions targeting Syria. Stringent US export control restrictions on exports and reexports to Syria remain....more
The dynamic pace of early policymaking by the new U.S. administration has continued into the spring of 2025, including in the context of sanctions on Venezuela. While Venezuela is not, and has not been, subject to...more
On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more
The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more
President Donald Trump announced on Feb. 26, 2025, that he was reversing the authorization granted to Chevron Corp. and its subsidiaries (Chevron) by the Biden Administration as a concession aimed at promoting free elections...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has implemented new sanctions affecting China pursuant to Executive Order (“E.O.”) 13959, one of the Trump Administration’s final actions. The...more
The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more
INTRODUCTION - The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently adopted measures substantially impacting Huawei-affiliated companies and their non-U.S. supply chains. Earlier this year, on...more
The U.S. government is expanding international trade restraints against Huawei Technologies Co. Ltd. (“Huawei”) and its affiliates in an effort to further restrict Huawei’s access to U.S. technologies.....more
On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued four new frequently asked questions (“FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions...more
The Trump Administration announced a more restrictive policy towards Cuba in a presidential memo issued in June 2017. Since then, the Administration has implemented initiatives that have narrowed or revoked authorized trading...more
On January 10, 2020, President Trump issued a new Executive Order that imposes the latest in a series of economic sanctions on Iran. Individuals and entities violating these and other sanctions on Iran can face significant...more
The U.S. Department of the Treasury on Oct. 21, 2019, renewed for three months a license granted to several U.S. oil companies so that they may continue operating in the country until Jan. 22, 2020. Chevron is the only...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced on Monday, November 18, 2019 the issuance of a new 90-day extension which will allow U.S. companies to continue doing business with Huawei...more
On October 21, 2019, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) imposing new sanctions on Cuba for human rights abuses and for its support of...more
The Situation: In response to events in Syria and in the face of strong Congressional pressure to act, President Trump introduced sanctions targeting Turkey. The Result: Although the President indicated that a ceasefire...more
In light of Turkey’s military intervention in northeast Syria, President Donald Trump issued, on October 14, 2019, Executive Order 13894 (EO 13894), “Blocking Property and Suspending Entry of Certain Persons Contributing to...more
On 14 October, President Donald Trump issued Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (EO). ...more
• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more