On June 25, 2026, the UK published a new Open General Export Licence (the “New OGEL”), permitting the export of a wide range of dual-use items to various low-risk destinations. The New OGEL consolidates existing open licensing routes for certain dual-use exports and adds coverage for several new destinations, reducing the need for individual license applications for eligible exports.
Today, Regulation (EU) 2026/1386 (“FDI Regulation”), the EU’s new regulation revising the Foreign Direct Investment (FDI) screening framework, was published in the Official Journal following its adoption by the Council of the EU earlier this month. The FDI Regulation will enter into force 20 days after its publication, and will begin to apply 18 months thereafter, by which time Member States must ensure compliance with its requirements. The FDI Regulation will replace Regulation (EU) 2019/452, which has governed EU-level coordination of FDI reviews since 2020.
On June 22, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Iran-related General License X (GL X), authorizing otherwise-prohibited transactions ordinarily incident and necessary to the production, sale, delivery or offloading of crude oil, petrochemical products or petroleum products of Iranian origin. The authorization remains in effect through 12:01 a.m. EDT on August 21, 2026.
On May 1, 2026, President Trump issued Executive Order (EO) 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” authorizing sanctions against persons determined to be operating in a variety of sectors of the Cuban economy, with significant impacts to non-U.S. financial institutions who process related transactions. In practical terms, the order gives the U.S. government a new designation authority for foreign persons connected to specified Cuba-related activity and creates a secondary sanctions risk for foreign financial institutions that facilitate significant transactions involving persons blocked under the order.
The UK has introduced a new “sanctions end‑use controls” licensing trigger aimed at restricting diversion of certain trade-sanctioned goods and related technology via non‑sanctioned third countries. The controls apply across all regimes with trade sanctions where restrictions extend beyond arms embargoes, and operates alongside, but separately from, export control “catch‑all” end‑use rules relating to military and weapons of mass destruction end-use concerns. The controls apply to goods, and technology related to the export of goods, that are subject to the relevant trade sanctions regime but are not otherwise subject to export controls.
On April 23, 2026, the EU adopted its 20th sanctions package targeting Russia and Belarus in connection with the Russia-Ukraine conflict.
The latest package significantly expands the EU’s restrictive measures across the energy, finance and crypto, trade, services and maritime and transport sectors, with a core focus on anti-circumvention and energy measures. A summary of the key updates follows.
In an April 2, 2026 Proclamation, the Trump administration made significant changes to the implementation of the existing tariffs on steel, copper, and aluminum products and derivative articles under Section 232 of the Trade Expansion Act (“Section 232”). Since June 2025, Section 232 duties on mixed metal and non-metal products have been calculated based on the value of the steel, aluminum or copper content within the article. This instruction to separate out metal versus non-metal content resulted in considerable confusion regarding the methodology to determine the price paid by the importer for steel or aluminum consistent with the principles of 19 U.S.C. 1401a.
On March 18, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 52 (GL 52). The license broadly authorizes established U.S. entities to engage in transactions with Petróleos de Venezuela, S.A. (PdVSA)—including oil trading, new investment and the formation of joint ventures—while maintaining substantial restrictions on counterparties, payment structures, and debt- or equity-related transactions. OFAC simultaneously issued FAQ 1245 and FAQ 1246, which clarify the scope of authorized activities, confirm key exclusions, and address the license’s implications for high-profile enforcement matters.
On January 29, 2026, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published its response to the consultation on “Improving civil enforcement processes for financial sanctions” (“Consultation Response”), confirming that OFSI intends to proceed with all proposals consulted on in July 2025, subject to limited legislative dependencies. The majority of the changes have now been operationalized through updated guidance published on February 9, 2026.
When some energy executives and their lawyers hear “investment protection” they think arbitration. They picture a panel in some neutral city, elaborate briefs and a damages award to be executed on some asset somewhere. In “An Integrated Approach to International Energy Investment Protection,” we observe that protection doesn’t begin when the dispute starts. It begins long before the investment is even made.
