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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.

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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.

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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.

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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.

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On March 5, news outlets reported that the U.S. government is drafting new export control regulations for AI chips. A copy of the draft regulations is not publicly available. According to reports, the draft regulations would cover most high-end processors sold by U.S. companies, positioning the U.S. as a gatekeeper for the global AI industry.

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Following its March 11 announcement of a Section 301 investigation focused on structural excess capacity, on March 12 the Office of the U.S. Trade Representative (USTR) initiated new investigations into 60 of the United States’ largest trading partners, examining whether those countries have failed to impose and effectively enforce bans on the importation of goods produced with forced labor.

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On March 11, the U.S. Trade Representative (USTR) announced the initiation of a series of Section 301 investigations under the Trade Act of 1974 into “structural excess capacity and production in manufacturing sectors.” The investigations target the following countries: China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan and India. The Administration has identified these as countries that “appear to exhibit structural excess capacity in various manufacturing sectors, such as through large or persistent trade surpluses or underutilized or unused capacity.”

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In recent weeks, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has greatly expanded the scope of authorized activities and transactions that U.S. persons may undertake regarding energy projects in Venezuela. The expanded authorizations align with the wider U.S. strategy to relax certain sanctions after President Maduro’s removal on January 3, 2026, signaling a significant shift toward broader commercial engagement with Venezuela’s energy industry.

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On February 20, 2026, the U.S. Supreme Court issued a 6–3 decision (in Learning Resources v. Trump) holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs.

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On February 6, 2026, the U.S. Department of the Treasury (Treasury) issued a Request for Information (RFI) seeking public input on CFIUS Known Investor Program (KIP). The RFI signals Treasury’s intent to formalize and begin implementation of the KIP announced in May 2025.

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