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…
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…
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…
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 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,…
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 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. Chief Justice Roberts, writing for the majority, stated that if Congress intended to grant tariff authority…
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. The comment period is open for any…
Following the removal of Venezuelan President Nicolás Maduro on January 3, 2026, the Trump administration has taken actions to expand Venezuela-related oil trade and investment opportunities, primarily for U.S. companies. While the broader framework of U.S. sanctions for Venezuela’s regime remains in place, the U.S. Department of Treasury’s Office of…
In recent weeks, the Trump administration has taken several actions to implement its policy toward the export of advanced AI commodities to China. These include the Department of Commerce (Commerce) Bureau of Industry’s (BIS) final rule implementing a case-by-case review policy (changed from a presumption of denial policy) of exports…