USA Law and Practice Contributed by: Bruce G. Paulsen, Brian Maloney and Hannah Thibideau, Seward & Kissel LLP
blocked property and Annual Reports of Blocked Property pursuant to § 501.603 (d), and reports of rejected transactions under § 501.604 (d), among other changes seeking to streamline reporting requirements and require filings to be made via email rather than mail or facsimile transmission. • OFAC’s 23 May 2025 release of General License (GL) 25 in the Syria sanctions programme. As stated by OFAC’s fact sheet, this licence “effec - tively” lifts sanctions on Syria, together with a concurrent waiver issued by the US Department of State under the Caesar Syria Civilian Protection Act. GL 25 authorises transactions that were previ - ously prohibited under the Syria Sanctions Regula - tions, including, generally speaking, the provision of services to people and companies in Syria; new investment in Syria; transactions with the new gov - ernment of Syria and with certain blocked persons listed in the Annex to GL 25; and the importation of and dealing in petroleum and petroleum products from Syria. • Passage of the COINS Act in December 2025, as part of the FY 2026 NDAA. The COINS Act broad - ens many aspects of the restrictions currently in place as a result of the Outbound Investment Security Program, including expanding the covered technologies to include high performance/super - computing and hypersonic systems, while also widening the geographic scope to include Cuba, Iran, North Korea and Venezuela. This expansion of the Outbound Program will likely lead to more enforcement efforts. • Related provisions of the NDAA also threaten to expand sanctions against companies identified as a Chinese Military Industrial Complex (CMIC) com - pany on OFAC’s “Non-SDN Chinese Military-Indus - trial Complex Companies List”. Provisions in the NDAA lay the groundwork for a notable expansion of the CMIC programme, which will involve broad - ening the investment restrictions on the companies on that list. • Passage of several general licences regarding Venezuela. These licences permit specific oil, gas, petrochemical, and electricity sector activities that had previously been prohibited for US persons. These authorisations include exports and imports of Venezuelan-origin crude oil and refined prod - ucts, sales of US-origin diluents, and the provision
of the goods, services and technology necessary to operate energy and petrochemical facilities. Separate licences are focused on the minerals sector, authorising the sales and supply of US- origin goods and services for mining operations by previously established US entities in Venezuela. Other licences permit financial services to certain Venezuelan banks and authorise legal, financial and consulting services related to potential debt restructuring or contingent investment negotia - tions. 3.2 Future Developments Given that decisions concerning sanctions are often driven primarily by US national security and foreign policy considerations, there is continued turbulence with respect to China, Russia, Iran, Venezuela and other notable sanctions regimes. In 2026, a number of national security initiatives are being rapidly advanced by different elements of the US government, most of which are focused on China and other “countries of concern”, including Venezuela, Russia and Iran. This includes programmes such as the Outbound Investment Security Program, imple - mented by the Department of the Treasury, and the recently enacted COINS Act, which broadens the programme – as well as sector-specific legislative and regulatory initiatives, in industries such as the US maritime, logistics and shipbuilding sectors, as well as the semiconductor, artificial intelligence, and quantum computing sectors. Additionally, at the time of writing, the United States and Iran are undergoing a transition period in the wake of the conflict and the signing of the memorandum of understanding between the two countries in June 2026. As of that date, the countries agreed to Iran reo - pening the Strait of Hormuz, a USD300 billion plan for Iran’s “reconstruction”, and the United States’ termi - nation of sanctions on Iran. At the time of writing, the agreement called for an end to hostilities and started a 60-day negotiating clock to reach a final deal on the future of Iran’s nuclear programme.
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