International Trade & National Security Law Firm

Since the U.S. military’s abrupt capture of Venezuelan President Nicolás Maduro on January 3, 2026, the Trump administration has authorized many activities involving Venezuela that were previously prohibited under U.S. sanctions. Specifically, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued numerous General Licenses (GLs) affecting the country’s energy and minerals sectors and allowing for greater participation by U.S. persons.

On March 13, 2026, the Trump administration issued an executive order (EO), "Ensuring Truthful Advertising of Products Claiming to Be Made in America," which seeks to increase enforcement related to the accuracy of products labeled “Made in America” or "Made in the USA." The EO reaffirms consumers’ right to accurate product information in the digital marketplace.

The Bureau of Industry and Security (“BIS”) has opened 2026 with several significant administrative enforcement actions that underscore how aggressively the agency is policing export controls involving China, Entity List parties, semiconductor-related trade, and even highly technical compliance issues such as de minimis calculations and recordkeeping. Among the most notable matters announced so far this year are the Exyte Management GmbH, Applied Materials, and Teledyne FLIR settlements. Taken together, these cases show that BIS continues to focus not only on obvious diversion or evasion risks, but also on flawed legal interpretations, compliance-process failures, and gaps in post-license controls.

On April 2, 2026, the one-year anniversary of President Trump’s “Liberation Day” tariff announcement¹, the administration published two new presidential actions related to tariffs under Section 232 of the Trade Expansion Act of 1962. The first of these actions is a Presidential Proclamation that re-shapes previously implemented Section 232 tariff measures on imports of steel, aluminum, and copper products (“the Metals Proclamation”). In addition to the Metals Proclamation, the President issued a separate Executive Order implementing a 100% tariff on imports of patented pharmaceutical products and ingredients.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued Russia-related General License 133 (“GL 133”) on March 5, 2026 and General License 134 (“GL 134”) on March 12, 2026, authorizing limited transactions involving the sale, delivery, or offloading of Russian-origin crude oil and petroleum products that were already loaded aboard vessels by specified cutoff dates. GL 133 covers cargoes loaded on or before 12:01 a.m. EST on March 5, 2026, and GL 134 covers cargoes loaded on or before 12:01 a.m. EDT on March 12, 2026.

On March 12, 2026, the Office of the U.S. Trade Representative (“USTR”) initiated new investigations pursuant to Section 301 of the Trade Act of 1974 into the acts, policies, and practices of the economies listed in Annex A of its Federal Register Notice (“FRN”) relating to the failure to impose and effectively enforce a prohibition on the importation of goods produced wholly or in part with forced labor. The USTR states that these failures may be unreasonable or discriminatory and may burden or restrict U.S. commerce, thereby potentially warranting action under Section 301. The announcement of the forced labor investigations follows the USTR’s March 11, 2026 announcement of investigations into structural excess capacity and production in manufacturing sectors in 16 foreign economies.