On March 23, 2026, the Federal Communications Commission (FCC) updated its Covered List—a list of communications equipment and services deemed to pose an unacceptable risk to U.S. national security or the safety and security of U.S. persons—to include consumer-grade routers produced in a foreign country, absent an exemption granted by the U.S. Departments of War (DoW) or Homeland Security (DHS). This designation effectively prohibits the import of all consumer routers that are not produced in the United States.

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On March 18 and 19, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new Venezuela-related general licenses: General License No. 52 (GL 52), authorizing most previously prohibited transactions involving Petróleos de Venezuela, S.A. (PdVSA)  and General License No. 5V (GL 5V), authorizing further transactions related to the PdVSA 2020 8.5 Percent Bond issued on or after May 5, 2026.

Background: In 2018, OFAC imposed debt-related sanctions on PdVSA – Venezuela’s state-run oil company, which OFAC supplemented on January 28, 2019 by designating PdVSA on the List of Specially Designated Nationals and Blocked Persons (SDN List). Then, on August 5, 2019, OFAC’s imposition of asset-freezing sanctions on the Government of Venezuela, PdVSA’s parent entity, resulted in a third set of sanctions applying to PdVSA.

Change in Dynamic: Since January 2026, OFAC has issued a series of general licenses authorizing certain U.S. persons to conduct business with PdVSA, the Government of Venezuela, and other sanctioned Venezuelan persons. Yet, those general licenses focus exclusively on select activities for preidentified sectors. These new general licenses change that approach.  

New General License 52: GL 52 authorizes all transactions prohibited by Executive Order (E.O.) 13884 (the E.O. authorizing the imposition of asset-freezing sanctions on PdVSA) or E.O. 13850 (the E.O. authorizing the imposition of asset-freezing sanctions on the Government of Venezuela), if those transactions involve PdVSA, or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”). A follow-on FAQ (OFAC FAQ 1245) from OFAC explains that this authorization includes activities related to

  • the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;
  • the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
  • entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;
  • the formation of new joint ventures or other entities in Venezuela related to such activities; and
  • all transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing.

Conditions for GL 52: However, similar to the other recently issued general licenses, there are stringent conditions.

  • The authorized transactions must be conducted by an “established U.S. entity.”  For purposes of GL 52, the term “established U.S. entity” means any entity organized under the laws of the United States or any jurisdiction within the United States on or before January 29, 2025. 
  • Any contract with PdVSA or PdVSA entities must be governed by U.S. law and provide for dispute resolution in the United States.
  • Any monetary payment to a blocked person — other than local taxes, permits, or fees — must be directed into the Foreign Government Deposit Funds as specified in E.O. 14373 of January 9, 2026, or another account as instructed by the U.S. Department of the Treasury. 
  • GL 52 does not authorize transactions otherwise prohibited by U.S. sanctions on Venezuela, such as transactions prohibited by E.O. 13808 related to bonds and certain other debt of the Government of Venezuela or PdVSA, nor transactions prohibited by E.O. 13835 related to the sale, transfer, assignment, or pledging as collateral of any equity interest in PdVSA, PdVSA Entities, or any other entity in which the Government of Venezuela holds a 50 percent or greater ownership interest. 
  • GL 52 also does not authorize settlement agreements, enforcement of liens, judgments, arbitral awards, or other judicial processes purporting to transfer blocked property. 
  • All terms must be commercially reasonable payment terms and cannot include debt swaps, payments in gold or Venezuelan digital currency (including the petro).
  • Transactions cannot involve persons located in or organized under the laws of Russia, Iran, North Korea, or Cuba, entities owned, controlled, or in a joint venture with persons in those jurisdictions or in China, or other persons subject to U.S. sanctions other than PdVSA itself or PdVSA Entities. 
  • Lastly, any person that exports, reexports, sells, resells, or supplies Venezuelan-origin oil or petrochemical products to countries other than the United States under GL 52 must submit detailed reports to Sanctions_inbox@state.gov and VZReporting@doe.gov, within ten days of the first such transaction, with follow-on reports required every 90 days while transactions remain ongoing. In GL 52, OFAC describes what must be in the report.

Updated General License 5V: GL 5V separately authorizes, on or after May 5, 2026, all transactions related to, the provision of financing for, and other dealings in the PdVSA 2020 8.5 Percent Bond that would otherwise be prohibited by E.O. 13835, as amended by E.O. 13857.  OFAC has a long history of issuing an iteration of GL 5 and replacing it by a subsequent authorization, which has had the impact of delaying the effective date since the very first replacement of GL 5 in October 2019.

Companies should continue to monitor OFAC’s Venezuela sanctions program for any further amendments, revocations, or supplemental guidance affecting the scope of GL 52 and GL 5V. Relevant requirements under other federal authorities, including the Export Administration Regulations (EAR) remain in effect – companies should therefore continue to assess whether equipment, technology, or services associated with oil activity implicate export licensing, end-use, or end-user restrictions, particularly where transactions involve sensitive jurisdictions or intermediaries.

On March 12th, the Office of the United States Trade Representative (USTR) initiated investigations under Section 301(b) of the Trade Act of 1974 of 60 countries for potential forced labor violations resulting in unfair competition for US companies selling abroad. According to U.S. Trade Representative Jameison Greer, the investigations will examine whether these countries have failed to take adequate measures to prevent goods produced with forced labor from entering global supply chains in a manner that burdens or restricts U.S. commerce and places U.S. exporters at a competitive disadvantage abroad.

The full list of all 60 countries covered by the investigation can be found at the USTR announcement and ranges from China to Switzerland, including several of the United States’ largest trading partners. If USTR determines that the acts, policies, or practices under review are unreasonable or discriminatory and burden U.S. Commerce, the agency may impose several remedies including tariffs, import restrictions, or the suspension of trade agreements.

Public hearings on the matter are scheduled to take place between April 28th and May 1st, 2026, with written comments due by April 15th, 2026. For countries without a trade agreement with the United States, a determination is generally expected within 12 months after the investigation begins.

USTR has previously investigated forced labor concerns in the context of Nicaragua. In 2024, the Biden administration initiated the first-ever Section 301 investigation targeting labor rights, human rights and rule of law violations. On October 20, 2025, USTR determined that Nicaragua’s acts, policies and practices were unreasonable and burdened U.S. commerce, and structured a remedy phased in over two years on all imported Nicaraguan goods, rising to 10 percent on January 1, 2027 and 15 percent on January 1, 2028.  This gives a concrete template for what may follow for other economies.

Companies with international supply chains or export operations involving the affected jurisdictions should monitor the investigations closely, as any resulting trade measures could impact sourcing strategies and compliance obligations.  In the policy context, these new Section 301 investigations represent a strategic shift to use Section 301’s forced labor authority as the legal backbone for a broad global tariff regime, after IEEPA-based tariffs were struck down.  Companies importing from any of the 60 covered economies face potential new tariffs and must urgently audit forced labor exposure across their supply chains.
Targeting close allies like the EU, UK, Canada, Japan, and Australia on forced labor grounds — economies with their own robust enforcement laws — is likely to generate significant diplomatic friction.

For additional information regarding submissions of comments or participation in the hearing, please feel free to reach out to Crowell & Moring for assistance.

Introduction

Over the last two months, OFAC has issued and updated a series of general licenses and Frequently Asked Questions (FAQs) that allow for a variety of activities in the Venezuela oil, gas, petrochemical products, electricity, and gold sectors when they involve persons sanctioned pursuant to the Venezuela sanctions regulations, including the Government of Venezuela (GOV) and its state-owned oil company PdVSA. 

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In what amounts to a material expansion of its existing sanctions program arising out of the conflict in the Democratic Republic of the Congo (“DRC”), on March 2, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against the Rwanda Defence Force (“RDF”)—an organization described by OFAC as Rwanda’s military—along with four senior RDF officials. According to Treasury, the RDF has been “supporting, training, and fighting alongside” M23, an armed group already designated by both the United States and United Nations and operating in the eastern DRC. Treasury tied the action  to alleged violations of the “Washington Accords for Peace and Prosperity,” including a recent M23 offensive that resulted in the capture of the city of Uvira in eastern DRC.

Under this blocking action, all property and interests in property of the RDF and the designated officials that are in the United States, or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. U.S. persons are generally prohibited from engaging in transactions or dealings with the designated parties unless authorized by OFAC.

OFAC’s “50 Percent Rule” also applies to entities owned, directly or indirectly, 50% or more– individually or in the aggregate– by one or more blocked persons, even if not separately identified on OFAC’s Specially Designated Nationals (“SDN”) List.  

Also on March, 2, 2026, OFAC issued Treasury’s General License No. 1 under the DRC Sanctions Regulations (31 CFR part 547). The General License authorizes transactions that are ordinarily incident and necessary to wind down pre-existing dealings involving the RDF, and any entity owned 50 percent or more by the RDF, through April 1, 2026.  The authorization is limited and it does not permit the initiation of new business, nor does it unfreeze blocked property.  Any payments involving a blocked person must be placed into a blocked account.  The General License also does not authorize transactions with any other persons blocked under the DRC program (or any other otherwise-prohibited conduct) unless separately authorized.

These actions build on Treasury’s February 20, 2025 designations of James Kabarebe and Lawrence Kanyuka Kingston, along with two associated companies registered in the United Kingdom and France. The March 2026 designations reflect a continued expansion of Treasury’s focus from individual actors to state-affiliated institutions alleged to be supporting destabilizing activities in the DRC.

Practically, companies with operations, counterparties, or financial flows connected to Rwanda, or the DRC region, particularly those with potential connections to regional military or defense sector or supply chains, should treat this development as an immediate compliance priority. In particular, businesses involved in regional logistics, extractive industries, commodities trading, defense-related activities or financial services should consider:

  • Conducting enhanced screening of counterparties and beneficial owners;
  • Reviewing existing contracts for potential RDF nexus;
  • Assessing whether wind-down activity is required before April 1, 2026; and
  • Confirming that any required blocking and reporting procedures are implemented.

Crowell & Moring will continue to monitor developments related to sanctions enforcement actions and their potential impact to industry.

On February 26, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) reached an administrative enforcement settlement with Teledyne FLIR LLC and its affiliates FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems, Inc. d/b/a Teledyne FLIR OEM, (together, “Teledyne FLIR”), imposing a $1,000,000 civil penalty to resolve alleged violations of the Export Administration Regulations (“EAR”).

According to BIS, Teledyne FLIR voluntarily self-disclosed 19 alleged violations between 2017 and 2024 tied to exports, reexports, and related conduct involving thermal imaging cameras under export control classification numbers (“ECCN”) 6A003 and 6A993.a. The penalties broke into four types of violations:

  • Causation: BIS alleged that Teledyne FLIR caused nine exports from abroad of ECCN 6A003 thermal imaging cameras from a Swedish affiliate to China without required BIS authorization, based in part on incorrect calculations under the EAR’s de minimis rule in 15 C.F.R. Part 734.
  • Evasion: BIS alleged an evasion-related fact pattern involving a 2018 collaboration with a Chinese drone manufacturer concerning the Zenmuse XT2, a project involving the integration of a FLIR camera for use with civilian drones. This evasion scheme consisted of a pricing structure that BIS alleged was designed to keep U.S.-controlled content below the de minimis threshold and did not reflect the fair market value of the items.
  • Failure to Keep Records: BIS alleged failures to comply with license-condition recordkeeping requirements for certain demonstrations by the Shanghai affiliate.
  • Exports to Entity List Address: BIS alleged eight unlicensed exports of ECCN 6A993.a thermal cameras to company included on the Entity List for being an “address only” company (i.e., part of a shell company). Under EAR § 744.16, a license was required for exports of any items listed on the Commerce Control List.

This action is a useful reminder that conducting a “de minimis” analysis is not a box-checking exercise and can be more complicated that it seems. When you assess the valuation of the controlled U.S.-origin item, it should reflect the fair market value of that item when it was exported from the United States and account for items customarily included (and actually shipped) with the controlled U.S.-origin item. BIS can view any attempts to “engineer” pricing to fall below the applicable de minimis thresholds as an evasion violation.

The settlement also underscores that exporters should not rely solely on name-based denied-party screening; address-only Entity List entries require address-level controls and, often, manual review. Companies should be sure that their screening providers both screen for these address-only Entity List entries and that their algorithms and fuzzy logic appropriately capture those addresses.

Lastly, the settlement is a good reminder that companies should be mindful of all license requirements and have in place disciplined recordkeeping processes when authorizations are obtained. Without these controls, U.S. export violations can quickly multiply.

Crowell & Moring will continue to monitor developments related to export control enforcement actions and their potential impact to industry.

On February 9, 2026, the U.S. Department of the Treasury’s (Treasury) Office of Investment Security (OIS) published a request for information (RFI) seeking public comments on how the Committee on Foreign Investment in the United States (CFIUS) might streamline its foreign investment review process, including through the Known Investor Program (KIP). The RFI requests feedback on (1) proposed eligibility criteria and a draft questionnaire for the KIP, including certain defined terms, and (2) other ways that CFIUS and transaction parties can streamline aspects of the foreign investment review process. Written comments are due March 18, 2026.

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On February 6, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) announced the launch of a new online Voluntary Self-Disclosure (VSD) Portal (the “New Portal”) intended to replace and reduce reliance on ad hoc submission methods with a more secure channel for reporting to OFAC potential sanctions violations. OFAC states that moving disclosures into the New Portal should improve process visibility for disclosing parties, including faster acknowledgment and clearer communication during OFAC’s review. Of note, “OFAC strongly encourages parties to begin submitting voluntary self-disclosures through” the New Portal.

From a submission mechanics standpoint, the New Portal’s form is designed to be completed in roughly 30 minutes and asks for core identifying information for the disclosing party and a primary correspondent (for example, if an entity or individual is represented by counsel), plus supporting documentation uploads.  The New Portal limits uploads to 15 files, restricts file size to no larger than 30 megabytes (MB), and accepts only certain common formats (.PDF, .DOC, .DOCX, .XLS, .XLSX, .JPEG, .JPG or .PNG). Previously, there was a 150 MB maximum, with a maximum of 50 MB per email, before OFAC required submitting through a large file transfer system. As before, the New Portal requires optical character recognition (OCR) on all PDFs prior to submission.

For extensive or document-intensive submissions, OFAC requests that submitters continue to use OFAC’s Production Submission Standards, which cover package organization, sequential pagination, Excel-compatible spreadsheets, and transmission protocols, including secure transfers with ID.me authentication. Compliance with these standards may factor into OFAC’s evaluation of cooperation.

The New Portal is a reminder that OFAC’s current Economic Sanctions Enforcement Guidelines (the “Guidelines”) explicitly note that a qualifying VSD is treated as a mitigating factor in any penalty assessment. In addition, where OFAC determines a civil monetary penalty is warranted, a qualifying VSD can result in a 50 percent reduction in the maximum possible penalty (with the precise calculation mechanics depending on whether OFAC treats the case as egregious or non-egregious), provided the VSD meets the criteria in the Guidelines. As we have previously noted, organizations that promptly report potential violations to OFAC may receive reduced penalties or even avoid enforcement altogether.

Crowell & Moring LLP regularly advises U.S. and foreign companies on VSDs to OFAC and related investigations. Please contact the authors regarding questions about VSDs or the New Portal.

On January 21, 2026, U.S. Customs and Border Protection (“CBP”) announced that its Forced Labor Portal is now live. This new online portal provides a single, centralized platform for importers to submit requests for review when their shipments are detained or excluded due to forced labor enforcement actions. By consolidating what was previously a patchwork of email and paper submission processes, the portal is intended to streamline communications and ensure that all forced labor-related documentation reaches the appropriate CBP officials for timely review.

Effective immediately, use of the Forced Labor Portal is mandatory for importers seeking to challenge or obtain exceptions for shipments held under U.S. forced labor laws. This includes filing admissibility review requests for goods detained under Withhold Release Orders (“WROs”) or forced labor findings, as well as review and exception requests related to the Uyghur Forced Labor Prevention Act (“UFLPA”) and other forced labor sanctions.

From a compliance and litigation standpoint, the Forced Labor Portal helps formalize CBP’s administrative record for forced labor enforcement actions. Information submitted through the portal is expected to form the basis of CBP’s admissibility determinations and may be relevant in subsequent administrative protests or judicial review before the U.S. Court of International Trade. As a result, the accuracy, timing, and completeness of portal submissions carry heightened legal significance.

Importers should be mindful of compressed administrative and statutory timelines, particularly for UFLPA detentions, which generally provide a shorter window to submit rebuttal evidence than traditional WRO cases. Companies should ensure that internal procedures and document retention practices are aligned with the portal’s submission requirements.

CBP has published a Quick Reference Guide and an instructional video on its website to assist users with the transition to the portal.

Crowell & Moring LLP continues to monitor developments in forced labor prevention enforcement, including CBP’s implementation of the Forced Labor Portal, and its impact on industry.

On January 29th, 2026 U.S. Customs and Border Protection announced a Withhold Release Order on all shipments of coffee harvested by Finca Monte Grande, a Mexican coffee farm in Chiapas, Mexico. Effectively immediately CBP will detain all shipments of coffee harvested by Finca Monte Grande at any U.S. Port of Entry for probable forced labor violations.

As a result of CBP investigation into the Finca Monte Grande plantation, evidence demonstrates that workers are subject to 6 of the 11 indicators of forced labor including:

  • Abusive Working and Living Conditions
  • Abuse of Vulnerability
  • Debt Bondage
  • Excessive Overtime
  • Retention of Identify Documents
  • Withholding of Wages

Under 19 U.S.C. § 1307, any good that is produced wholly or in part with forced labor is prohibited from entering the United States and if violations are found, goods are subject to detention and seizure at the time of importation. A 2024 US Department of Labor report found that multiple industries in Mexico engage in child labor and forced labor violations with the agricultural sector being the largest risk. These affected commodities include coffee, melons, sugarcane and other agricultural products.

This is the first issued WRO in 2026 and emphasizes the importance of supply chain tracing by importers to ensure compliance with US regulations, avoiding unnecessary disruptions and costly delays. For more information on implementing due diligence and supply chain management, please feel free to reach out to Crowell & Moring for assistance.