Pillsbury Trade & Sanctions Blog

US Drafts AI Chip Export Controls

The US is reportedly drafting new export control regulations for AI chips, which would implement a tiered licensing system based on computing power. These draft rules aim to position the US as a gatekeeper for the global AI industry and could impose significant pre-clearance requirements for high-volume exports.

USTR Launches Section 301 Investigations on Forced Labor Imports

The Office of the U.S. Trade Representative (USTR) has initiated Section 301 investigations into 60 major trading partners to determine if they are effectively banning imports of goods produced with forced labor. The USTR is seeking public comment and will hold hearings on the matter.

USTR Section 301 Investigations into Excess Capacity

The U.S. Trade Representative (USTR) has initiated Section 301 investigations into structural excess capacity and production in 16 economies. The USTR is seeking public comments on these investigations, with a deadline of April 15, 2026.

US Imposes Export Controls on AI Chips to China, Tariffs

The US Department of Commerce's Bureau of Industry and Security (BIS) issued a final rule on January 15, 2026, revising its export licensing review policy for advanced computing items to China. This change shifts from a presumption of denial to a case-by-case review for certain AI chips, while also imposing a 25% fee on such sales. Concurrently, a Section 232 Proclamation targets semiconductor imports with tariffs, offering exceptions for domestic use.

OFAC Issues Venezuela Oil Trade General Licenses

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued General License (GL) 46, authorizing certain transactions related to Venezuelan oil and petroleum products for established U.S. entities. This action aims to expand trade and investment opportunities, though broader sanctions remain in place.

Treasury RFI on CFIUS Known Investor Program

The U.S. Department of the Treasury has issued a Request for Information (RFI) regarding the implementation of the CFIUS Known Investor Program (KIP). The RFI seeks public input on formalizing this voluntary program, which aims to streamline foreign investment reviews. The comment period closes on March 18, 2026.

Supreme Court Invalidates IEEPA Tariffs

The U.S. Supreme Court, in a 6-3 decision in Learning Resources v. Trump, ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. This decision invalidates previously imposed IEEPA tariffs and forecloses their future use as a statutory basis for tariffs.

OFAC Authorizes Expanded Oil Activities in Venezuela

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued new General Licenses (GLs) expanding authorizations for U.S. persons involved in Venezuela's oil and gas sector. These licenses permit a wider range of transactions related to oil extraction, export, and services, aligning with a broader U.S. strategy to relax sanctions.