OFAC General Licenses Authorizing Venezuela Energy and Petrochemical Exports

The U.S. Department of the Treasury's OFAC issued multiple amended General Licenses (46B, 47, 48A, 49A, 50A, 51A, 52, 53, 54, and 55) authorizing transactions related to Venezuela's energy and petrochemical sectors. The licenses permit U.S. entities to engage in Venezuelan-origin oil exports and imports, U.S.-origin diluent exports to Venezuela, and oil/gas exploration and production activities. Contracts with Venezuelan government or PdVSA entities must be governed by U.S. law with U.S.-based dispute resolution.

FCC Adds Foreign-Produced Consumer Routers to Covered List

The FCC released Public Notice DA-26-278A1 adding foreign-produced consumer routers to the Covered List, prohibiting new router models from receiving FCC equipment authorizations for U.S. importation and sale. The action stems from a March 20, 2026 National Security Determination finding consumer-grade routers produced outside the U.S. pose an unacceptable risk to national security. A companion notice (DA-26-286A1) provides an implementation grace period until March 1, 2027.

Whistleblower Reward Program for AML and Sanctions Violations

FinCEN published a Notice of Proposed Rulemaking to establish a whistleblower award program for BSA/AML and sanctions violations, funded by a $300 million revolving fund. The proposal would allow individuals to receive monetary awards for reporting violations that result in enforcement actions with penalties exceeding $1 million. Unlike SEC's program, compliance officers and internal auditors would not be broadly excluded from eligibility.

Bill transposing EU Sanctions Directive 2024/1226 into French law

France filed Bill No. with the National Assembly on March 3, 2026 to transpose EU Sanctions Directive 2024/1226 into French law, 10 months past the May 20, 2025 transposition deadline. The Bill substantially enhances penalties for violations of EU restrictive measures and introduces a new non-intentional offence. The proposal includes exemptions and reduced penalties as permitted by the Directive.

EU CBAM Definitive Phase Enforcement and Penalties Analysis

The EU Carbon Border Adjustment Mechanism entered its definitive phase on January 1, 2026, transforming from a reporting tool to an economic instrument imposing financial obligations. Only authorized CBAM declarants may import carbon-intensive goods above a 50-ton de minimis threshold, with certificate sales opening February 1, 2027 and the first annual declaration and surrender due September 30, 2027.

EU Foreign Subsidies Regulation Quarterly Update, Enforcement Activity

The European Commission published FSR Guidelines on 9 January 2026 setting out its substantive assessment framework for foreign subsidies, including the balancing test and call-in powers for below-threshold transactions and public tenders. The EC also published summary notices in February 2026 for its first two ex officio investigations under the FSR: Nuctech and Goldwind.

SEC Pauses Cboe Rule 8.23 Disruptive Trading Rule

The SEC halted Cboe's self-certification of proposed Rule 8.23 governing disruptive trading practices, requiring the rule to undergo public notice and comment. The rule would have prohibited traders from submitting orders or quotes for non-bona fide purposes and enumerated 11 specific illegitimate purposes. Market participants had objected that the rule contained over 30 separate items and constituted substantive modifications to investor protection rules without proper rulemaking.

Payments and Digital Assets Regulatory Developments - March 2026 Newsletter

Hogan Lovells' March 2026 Payments Newsletter covers UK FCA and PSR regulatory priorities for payments and digital finance, ECB's digital euro pilot call for expression of interest, and Delaware's proposed digital assets and stablecoin licensing bills. The FSB also announced a new implementation phase for the G20 Roadmap to enhance cross-border payments, with industry expected to play a decisive role as the 2027 target date approaches.

UK Securitisation Framework Reforms - Due Diligence and Risk Retention

The UK FCA and PRA published joint consultation papers (CP26/6 and CP2/26) on 17 February 2026 proposing significant reforms to the UK Securitisation Framework. Key changes include more principles-based due diligence, removal of private/public securitisation distinctions, elimination of mandatory repository reporting, a new L-shaped risk retention model, and resecuritisation options. The reforms aim to reduce regulatory friction and costs for UK market participants. Rules are expected to be finalised by end-2026 with application from Q2 2027.

Canada's New Anti-Money Laundering Legislation Significantly Raises Penalties

The Parliament of Canada has enacted Bill C-12, amending the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Maximum administrative monetary penalties have been increased 40-fold, with very serious violations now carrying penalties up to C$20-million per violation and cumulative caps reaching C$20-million or 3% of gross global revenue. A new enrollment requirement with FINTRAC has been introduced, with implementation pending Order in Council.