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Welcome to this month’s issue of The BR International Trade Report, Blank Rome’s monthly digital newsletter highlighting international trade, cross-border investment, and geopolitical risk issues impacting businesses domestically and abroad. We invite you to share this resource with your colleagues and visit Blank Rome’s <a href="/services-and-industries/international-trade/" type="poa_practice" id="18498">International Trade </a>webpage for more information about our team.

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OFAC issues new general licenses and guidance regarding authorized business with Venezuela.

On January 29, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued&nbsp;<a href="https://ofac.treasury.gov/media/934886/download?inline">General License (“GL”) No. 46</a>,&nbsp;authorizing “established U.S. entit[ies]”&nbsp;to lift, purchase, sell, and engage in export-related activities involving Venezuelan-origin oil, subject to certain restrictions. Parties that make sales or export Venezuelan-origin oil to countries other than the United States must provide detailed reports to the U.S. Department of State (“DOS”) and the U.S. Department of Energy (“DOE”), and payments to blocked persons must be made into the Trump Administration-established Foreign Government Deposit Funds. &nbsp;OFAC updated this authorization on February 10 by issuing&nbsp;<a href="https://ofac.treasury.gov/media/935001/download?inline">GL 46A</a>, which supersedes GL 46 and provides that payments to Venezuelan blocked persons of local taxes, permits, and fees need not be made into the Foreign Government Deposit Funds.

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On February 3, OFAC issued&nbsp;<a href="https://ofac.treasury.gov/media/934891/download?inline">GL 47</a>&nbsp;authorizing the sale, storage, transportation, and other export-related activities of U.S.-origin diluents to Venezuela, subject to certain restrictions. Parties that export U.S.-origin diluents pursuant to GL 47 must provide detailed reports to DOS and DOE.&nbsp;

On February 10, OFAC issued&nbsp;<a href="https://ofac.treasury.gov/media/934986/download?inline">GL 48</a>, which authorizes the provision from the U.S. or U.S.-persons of “goods, technology, software, or services for the exploration, development, and production of oil and gas in Venezuela,” subject to certain restrictions.

In addition, OFAC has released&nbsp;<a href="https://ofac.treasury.gov/faqs/added/2026-02-06">Frequently Asked Questions</a>&nbsp;clarifying terms related to the new general licenses, notably confirming that the term “Venezuelan-origin oil” in GL 46 includes unfinished oils, liquified petroleum gasses, petrochemical feedstocks, petroleum coke, still gas, and other products.&nbsp;

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United States&nbsp;reaches deal with Taiwan.&nbsp;On January 15, the U.S. Department of Commerce announced a&nbsp;<a href="https://www.commerce.gov/news/fact-sheets/2026/01/fact-sheet-restoring-american-semiconductor-manufacturing-leadership">trade and investment deal</a>&nbsp;between the United States and Taiwan in which Taiwanese semiconductor and technology companies will invest at least $250 billion to strengthen U.S. “advanced semiconductor, energy, and artificial intelligence production and innovation capacity” in exchange for the United States capping its tariffs on Taiwanese-origin goods at 15 percent (inclusive of both reciprocal and Section 232 tariffs). In&nbsp;<a href="https://x.com/CommerceGov/status/2011913561757380826?ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembed%7Ctwterm%5E2011913561757380826%7Ctwgr%5E1e4be043372a6ad2544267aa45a094a10b1d8c57%7Ctwcon%5Es1_&amp;ref_url=https%3A%2F%2Fwww.commerce.gov%2Fnews%2Fblog%2Ftweets%2Fhistoric-us-taiwan-trade-deal">remarks to CNBC</a>, Secretary of Commerce Howard Lutnick explained that “[t]he objective is to bring 40 percent of Taiwan’s entire supply chain and production . . . into America… [i]f they don’t build in America, the tariff is likely to be 100 percent.”

United States and Israel announce joint partnership on the advancement of artificial intelligence.&nbsp;On January 16, the two countries announced the launch of a new&nbsp;<a href="https://www.state.gov/releases/office-of-the-spokesperson/2026/01/joint-statement-of-the-united-states-and-israel-on-the-launch-of-a-strategic-partnership-on-artificial-intelligence-research-and-critical-technologies/">Strategic Partnership on Artificial Intelligence, Research, and Critical Technologies</a>&nbsp;to deepen and formalize their long-standing collaboration in critical technology sectors. The joint statement outlines cooperation in several fields, including artificial intelligence, energy, advanced computing, space, and semiconductors. The agreement between the two nations falls under the&nbsp;<a href="https://www.state.gov/pax-silica">Pax Silica</a>&nbsp;framework, a U.S.-led initiative to advance supply chain technologies and protect digital infrastructure.

President Trump announces deal with India.&nbsp;On February 2, President Trump&nbsp;<a href="https://truthsocial.com/@realDonaldTrump/posts/116002095109616255">announced on Truth Social</a>&nbsp;that he and Indian Prime Minister Narendra Modi had agreed to a trade deal that would see India reduce its tariff and non-tariff barriers on U.S.-origin goods to zero and purchase “over $500 BILLION DOLLARS of U.S. Energy, Technology, Agricultural, Coal, and many other products,” in exchange for the United States lowering its reciprocal tariff on Indian-origin goods to 18 percent. The key provisions of the&nbsp;<a href="https://www.whitehouse.gov/fact-sheets/2026/02/fact-sheet-the-united-states-and-india-announce-historic-trade-deal/">trade deal</a>&nbsp;will require India to lower or remove tariffs on a broad set of U.S. industrial goods, food, and agricultural goods, while increasing purchasing of American energy, technology, and other products. The trade deal also includes commitments from both countries to strengthen technology cooperation and economic security. Following the announcement, on February 6, President Trump signed&nbsp;<a href="https://www.whitehouse.gov/presidential-actions/2026/02/modifying-duties-to-address-threats-to-the-united-states-by-the-government-of-the-russian-federation-04b2/">EO 14384</a>&nbsp;removing the 25-percent secondary tariff imposed on imports from India as a result of its import of Russian oil.&nbsp;

White House announces trade deal with Bangladesh.&nbsp;On February 9, the White House released a&nbsp;<a href="https://www.whitehouse.gov/briefings-statements/2026/02/joint-statement-on-framework-for-united-states-bangladesh-agreement-on-reciprocal-trade/">joint statement</a>&nbsp;detailing the agreement, which includes a reduction of the reciprocal tariff rate on Bangladeshi goods from 20 percent to 19 percent, while some products from the&nbsp;<a href="https://www.whitehouse.gov/wp-content/uploads/2025/09/ANNEX-II.pdf">Potential Tariff Adjustments for Aligned Partners</a>&nbsp;list may not face reciprocal tariffs. In addition, a currently unspecified volume of Bangladeshi apparel and textiles—the country’s&nbsp;<a href="https://tradingeconomics.com/united-states/imports/bangladesh">largest</a>&nbsp;sector for exports to the United States—will be exempt from reciprocal tariffs. This quantity will be based on a “mechanism” determined by Bangladesh’s import quantity of U.S.-produced textile inputs. In return for decreased tariff rates, Bangladesh agreed to further open its market to U.S. products such as chemicals, motor vehicles, and certain agricultural products.

European Union and India agree to free trade deal.&nbsp;The&nbsp;<a href="https://ec.europa.eu/commission/presscorner/detail/en/ip_26_184">trade deal</a>, which still must be ratified by leadership in the EU and India, would see the two economies reduce tariffs on nearly all imports—including cars and agri-food products—and&nbsp;<a href="https://www.weforum.org/stories/2026/02/india-eu-mother-of-all-trade-deals-what-to-know/">create the world’s largest free trade zone</a>, encompassing close to 25 percent of global gross domestic product.

European Parliament refers EU-Mercosur deal to the European Court of Justice.&nbsp;The&nbsp;<a href="https://www.europarl.europa.eu/news/en/press-room/20260116IPR32450/eu-mercosur-meps-demand-a-legal-opinion-on-its-conformity-with-the-eu-treaties">334-324 vote</a>, with 11 abstentions, held just four days after European Commission President Ursula von der Leyden&nbsp;<a href="https://ec.europa.eu/commission/presscorner/detail/en/ac_26_163">traveled to Paraguay</a>&nbsp;to sign the trade deal, prevents ratification of the deal until the European Court of Justice (“ECJ”) has ruled on its legality. According to reports, the ECJ may take&nbsp;<a href="https://www.politico.eu/article/opinion-europe-must-scramble-recover-mercosur-blunder/">up to two years</a>&nbsp;to issue an opinion.

European Parliament resumes consideration of EU-U.S. trade deal.&nbsp;In late January,&nbsp;the European Parliament&nbsp;<a href="https://www.bbc.com/news/articles/c4gwp2me3gzo">suspended consideration</a>&nbsp;of the EU-U.S. trade deal in response to President Trump’s calls for the United States to acquire Greenland. While members of the European Parliament have since&nbsp;<a href="https://www.politico.eu/article/eu-parliament-fails-to-reach-deal-on-us-trade-pact/">unfrozen its consideration</a>, they continue to disagree over certain tariffs, including those imposed on U.S. agricultural goods and lobster. Karin Karlsbro, lead negotiator for the liberal Renew group, remarked that “[t]o move forward[,]we need a ‘Trump-proofed’ agreement. If the U.S. threatens new tariffs, introduces new tariffs, or threatens the EU’s security interests, the agreement will be suspended.”

U.S. Department of the Treasury (“Treasury”) seeks public input on proposed “Known Investor Program” aimed at “fast tracking” the process for CFIUS review of foreign investments.&nbsp; Treasury’s February 9&nbsp;<a href="https://www.federalregister.gov/documents/2026/02/09/2026-02481/request-for-information-pertaining-to-the-cfius-known-investor-program-and-streamlining-the-foreign">Request for Information</a>&nbsp;(“RFI”) details the types of information, including eligibility criteria, which the Committee on Foreign Investment in the United States (“CFIUS”) proposes to collect from foreign investors through a formal questionnaire.&nbsp; Interested parties are invited to submit comments no later than March 18, 2026.&nbsp; Assistant Secretary for Investment and Security Chris Pilkerton&nbsp;<a href="https://home.treasury.gov/news/press-releases/sb0389">stated</a>&nbsp;that the RFI “underscores the efforts being made to expand stakeholder engagement with CFIUS with the aim of enhancing and evolving the Committee’s processes while maintaining our longstanding commitment to open investment and protecting U.S. national security.”&nbsp;

Japan proposes Committee on Foreign Investment.&nbsp;&nbsp;On January 23, the Office of the Japanese Prime Minister&nbsp;<a href="https://japan.kantei.go.jp/104/statement/202601/_00007.html">proposed the establishment of a Committee on Foreign Investment in Japan</a>.&nbsp;Modeled after CFIUS, the committee will be structured to strengthen the country’s framework for screening inbound foreign investment in Japanese companies involved in&nbsp;<a href="https://www.asahi.com/ajw/articles/16277266">key industries affecting national security</a>, such as aerospace and defense and nuclear energy.&nbsp;Under the proposed framework, foreign investors seeking to make certain investments in key industries would be required to submit an application for review by&nbsp;<a href="https://www.japantimes.co.jp/business/2026/01/08/economy/japan-foreign-investment-committee/">relevant governmental bodies</a>, including the Finance Ministry, Trade Ministry, and the National Security Secretariat.&nbsp; The committee could be established by the end of 2026.

Japan’s Liberal Democratic Party (“LDP”) secures supermajority in February snap election.&nbsp;Led by Prime Minster Sanae Takaichi, the LDP now holds&nbsp;<a href="https://www.nytimes.com/2026/02/08/world/asia/japan-takaichi-election-landslide.html">316 of the 465 seats</a>&nbsp;in the House of Representatives, marking the first time since World War II that a single political party has held a two-thirds supermajority. Prime Minister Takaichi is&nbsp;<a href="https://truthsocial.com/@realDonaldTrump/posts/116019257556623305">scheduled to meet</a>&nbsp;President Trump at the White House on March 19.

United States to build stockpile of critical minerals.&nbsp;The initiative, dubbed “<a href="https://www.exim.gov/news/week-review-project-vault-and-strategic-critical-mineral-reserve">Project Vault</a>,” will “establish[ ] the U.S. Strategic Critical Minerals Reserve, an independently governed public-private partnership that will store essential raw materials in secure facilities across the United States.” Funded by a $10 billion loan from the Export-Import Bank of the United States and $2 billion in private sector investment, Project Vault underscores American efforts to diversify supply chains away from China.

Vice President J.D. Vance calls for a critical minerals trading bloc.&nbsp;On February 4, the U.S. Department of State hosted leaders from 54 countries and the European Commission at the&nbsp;<a href="https://www.state.gov/releases/office-of-the-spokesperson/2026/02/2026-critical-minerals-ministerial">2026 Critical Minerals Ministerial</a>. During his&nbsp;<a href="https://www.state.gov/releases/office-of-the-spokesperson/2026/02/opening-remarks-of-the-critical-minerals-ministerial">opening remarks</a>, Vice President Vance encouraged attendees to join a “preferential trade zone for critical minerals, protected from external disruptions through enforceable price floors . . . maintained through adjustable tariffs to uphold pricing integrity.”

U.S. government announces critical minerals action plan with Mexico.&nbsp;The&nbsp;<a href="https://ustr.gov/sites/default/files/files/Press/Releases/2026/FINAL%20Critical%20Minerals%20Action%20Plan_US%20MX%20for%20release%204%20Feb%202026.pdf">Critical Minerals Action Plan</a>&nbsp;(the “Action Plan”) focuses on creating a resilient supply chain and effective trade policies for critical minerals. The Action Plan directs the Office of the U.S. Trade Representative and the Mexican Secretariat of Economy to discuss key aspects within the next 60 days, such as identifying “mining, processing, and manufacturing projects for critical minerals” and “coordinated trade policies and mechanisms” to facilitate the Action Plan.

Washington, Brussels, and Tokyo declare intent to develop critical minerals action plan.&nbsp;On February 4,&nbsp;the United States, the European Union and Japan announced a joint intention to form a coordinated partnership to strengthen&nbsp;<a href="https://ustr.gov/sites/default/files/files/Press/Releases/2026/Joint%20Press%20Statement%20-%204%20February%202026.pdf">critical minerals supply chain reliance</a>. The three partners committed to deepening economic and national security cooperation by securing and diversifying critical minerals supply chains essential for energy and advanced technology. The joint press statement outlines goals to create coordinated trade policies and boost cooperation, such as developing a Memorandum of Understanding between the United States and the EU and building upon the existing&nbsp;<a href="https://www.whitehouse.gov/briefings-statements/2025/10/united-states-japan-framework-for-securing-the-supply-of-critical-minerals-and-rare-earths-through-mining-and-processing/">U.S.-Japan critical minerals framework</a>&nbsp;established in October 2025.

United States prepares to levy secondary tariffs on countries selling oil to Cuba and doing business with Iran.&nbsp;

President Trump declares national emergency with respect to Cuba, authorizing the imposition of secondary tariffs.&nbsp;<a href="https://www.whitehouse.gov/presidential-actions/2026/01/addressing-threats-to-the-united-states-by-the-government-of-cuba/" target="_blank" rel="noreferrer noopener">Executive Order (“EO”) 14380</a>, signed January 29, directs the U.S. Secretary of Commerce and the U.S. Secretary of State to identify countries that directly or indirectly sell or provide oil to Cuba, determine whether an additional tariff on those countries is necessary, and provide recommendations to the President. See also the corresponding&nbsp;<a href="https://www.whitehouse.gov/fact-sheets/2026/01/fact-sheet-president-donald-j-trump-addresses-threats-to-the-united-states-by-the-government-of-cuba/" target="_blank" rel="noreferrer noopener">Fact Sheet</a>.

President Trump establishes process to impose tariffs on countries transacting with Iran.&nbsp;<a href="https://www.whitehouse.gov/presidential-actions/2026/02/modifying-duties-to-address-threats-to-the-united-states-by-the-government-of-the-russian-federation/" target="_blank" rel="noreferrer noopener">EO 14382</a>, signed February 6, establishes a process similar to those described in EO 14380, requiring the U.S. Secretary of Commerce and the U.S. Secretary of State to recommend to the President&nbsp;<a href="https://www.whitehouse.gov/fact-sheets/2026/02/fact-sheet-president-donald-j-trump-addresses-threats-to-the-united-states-by-the-government-of-iran/" target="_blank" rel="noreferrer noopener">additional tariffs</a>&nbsp;on countries that “acquire any goods or services from Iran.” The February 6 EO follows escalating tensions between the United States and Iran in the Arabian Sea, which saw a U.S. aircraft carrier&nbsp;<a href="https://www.cnn.com/2026/02/03/politics/iran-drone-uss-lincoln-tensions" target="_blank" rel="noreferrer noopener">shoot down</a>&nbsp;an Iranian drone.

President Trump announces an America First Arms Transfer Strategy.&nbsp;The strategy, set out in&nbsp;<a href="https://www.whitehouse.gov/presidential-actions/2026/02/establishing-an-america-first-arms-transfer-strategy/" target="_blank" rel="noreferrer noopener">Executive Order 14383</a>, aims to use foreign arms sales to fund domestic reindustrialization and production capacity, thereby expanding the defense industrial base. The EO gives the Secretary of War and the Secretary of State 90 days to “develop clear criteria for determining which weapons, platforms, or capabilities require Enhanced End Use Monitoring,” as well as a “sales catalog” of platforms and systems to be encouraged as exports. Pursuant to the EO, the Secretary of War, the Secretary of State, and the Secretary of Commerce will establish a task force set to publish quarterly performance metrics on foreign military sales and the adjudication of export licenses.&nbsp;

Hong Kong-owned port operator removed from Panama Canal.&nbsp;On January 29, the Supreme Court of Panama&nbsp;<a href="https://www.wsj.com/business/logistics/panamas-high-court-rules-against-hong-kong-firm-running-canal-ports-714c23c8?mod=hp_lead_pos4" target="_blank" rel="noreferrer noopener">canceled the contracts</a>&nbsp;of a Chinese-owned company for the operation two ports at either end of the Panama Canal, ruling that the contracts held by the company&nbsp;<a href="https://www.reuters.com/world/asia-pacific/panama-court-voids-ck-hutchison-port-contracts-2026-01-30/" target="_blank" rel="noreferrer noopener">since the 1990s</a>&nbsp;were unconstitutional. Several countries praised the decision in a&nbsp;<a href="https://www.state.gov/releases/office-of-the-spokesperson/2026/01/nations-support-panamanian-rule-of-law" target="_blank" rel="noreferrer noopener">joint statement</a>, including the United States, Bolivia, Costa Rica, Ecuador, Guatemala, Honduras, and Paraguay, who have praised the court for “confronting corruption and enforcing accountability.”

For continuous, up-to-date information on the evolving administrative landscape, check out Blank Rome’s <a href="https://www.blankrome.com/trump-administration-resource-hub">Trump Administration Resource Hub</a>. Explore previous BR International Trade Reports <a href="/the-br-international-trade-report/" type="page" id="43249">here</a>.

DOJ Announces Record-Breaking False Claims Act Recoveries in FY 2025: What the Stats Portend for 2026

Blank Rome partner&nbsp;<a href="https://www.blankrome.com/people/jennifer-a-short">Jennifer A. Short</a>&nbsp;and associate&nbsp;<a href="https://www.blankrome.com/people/oliver-e-jury">Oliver E. Jury</a>&nbsp;authored this alert discussing the Department of Justice’s securing of $6.8 billion in False Claims Act recoveries in FY 2025, and what current statistics suggest for priorities and resolutions moving into 2026.&nbsp;

Kenneth J. Nunnenkamp Recognized as a 2026 Power Player in Foreign Investment and National Security by&nbsp;Financier Worldwide

Blank Rome is pleased to share that partner&nbsp;<a href="https://www.blankrome.com/people/kenneth-j-nunnenkamp#biography">Kenneth J. Nunnenkamp</a>&nbsp;has been recognized in&nbsp;Financier Worldwide’s&nbsp;Power Players: Foreign Investment &amp; National Security 2026 – Distinguished Advisers list.

Making the Toughest Export Compliance Calls: Executives Discuss the Newest Pressures, C-Suite Questions, and Dilemmas Affecting Decision-Making

Blank Rome partner&nbsp;<a href="https://www.blankrome.com/people/anthony-rapa">Anthony Rapa</a>&nbsp;will serve as a session panelist at American Conference Institute’s 3rd Advanced Forum on Global Export Controls, being held February 24 and 25, 2026, in Arlington, Virginia.

To learn more about other Recent Developments or Upcoming Events, click&nbsp;<a href="https://www.blankrome.com/services/cross-border-international/international-trade#news" target="_blank" rel="noreferrer noopener">here</a>.

To read more about Blank Rome's International Trade practice, please visit our&nbsp;<a href="https://www.blankrome.com/services/cross-border-international/international-trade#overview" target="_blank" rel="noreferrer noopener">website</a>.

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© 2026 Blank Rome LLP. All rights reserved. Please contact Blank Rome for permission to reprint. Notice: The purpose of this update is to identify select developments that may be of interest to readers. The information contained herein is abridged and summarized from various sources, the accuracy and completeness of which cannot be assured. This update should not be construed as legal advice or opinion, and is not a substitute for the advice of counsel.

The BR International Trade Report: February 2026

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The BR International Trade Report: February 2026

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