On April 17, 2026, the Office of Management and Budget (“OMB”) issued Memorandum M‑26‑11 announcing that there will be no annual inflation adjustment to federal civil monetary penalties (“CMPs”) for the calendar year 2026. (For prior annual CMP adjustments, see our previous blog post available here and here.) The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (the “Act”) mandates annual adjustments to CMPs across the federal government, including CMPs administered by the Department…
On April 8, 2026, the US Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) issued a joint proposed rule (“Proposed Rule”) to implement provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (“GENIUS Act”). The Proposed Rule implements the GENIUS Act’s anti-money laundering (“AML”) and sanctions compliance program requirements and encourages innovation in payment stablecoins while providing a regulatory regime to mitigate…
On April 17, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia‑related General License No. 134B (“GL 134B”), extending the duration of General License No. 134A, which authorized certain transactions involving crude oil and petroleum products of Russian Federation origin that had already been loaded onto vessels. As with GL 134A, GL 134B authorizes transactions that are ordinarily incident and necessary to the sale, delivery, or offloading of Russian‑origin…
On April 14, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License Nos. 128C and 130A (“GL 128C” and “GL 130A”, respectively), further extending prior authorizations relating to certain transactions involving certain subsidiaries of Public Joint‑Stock Company Oil Company Lukoil (“Lukoil”). As with earlier iterations, these general licenses permit limited, time‑bound transactions to proceed notwithstanding the designation of Lukoil and certain affiliates as Specially Designated Nationals (“SDNs”). We…