On June 4, 2026, the US Department of State announced a new round of designations under Executive Order 14404 (“EO 14404”) targeting five entities and five individuals for being “associated with developing, implementing, and funding the Cuban regime’s violent revolutionary network.” Secretary of State Marco Rubio issued a press statement explaining the purpose of these designations. Concurrent with these designations, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new…
On May 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 134C (“GL 134C”), further extending the temporary authorization for certain transactions involving crude oil and petroleum products of Russian Federation origin that were loaded onto vessels prior to a specified cutoff date. GL 134C replaces and supersedes General License No. 134B (“GL 134b”) in its entirety but replicates its substantive terms. As we previously reported,…
On May 1, 2026, President Trump signed Executive Order 14404 (“EO 14404”) entitled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” which significantly expands the US sanctions framework targeting Cuba. EO 14404 imposed a modern US secondary sanctions regime targeting Cuba that is likely to encourage many non-US companies – particularly those with US assets/business and/or reliance on the US financial system –…
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…