On October 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published an alert (the “Alert”) warning that foreign financial institutions (“FFIs”) that continue to transact with sanctioned Iranian financial institutions “could be targeted at any time without advance notification.” OFAC also amended Iran-related FAQ 156 to remove earlier language indicating that OFAC would generally contact an FFI about its conduct before making a finding that the FFI knowingly engaged…
On September 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the expiration of the national emergency declared in Executive Order 14046 of September 17, 2021, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia” (“EO 14046”), and removed persons designated under that order from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Department of State published…
On July 27, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a statement (here) of enforcement policy committing not to take supervisory or enforcement action against US financial institutions under the Bank Secrecy Act (“BSA”) in connection with the provision of authorized financial services provided in Venezuela. The statement was issued in consultation with the Internal Revenue Service and the staffs of the Board of Governors of the Federal Reserve…
On July 20, 2026, the US State Department published Public Notice 13072 imposing additional sanctions on Sudan under Section 307(b) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “Act”). The action follows the State Department’s April 24, 2025, determination under Section 306(a) of the Act, that the Government of Sudan used chemical weapons in violation of international law. Section 307(b) of the Act calls for additional sanctions unless the…