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 28, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took a series of Iran-related actions as part of the Administration’s “Economic Fury” campaign of exerting maximum pressure against Iran. Specifically, OFAC (1) issued an alert warning of the sanctions risks of dealing with Chinese “teapot” oil refineries that process Iranian crude oil and (2) published FAQ 1249, which warns that “toll” payments to the Government of Iran (“GoI”)…
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 March 31, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Sanctions Advisory to raise awareness of potential sanctions risks arising from sham transactions used to evade sanctions. The advisory presents examples and lists red flags that may indicate the presence of a sham transaction. While it is explanatory only and does not have the force of law, the advisory follows several recent enforcement actions involving blocked persons…