The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) has restructured the location of penalty and enforcement procedure provisions within its regulations. On September 25, 2026, OFAC published a final rule creating 31 CFR Part 505, the Sanctions Penalties Regulations. Then, on September 30, 2026, OFAC issued a second related rule removing superseded penalties provisions and reorganizing remaining parts. These regulatory updates memorialize OFAC’s existing practices with enforcement matters but do not implement substantive changes to these processes.
31 CFR Part 505: Sanctions Penalties Regulations
The Sanctions Penalties Regulations consolidate within a single Part of OFAC’s regulations the penalty and enforcement procedure provisions that previously appeared separately in each program’s regulations. As codified, Part 505 comprises five subparts: Subpart A with general provisions (§§ 505.101 to 505.103), Subpart B with general definitions (§§ 505.201 to 505.203), a reserved Subpart C, Subpart D detailing the International Emergency Economic Powers Act (“IEEPA“) penalties (§§ 505.401 to 505.405), and Subpart E outlining the United Nations Participation Act (“UNPA“) penalties.
The consolidated provisions are substantively identical to those previously contained in each program’s regulations, and OFAC states that the rule makes no substantive changes to the penalty provisions. Part 505 provides that the Economic Sanctions Enforcement Guidelines (in Appendix A to Part 501) continue to govern how OFAC reviews and considers specific enforcement cases, including relevant mitigating and aggravating factors.
Conforming Amendments Across 36 Sanctions Programs
The second related rule, Removing Duplicative Penalties Information and Reorganizing Certain Parts, removed Subpart G from 36 parts of 31 CFR Chapter V. Subpart G previously set forth program-specific penalty provisions for each sanctions program. OFAC added a section to the affected CFR parts, in Section 105, to refer readers to the Sanctions Penalties Regulations for penalties information.
OFAC also reorganized the structure of most affected CFR parts by renaming Subpart A “General Provisions,” with related provisions in other locations being relocated to this subpart. The sections being moved to Subpart A include records and reports from Subpart F; procedures and delegation of authorities from Subpart H; and Paperwork Reduction Act from Subpart I. OFAC then removed Subparts F, H, and I.
The authors acknowledge the assistance of Jack Curtin with the preparation of this blog post.
