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 Then, on September 30, 2026, OFAC issued a second related rule removing superseded penalties provisions and reorganizing remaining parts.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…
On August 26, 2026, President Trump issued Executive Order 14420, “Declaring a National Emergency to Secure the United States Bulk-Power System” (“EO 14420”), which aims to prevent certain foreign actors from creating or exploiting vulnerabilities in foreign-produced equipment used in the US bulk-power system. EO 14420 builds on and significantly expands Executive Order 13920, “Securing the United States Bulk-Power System” (“EO 13920”), which the Trump administration issued in 2020 and formed the basis of an…