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 July 23, 2026, the US Department of State designated multiple entities and individuals in Cuba, and the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three new Cuba-related general licenses. The actions are intended to further restrict revenue streams supporting the Cuban government, including activities tied to the energy sector, sanctions evasion networks, financial services, and Cuba’s overseas medical missions program. The designations and general licenses were issued under Executive…
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…