On June 4, 2026, the US Department of State announced a new round of designations under Executive Order 14404 (“EO 14404”) targeting five entities and five individuals for being “associated with developing, implementing, and funding the Cuban regime’s violent revolutionary network.” Secretary of State Marco Rubio issued a press statement explaining the purpose of these designations. Concurrent with these designations, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new…
On May 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 134C (“GL 134C”), further extending the temporary authorization for certain transactions involving crude oil and petroleum products of Russian Federation origin that were loaded onto vessels prior to a specified cutoff date. GL 134C replaces and supersedes General License No. 134B (“GL 134b”) in its entirety but replicates its substantive terms. As we previously reported,…
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…