Join us in Mountain View, California on Thursday, November 12, for an exclusive in-person forum on Trade Strategy in a Fragmented World. The event will kick off with a fireside chat featuring Peter Harrell (Visiting Scholar Georgetown Law, former White House Senior Director for International Economics and Competitiveness, Contributing Editor, Lawfare), who will share insights on making sense of economic statecraft, the weaponization of tariffs, sanctions, and export controls, and adapting to the proliferation of…
Join us for the 47th Year-End Review of Global Trade Developments Conference, a three-day webinar series featuring five substantive sessions led by our international trade lawyers from around the world. Topics will include sanctions, export controls, customs and imports compliance, enforcement trends, and key global and regional trade developments. Please visit our event page for more information and to register.
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…
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 Then, on September 30, 2026, OFAC issued a second related rule removing superseded penalties provisions and reorganizing remaining parts.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…