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 Then, on September 30, 2026, OFAC issued a second related rule removing superseded penalties provisions and reorganizing remaining parts.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…
Earlier this month, as part of Operation Economic Outcast targeting Iran, the US Department of the Treasury ushered in a flurry of administrative and regulatory changes. On September 10, 2026, the Office of Foreign Assets Control (“OFAC”) modified its Iran-related specific licensing policy, announced a settlement agreement, and updated the Specially Designated Nationals and Blocked Persons List (“SDN List”). These changes landed two days after OFAC’s September 8, 2026 action against Iran’s aviation sector, which…
On September 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the expiration of the national emergency declared in Executive Order 14046 of September 17, 2021, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia” (“EO 14046”), and removed persons designated under that order from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Department of State published…
Two recent pronouncements indicate that enforcement risks around dealing with criminal narcotics trafficking organizations in Latin America continue to increase. We expect the Trump Administration to continue to focus on designating such organizations as Foreign Terrorist Organizations (“FTOs”), sanctioning their supporters, and enforcing the measures already in place. We also expect countries across Latin America to align more with the United States and impose their own sanctions against these organizations. First, on September 15, President…