Publications, Presentations & Events

Recent OFAC enforcement activity demonstrates the agency’s continued focus on sanctions compliance across sectors and geographic contexts, as shown by settlements involving IMG Academy, LLC and a U.S. individual.

New York County District Attorney Alvin Bragg and New York State Senator Zellnor Myrie recently announced draft legislation that would create additional state criminal exposure for cryptocurrency businesses operating without a valid New York license. The so called "CRYPTO ACT" would make it a criminal offense to engage in a “prohibited virtual currency act” in New York without a New York BitLicense issued by the New York Department of Financial Services.

OFAC has launched a new online portal for individuals and entities to submit voluntary self-disclosures of potential violations of sanctions programs.

On December 19, the U.S. Treasury’s Office of Foreign Assets Control announced a further expansion of Venezuela-related sanctions, taking coordinated action that included new Specially Designated Nationals (“SDN”) designations, the issuance of a Venezuela-related general license, and updated compliance guidance. These measures reflect the Trump Administration’s continued focus on applying targeted financial pressure against individuals and networks linked to narco-corruption and state-controlled energy activity in Venezuela.

On December 16, 2025, the U.S. Court of Appeals for the Eleventh Circuit issued a unanimous decision upholding the constitutionality of the Corporate Transparency Act (“CTA”), reversing a lower court ruling that had invalidated the statute.The decision represents a significant judicial endorsement of Congress’s effort to curb the use of anonymous companies in money laundering, sanctions evasion, and other forms of illicit finance.