Publications, Presentations & Events

An examination of the Bank of America settlement agreement and other enforcement actions from OFAC since September 1, 2026

A quiet OFAC civil docket contrasts sharply with a heavy, fast-moving designation calendar during June, July, and August 2026.

OFAC took three designation actions between July 10 and July 14, 2026. Two target Iran and are expressly framed as a response to Iran’s resumption of attacks on shipping in the Strait of Hormuz; the third targets the service providers behind ransomware operations.

The online Portal is designed to improve the efficiency of the delisting process by prompting petitioners to provide key information at the outset of a matter, rather than through multiple follow-up questionnaires that can delay OFAC’s review.

OFAC settlements with Adani Enterprises and FTI Consulting share a common message: OFAC will hold sophisticated, U.S. and foreign companies responsible for the economic realities of their transactions.