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2025

November 2025: Penalties Imposed on Atlanta Real Estate Investor Who Sold Property Owned by Sanctioned Russian Elite
OFAC imposed a $4.7 million penalty on an Atlanta real estate investor for knowingly renovating and selling property owned by a sanctioned Russian individual, and also for failing to comply with an OFAC subpoena and violating the terms of an OFAC cease-and-desist letter.
November 2025: OFAC Continues its Focus on Iranian Shadow Fleet and Global Network
OFAC has announced sanctions on a global network of individuals, entities, ships, and aircraft for their involvement with the Iranian regime. The alleged network was sanctioned pursuant to OFAC’s counterterrorism authority. In announcing the sanctions, OFAC noted it targeted six vessels of Iran’s shadow fleet bringing the total number of vessels sanctioned by the Trump Administration to over 170.
October 2025: OFAC Delists Former Paraguayan President Horacio Cartes
OFAC removed former Paraguayan President Horacio Manuel Cartes Jara and several affiliated companies from its Specially Designated Nationals (SDN) list, reversing measures that had been in place for nearly three years under the Global Magnitsky Human Rights Accountability Act.
October 2025: Now-Dissolved Crypto Exchange ShapeShift AG Settles with OFAC over Transfers of Digital Assets to Sudan, Cuba, Iran and Syria
Cryptocurrency exchange ShapeShift AG agreed to a settlement of $750,000 with the U.S. Office of Foreign Assets Control for apparent violations of US sanctions regulations relating to Cuba, Sudan, Iran and Syria.
October 2025: OFAC Continues to Target Iranian Shadow Fleet

(“OFAC”) announced sweeping designations of almost 100 vessels, a refinery, an oil terminal and shell companies all alleged to support Iran’s illicit oil trade.
September 2025: OFAC Sanctions Cryptocurrency Exchange and Network
OFAC re-designated the cryptocurrency exchange Garantex Europe OU. OFAC alleged that Garantex directly facilitated cybercriminals by processing over $100 million in transactions linked to illicit activities since 2019.
July 2025: OFAC Settlement with U.S. Electronics Company for Iran Sanctions Violations
OFAC announced a settlement and civil monetary penalty of USD 1,454,145 with Harman International Industries, Inc. arising from violations of OFAC sanctions on Iran.
July 2025: Mind the Middleman or Face “Maximum Pressure”: Amid Shifting Geopolitical Priorities, US Sanctions Continue to Focus on the United Arab Emirates
Whether the focus of US foreign policy is on disrupting Russia’s war financing efforts or confronting Iran’s shadow banking network, the UAE remains a consistent “country of focus” for the US Treasury Department.
June 2025: Trump Administration Focuses on LatAm Region for Sanctions Enforcement Targeting Cartels
New 311 actions require immediate attention from the legal and business community in the region.
June 2025: Changing Landscape for Investigation and Prosecution of Foreign Corrupt Practices Act Matters
The U.S. Deputy Attorney General has issued guidelines for FCPA investigations.
June 2025: United States Sanctions Relief for Syria: The Road to Reconstruction Begins in Washington
President Trump has cracked down on terror support networks in Yemen and Iran, but he has also extended hope for development in war-torn Syria.
May 2025: Section 311 Action Against Huione Group: Indicator of More to Come?
FinCEN used Section 311 of the USA PATRIOT Act’s “special measures” to exile a “network” of Cambodia-based businesses, including a crypto brokerage, from the U.S. financial system.
January 2025: US Sanctions UAE Trading Companies for Support of Sudanese Rebels
The United States remains focused on the UAE as a region of concern for sanctions enforcement.

2024

December 2024: Anti-WMD Proliferation Sanctions in Pakistan
The US State Department announced sanctions against three Pakistani companies and a government-owned entity. This action serves as a reminder that sanctions determinations are not limited to OFAC.
December 2024: Musical instrument manufacturer’s OFAC settlement demonstrates value of self-reporting
A manufacturer of musical instruments based in California agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran.
December 2024: Lack of Sanctions Due Diligence in Foreign Acquisitions Leads to OFAC Penalty
The case illustrates the risk of failing to conduct adequate sanctions screening, as well as the advantages of self-reporting and cooperating with OFAC.
October 2024: The “Engel List”: Corruption and Anti-Democracy Sanctions against Latin American Officials
While the list serves an important role in identifying the individuals responsible for corrupt practices in Central America, like many US “lists,” it presents significant challenges from a due process perspective.
July 2024: OFAC Sanctions Deserve To Be Challenged Post-Chevron
The unintended consequences of OFAC's expansion of the Specially Designated Nationals List.

2023

August 2023: OFAC Designation Prosecutions Are Constitutionally Suspect
In light of the severe consequences of running afoul of OFAC's directives, there has not been enough meaningful opportunity to challenge the scope and basis of OFAC's decision making.
March 2023: US Sanctions Focus on the United Arab Emirates
The UAE is a “country of focus” for US investigators.

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The foregoing is for informational purposes only. It is not intended as legal advice and no attorney-client relationship is formed by the provision of this information.

Analysis of recent OFAC enforcement actions and other sanctions topics.