Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

On 1 June 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) announced that FTI Consulting, Inc. (NYSE: FCN), a global business-advisory and expert-witness firm, agreed to pay $1,050,000 to settle apparent civil liability for six indirect dealings in prohibited debt of VTB Bank OAO between April 2019 and May 2021 — constituting violations of the Russia Harmful Foreign Activities Sanctions Regulations (RuHSR) and the then-applicable Directive 1 debt-tenor restrictions. FTI had been engaged via an intermediary global law firm to provide expert economic consulting services supporting VTB in Singapore litigation; invoices issued through that intermediary went unpaid or were paid far beyond the permissible 14-day tenor, extending prohibited debt on six occasions totalling approximately $353,862. OFAC determined the conduct was non-egregious and not voluntarily self-disclosed, and imposed a penalty of $1,050,000 — double the $525,000 base penalty — citing the foundational principle that a party may not do indirectly what it cannot do directly.

President Trump signed Executive Order 14404, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy," on 1 May 2026. The order operationalises the country-specific national emergency declared by EO 14380 (29 January 2026) — which had been preserved after the SCOTUS *Learning Resources* vacatur of the IEEPA tariff authority — by establishing a sectoral OFAC blocking regime. Section 2 authorises asset-blocking against any foreign person determined by the Secretary of Treasury (in consultation with State) to operate in Cuba's energy, defense and related materiel, metals and mining, financial services, or security sectors, or "any other sector" subsequently designated. Section 3 suspends entry under INA § 212(f) for covered aliens. Section 4 authorises secondary sanctions against foreign financial institutions that knowingly conduct or facilitate significant transactions for blocked persons, with both correspondent-account and SDN-listing remedies. The EO itself includes no annex of named designations — those are issued by OFAC under separate determinations.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced on 17 March 2026 that TradeStation Securities, Inc. agreed to pay $1,110,661 to settle 481 apparent violations of the Iranian Transactions and Sanctions Regulations (31 CFR Part 560), the Syrian Sanctions Regulations (31 CFR Part 542), and the Ukraine-/Russia-Related Sanctions Regulations (31 CFR Part 589) that occurred between 21 June 2021 and 15 June 2022. The violations arose from a mobile-platform software update that inadvertently caused the firm's second-tier geo-blocking to screen the IP address of a U.S.-located server rather than the user's IP, allowing customers in Iran, Syria, and Crimea to execute securities-related transactions. OFAC determined the apparent violations were non-egregious and voluntarily self-disclosed, resulting in a significantly reduced settlement amount.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 25 February 2026 that a U.S. person agreed to pay $3,777,000 to settle potential civil liability for 20 apparent egregious violations of the Syrian Sanctions Regulations (31 CFR Part 542) occurring between January 2018 and December 2021. The individual provided managerial services — reviewing and signing financial statements, approving operational and employee expenses, and supervising service-fee collection — as an officer and board member of four Syrian real-estate companies supporting luxury real-estate development projects in Syria. OFAC determined the conduct was egregious and not voluntarily self-disclosed, setting the settlement at 10× the statutory IEEPA base amount per apparent violation (the maximum egregious multiplier) and establishing a significant personal-liability precedent for U.S. persons serving on boards or in officer roles of companies in sanctioned jurisdictions.

OFAC reached a $1,720,000 civil penalty settlement with IMG Academy LLC on 12 February 2026 to resolve 89 apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations (31 CFR Part 598) arising from tuition-related transactions processed on behalf of two individuals designated as SDNs under the Kingpin Act between 2018 and 2023. OFAC determined the apparent violations were NON-EGREGIOUS and not voluntarily self-disclosed; the penalty reflects substantial cooperation and remedial measures taken by IMG Academy after becoming aware of the violations. This is the first OFAC enforcement action in the register against a US educational or academic-services institution, establishing Kingpin Act SDN-screening obligations for schools and training academies accepting international student tuition payments.

On 16 January 2026, the US Treasury's Office of Foreign Assets Control designated 21 individuals and entities and identified one vessel for transferring oil products, procuring weapons and dual-use equipment, and providing financial services to Iran-backed Ansarallah (the Houthis). Designated parties — oil-trading and exchange companies, a shipping/logistics facilitator, and front-company operatives — are based in Yemen, Oman, and the UAE, and are accused of running an oil-sales and financial- facilitation network that Treasury says generates the Houthis over $2 billion in annual illicit revenue. The action was taken pursuant to Executive Order 13224 (as amended) and builds on a multi-year cadence of prior OFAC designations against Houthi leaders, smugglers, financiers, and weapons-procurement suppliers.

The US Treasury's Office of Foreign Assets Control designated 18 individuals and entities that make up the "rahbar" shadow-banking networks of sanctioned Iranian banks Bank Melli and Shahr Bank, including Singapore-based Golden Mist PTE Ltd, UAE-based Empire International Trading FZE and HMS Trading FZE, Iran-based Nikan Pezhvak Aria Kish Company and Tejarat Hermes Energy Qeshm, and UK-based Nanshan Ltd. Separately, OFAC designated senior Iranian security officials, including SCNS Secretary Ali Larijani, for their role in the regime's violent crackdown on peaceful protesters that began in December 2025. The financial designations were made under E.O. 13902 (Iran's financial/petroleum/petrochemical sectors) and the human-rights designations under E.O. 13553 and E.O. 13876, in furtherance of NSPM-2; Treasury noted it sanctioned more than 875 persons, vessels, and aircraft under the same maximum-pressure campaign in 2025.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into a $3,103,360 settlement with Exodus Movement, Inc., a U.S.-incorporated non-custodial / self-custody crypto wallet software company, to resolve 254 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560) committed between October 17, 2017 and January 4, 2019. Exodus customer-support staff provided technical and account-related support — and in 12 of the 254 instances recommended the use of virtual private networks (VPNs) to circumvent partner-exchange geoblocking controls — to users who self-identified as located in Iran, in violation of the ITSR's prohibition on the export of services to Iran (§ 560.204) and, for the 12 egregious cases, the facilitation prohibition (§ 560.203). OFAC deemed the 12 VPN-coaching cases "egregious" because Exodus personnel were generally aware of U.S. sanctions and the company's own terms of use prohibited Iran usage, yet support staff actively helped Iranian users evade controls. Exodus separately committed to invest $630,000 in additional sanctions compliance controls. The settlement is structurally novel as the first OFAC enforcement action against a Web3-infrastructure / non-custodial wallet-software vendor and establishes that OFAC will assert jurisdiction over self-custody software providers based on customer-support facilitation conduct, not just custodial flow control.

OFAC settled civil liability of USD 1,092,000 with an unnamed individual (a former US government official and attorney) for 122 apparent violations of Russia-related sanctions programs spanning April 2018 to June 2022. The individual served as fiduciary and trustee of a US-based family trust established for the benefit of a sanctioned Russian oligarch (SDN-listed under EO 13662 and EO 14024) and in that capacity dealt in the blocked property of — and provided prohibited trust-administration services to — the oligarch without OFAC authorisation. OFAC assessed the conduct as non-egregious and not voluntarily self-disclosed, but credited substantial cooperation in fixing the penalty below the base amount.

The U.S. Treasury's Office of Foreign Assets Control designated four individuals and four entities under Executive Order 14098 ("Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition") for operating a transnational network that recruits former Colombian military personnel to fight for Sudan's Rapid Support Forces (RSF) paramilitary. Designated persons include retired Colombian officer Alvaro Andres Quijano Becerra, his wife Claudia Viviana Oliveros Forero, the Colombia-based recruitment agency International Services Agency (A4SI), and Panama-based intermediary Talent Bridge, S.A. (formerly Global Staffing S.A.). All property and interests in property of the designated persons subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from transacting with them.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into an $11,485,352 settlement with IPI Partners, LLC — a US private-equity data-center fund manager (~$10.5bn AUM) — to resolve 51 apparent violations of the Ukraine-/Russia-Related Sanctions Regulations between July 2018 and June 2022. IPI solicited and accepted two $25 million fund subscriptions in September 2017 and March 2018 from Definition Services, Inc. — a British Virgin Islands entity ultimately owned by Heritage Trust, a Delaware family trust established by sanctioned Russian oligarch Suleiman Kerimov — and continued processing 18 capital calls, 20 distributions, and 13 management-fee payments for four years after Kerimov's April 2018 SDN designation. OFAC simultaneously issued an unusually direct sectoral warning to the private-equity industry, marking the first major OFAC enforcement against a US PE-fund administrator in the data-center / AI-infrastructure segment and the second Kerimov-linked PE/VC settlement of 2025 (after the June 2025 $216M GVA Capital statutory-maximum penalty).

The US Treasury's Office of Foreign Assets Control designated Burma-based arms procurement company Royal Shune Lei Company Limited, its three Burmese executives, and two North Korean nationals linked to the Korea Mining Development Trading Corporation (KOMID) for operating an arms-trafficking and revenue-generation network supporting DPRK weapons of mass destruction and ballistic missile programs. Royal Shune Lei brokered sales of aerial bomb guidance kits, bombs, and airborne monitoring equipment to Burma's military junta on behalf of KOMID starting in 2022. Designations were made under Executive Order 13687 (DPRK), Executive Order 13551 (DPRK arms trade), and Executive Order 14014 (Burma), blocking all US-jurisdiction property of the six designated parties and barring US persons from transactions with them.

On 22 September 2025, OFAC designated Lex Instituto de Estudos Juridicos LTDA (Lex Institute) and Viviane Barci de Moraes — wife of Brazilian Supreme Federal Court (STF) Justice Alexandre de Moraes and the Institute's Managing Partner — pursuant to Executive Order 13818 (the Global Magnitsky Human Rights Accountability Act authority). The Lex Institute is a family holding company that owns de Moraes' residence and other properties; Treasury designated it for materially supporting de Moraes, who was himself designated under the same authority on 30 July 2025 for authorizing arbitrary pre-trial detentions and suppressing freedom of expression, including in the prosecution of former President Jair Bolsonaro. All US property and interests of the designated persons are blocked and U.S. persons are generally barred from transacting with them.

The US Treasury's Office of Foreign Assets Control designated two Iranian financial facilitators — Alireza Derakhshan and Arash Estaki Alivand — along with more than a dozen Hong Kong- and UAE-based individuals and entities for operating a shadow-banking network that laundered proceeds from Iranian oil sales through front companies and cryptocurrency. The designated addresses account for over $600 million in total inflows, including more than $100 million in cryptocurrency purchases tied to oil sales between 2023 and 2025. Proceeds are alleged to benefit the IRGC-Qods Force and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). This is the second round of OFAC sanctions targeting Iran's shadow-banking infrastructure since National Security Presidential Memorandum 2 (NSPM-2) directed a maximum-pressure campaign on Iran in February 2025.

On 11 September 2025, the US Treasury's Office of Foreign Assets Control designated 32 individuals and entities and identified four vessels in what Treasury described as its broadest sanctions action to date against Iran-aligned Ansarallah (Houthi) support networks. The designated network — companies, owners, and operatives located in Yemen, China, the UAE, and the Marshall Islands — is accused of running oil and commodity smuggling through Houthi-controlled Yemeni ports, laundering the proceeds, and using them to finance a global weapons procurement supply chain of front companies and shipping facilitators. The action was taken pursuant to Executive Order 13224 (as amended) and builds on nine prior 2024-2025 OFAC actions against Houthi leaders, smugglers, financiers, and suppliers.

The US Treasury's Office of Foreign Assets Control designated a Russian national (Vitaliy Sergeyevich Andreyev), a Russia-based DPRK economic and trade consular official (Kim Ung Sun), a Chinese front company (Shenyang Geumpungri Network Technology Co., Ltd), and a DPRK trading company subordinate to the DPRK Ministry of People's Armed Forces General Political Bureau (Korea Sinjin Trading Corporation) for facilitating a fraudulent overseas IT-worker scheme that funds North Korea's weapons of mass destruction and ballistic missile programs. The action expands on the prior designation of Chinyong Information Technology Cooperation Company, an entity tied to the DPRK defense ministry that deploys IT worker delegations in Russia and Laos. Treasury said Andreyev and Kim Ung Sun facilitated cryptocurrency-to-cash conversions worth nearly USD 600,000 since December 2024, and that Shenyang Geumpungri's delegation of DPRK IT workers has earned Chinyong and Sinjin over USD 1 million in profits since 2021. Designations were made under Executive Order 13687, blocking all US-jurisdiction property of the four parties and barring US persons from transactions with them.

On 14 August 2025 OFAC re-designated the cryptocurrency exchange Garantex Europe OU under its cyber authority (E.O. 13694, as amended) for processing over USD 100 million in transactions tied to ransomware and darknet-market actors since 2019, and designated its successor exchange Grinex — created by former Garantex staff to move customer deposits and continue operations after a March 2025 US Secret Service-led takedown of Garantex's infrastructure. OFAC also designated three Garantex executives, the A7A5 ruble-backed stablecoin issuer Old Vector (Kyrgyzstan), and Russian settlement-platform firm A7 and its subsidiaries A71 and A7 Agent — entities linked to sanctioned Moldovan oligarch Ilan Shor and sanctioned Promsvyazbank — for supplying the A7A5 token used to compensate Garantex customers and route funds through Grinex.

On 30 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identified more than 50 vessels belonging to the shipping empire of Mohammad Hossein Shamkhani, son of Ali Shamkhani, a top political adviser to Iran's Supreme Leader. Treasury described the action — over 115 sanctions in total — as its largest Iran-related action since 2018. The network launders billions of dollars from sales of Iranian and Russian crude oil and petroleum products (mostly to buyers in China) through vessels and front companies registered across the UAE, Hong Kong, India, Cyprus, Panama, Romania, China, Liberia, the Marshall Islands and Seychelles. Concurrently, the State Department designated 20 entities and identified 10 vessels under E.O. 13846 and E.O. 13902 for trading and transporting Iranian petroleum and petrochemical products.

The US Treasury's Office of Foreign Assets Control designated the Korea Sobaeksu Trading Company (also known as Sobaeksu United Corporation) and three associated individuals — Kim Se Un, Jo Kyong Hun, and Myong Chol Min — for evading US and UN sanctions and clandestinely generating revenue for the DPRK government, including through fraudulent information-technology worker schemes. Sobaeksu operates as a front company for the US-designated Munitions Industry Department, which oversees North Korea's nuclear program and ballistic-missile development. The action was coordinated with a Department of Justice unsealing of indictments against seven DPRK nationals over counterfeit- cigarette sanctions evasion, and State Department reward offers of up to USD 7 million for information on the individuals involved. Designations block all US-jurisdiction property of the four parties and bar US persons from transacting with them.

On 22 July 2025, the US Treasury's Office of Foreign Assets Control designated two individuals and five entities under Executive Order 13224 for facilitating revenue generation and material support to the Houthis (Ansarallah) through petroleum importation and money laundering. The network — Muhammad Al-Sunaydar's Arkan Mars petroleum companies (Yemen/UAE) and Yahya Mohammed Al Wazir's Al-Saida Stone for Trading and Agencies and Amran Cement Factory — coordinated roughly $12 million of Iranian petroleum imports through the Houthi-controlled Ras Isa port with an Iranian IRGC-linked petrochemical trading entity, and laundered approximately €6 million through bulk-coal front-company transactions. The action builds on a cadence of OFAC designations against Houthi revenue and weapons-procurement networks running since mid-2024.

The US Treasury's Office of Foreign Assets Control designated 22 entities based in Hong Kong (18), the UAE, and Türkiye under Executive Order 13224 for facilitating sales of Iranian oil that benefit the IRGC-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. The front-company network moves refinery payments for Iranian oil through offshore accounts to fund IRGC-QF activity; the action is the second round of sanctions under National Security Presidential Memorandum 2's "maximum pressure" campaign, following a June 6, 2025 action against Iranian exchange-house money-laundering networks. All property and interests of the designated entities within US jurisdiction are blocked, and US persons are generally prohibited from dealing with them.

On 3 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the other member states of the Terrorist Financing Targeting Center (TFTC), designated five entities and sixteen individuals forming the core of Hizballah's financial infrastructure, under Executive Order 13224 as amended. Newly designated entities include Tashilat SARL (a Lebanese lender that provided loans on behalf of Hizballah and operated as part of Al-Qard Al-Hassan (AQAH) and Bayt al-Mal), alongside senior AQAH officials Samer Hasan Fawaz and Ali Mohamad Karnib. The action reaffirms and expands sanctions on AQAH, Hizballah's shadow "benevolent loan association" bank, and Bayt al-Mal, its unofficial treasury, both previously designated by OFAC in 2007 and 2006 respectively. It is the ninth TFTC joint designation since the center's creation in May 2017 and the third under this Administration; designated persons are alleged to have moved over $500 million through the formal Lebanese banking system — including US-designated Jammal Trust Bank — via joint and shadow accounts despite existing sanctions.

On 25 June 2025, FinCEN issued three coordinated orders identifying CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. as foreign financial institutions of primary money-laundering concern in connection with illicit opioid trafficking, and prohibiting US covered financial institutions from engaging in certain transmittals of funds (including convertible virtual currency transmittals) to or from those three institutions or any account or CVC address administered on their behalf. The orders were published in the Federal Register on 30 June 2025 (FR docs 2025-11991 Vector, 2025-11993 CIBanco, 2025-11990 Intercam) with an original effective date of 21 July 2025. These are the first-ever orders issued under Section 2313a of the Fiscal Year 2024 NDAA (added by the FEND Off Fentanyl Act and Fentanyl Sanctions Act), and target Mexican counterparties tied by FinCEN to the Beltran-Leyva Cartel, Jalisco New Generation Cartel (CJNG), and the Gulf Cartel.

On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated four individuals, twelve entities, and two vessels in what Treasury called its single largest action to date against Iran-backed Ansarallah (the Houthis), pursuant to Executive Order 13224 as amended. The designated network — Sana'a- and Hudaydah-based oil-trading front companies (including Black Diamond Petroleum Derivatives, Star Plus Yemen, Tamco Establishment, Royal Plus Shipping, and Abbot Trading) and their Houthi operator-owners — facilitates black-market oil and oil-derivative sales that fund Houthi militant operations, while shipping firms Best Way Tanker Corp, Ocean Voyage LLC, and Atlantis M. Shipping Co were designated for discharging over 120,000 combined metric tons of gasoline and LPG at the Houthi-controlled Ras Isa port via the vessels Valente and Atlantis MZ after the April 2025 expiration of Counter Terrorism General License 25A. The action builds on OFAC's June 2024–April 2025 cadence of designations against Houthi leaders, weapons-procurement operatives, and suppliers.

On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated one individual, eight entities, and one vessel pursuant to Executive Order 13382 (WMD proliferators) for procuring and transshipping sensitive machinery to Iran's Rayan Roshd Afzar Company (RRA), a producer of UAV components and aerospace software for the IRGC. The vessel SHUN KAI XING, owned by Hong Kong-based Unico Shipping Co Ltd and chartered by Singapore-based V-Shipping Pte Ltd, was carrying the machinery for RRA and an affiliated firm when its cargo was inspected; the designated network — including China-based Shenzhen Xinxin Shipping, Dongguan Zanyin Machinery and Equipment, Athena Shipping, shipmaster Zhang Yanbing, and Turkiye-based Edisa Dis Ticaret Limited Sirketi — then falsified bills of lading to obscure the Iran-bound, RRA-consigned cargo after the inspection.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced a $3,882,797 civil settlement with Unicat Catalyst Technologies LLC, an Alvin, Texas-based specialty catalyst supplier, resolving 13 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) and one apparent violation of the Venezuela Sanctions Regulations (VSR, 31 CFR Part 591). OFAC determined the conduct egregious; Unicat had voluntarily self-disclosed. The settlement was concurrent with separate actions by the U.S. Department of Justice and the Department of Commerce Bureau of Industry and Security (BIS). The violations, spanning 2016–2021, involved the supply of catalyst products and consulting services to Iranian customers via a Dutch affiliate and Chinese supplier, and the sale of catalysts to Orinoco Iron S.C.S., a blocked Venezuelan government-owned entity, routed through a Chinese intermediary.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) imposed a $215,988,868 civil monetary penalty — the statutory maximum applicable — on GVA Capital Ltd., a Silicon Valley early-stage venture capital firm, for willful violations of Russia-related sanctions and for failure to comply with an administrative subpoena. The penalty resolves conduct in which GVA, after its founding investor Suleiman Kerimov (a Russian oligarch and Federal Assembly member) was designated as a Specially Designated National in April 2018, continued for approximately three years to manage and attempt to liquidate Kerimov's $20 million investment in a Delaware special-purpose vehicle linked to Prosperity Investments, L.P. (a Guernsey-domiciled fund in which Kerimov retained a property interest). OFAC determined the conduct was egregious and not voluntarily self-disclosed. The action is the first public OFAC enforcement of the second Trump administration and the largest OFAC civil penalty since the November 2023 Binance Holdings settlement; it is also OFAC's first major enforcement action against a U.S. venture-capital / investment-adviser firm.

The US Treasury's Office of Foreign Assets Control designated more than 35 individuals and entities tied to Iranian brothers Mansour, Nasser, and Fazlolah Zarringhalam, whom OFAC says have collectively laundered billions of dollars through the international financial system using Iranian exchange houses (including Zarrin Ghalam, GCM Exchange, and Berelian Exchange) and foreign front companies based in the UAE and Hong Kong. The network is used to move revenue from Iranian oil and petrochemical sales that fund the regime's nuclear and missile programs and terrorist proxies. The action, taken pursuant to Executive Order 13902, is the first designation round under National Security Presidential Memorandum 2's "maximum pressure" campaign since its February 4, 2025 issuance; Treasury's FinCEN concurrently issued an updated advisory on Iranian shadow-banking and oil-smuggling red flags for financial institutions.

On 13 May 2025, the US Treasury's Office of Foreign Assets Control designated nearly two dozen firms and individuals — including Hong Kong-based intermediary Star Energy International Limited — for operating in Iran's illicit international oil trade on behalf of Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), the Tehran-based oil-sales arm of Iran's Armed Forces General Staff (AFGS). The designated network spans commercial intermediaries and shipping counterparties across China, Hong Kong and Singapore, the last a hub for ship-to-ship transfers of Iranian-origin crude. Designations were made under counter-terrorism (SDGT) and Iran Financial Sanctions Regulations (IFSR) authorities as part of the administration's maximum-pressure campaign to cut off military and IRGC-linked revenue from Iran's oil exports.

On 8 May 2025, the US Treasury's Office of Foreign Assets Control designated China-based "teapot" refinery Hebei Xinhai Chemical Group Co., Ltd. and its Singapore-based broker subsidiary Xing AO Energy PTE. LTD., three firms tied to a Dongying Port (Shandong) terminal that has received Iranian crude from shadow-fleet tankers, and six Hong Kong-, UK-, and Marshall Islands-owned shadow-fleet vessels (STAR TWINKLE 6, LAMD, SKADI, BIG MAG, IMPALAS, THANE) plus their owning shipping companies and two vessel captains. It is OFAC's third action against an Iranian-oil teapot refinery and its first targeting Shandong port terminal operators, taken under E.O. 13902 (Iran petroleum/ petrochemical sector) and E.O. 13846 (NIOC support) as part of the administration's NSPM-2 maximum-pressure campaign.

On 1 May 2025 the US Treasury's Office of Foreign Assets Control (OFAC), jointly with FinCEN, designated two Mexican nationals — Oscar Guillermo Juraidini Silva and J. Refugio Ruiz Villagomez — and nine entities they own or control, pursuant to Executive Order 14059 (illicit drug trade) and E.O. 13224 (as amended), for facilitating a Cartel Jalisco Nueva Generacion (CJNG) fuel-theft and cross-border smuggling scheme ("huachicol fiscal") that falsifies customs documentation to evade Mexico's IEPS fuel-import tax. FinCEN concurrently issued a supplemental alert on fuel-smuggling and fiscal fuel-theft red flags. All property and interests in property of the designees within US jurisdiction are blocked, and US persons are generally barred from transacting with them.

President Trump signed Executive Order 14203, "Imposing Sanctions on the International Criminal Court," on 6 February 2025, declaring a national emergency under IEEPA over the ICC's "illegitimate and baseless actions targeting America and our close ally Israel." The order authorises OFAC asset-blocking and INA § 212(f) entry suspensions against any foreign person determined by Treasury (in consultation with State) to have directly engaged in or materially assisted ICC efforts to investigate, arrest, detain, or prosecute protected persons (US persons and persons of US-allied non-ICC-state parties such as Israel). On 13 February 2025 OFAC made the first designation under the EO, adding ICC Prosecutor Karim Khan to the SDN List. OFAC subsequently codified the prohibitions into the new 31 CFR Part 528 ("International Criminal Court-Related Sanctions Regulations") published in abbreviated form on 1 July 2025 (FR doc 2025-12036). The program has since been used to designate eight additional ICC judges across 5 June 2025, 20 August 2025, and 18 December 2025 announcements.

On 4 February 2025, President Donald J. Trump signed National Security Presidential Memorandum/NSPM-2, "Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran's Malign Influence." The memorandum reimposes the first- term "maximum pressure" framework, directing the Secretaries of State and Treasury and the Attorney General to (i) drive Iran's exports of crude oil and petroleum products — including to the People's Republic of China — to zero; (ii) review and modify or rescind sanctions waivers and general licences (notably the Chabahar port waiver benefiting India); (iii) sanction shadow-fleet vessels, intermediaries, refineries (including PRC "teapot" refiners) and oil traders facilitating Iranian energy exports; and (iv) lead a diplomatic isolation campaign including a snapback of UN Security Council sanctions under JCPOA Resolution 2231 paragraph 11. Since promulgation, OFAC has designated 1,000+ Iran-related persons, vessels and aircraft and four PRC independent ("teapot") refiners alleged to have processed sanctioned Iranian crude. The DOJ is also directed to pursue impoundment of Iranian oil cargoes and seizure of Iranian assets to satisfy US-court terrorism-victim judgments.

On January 10, 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the Department of State, designated PJSC Gazprom Neft and PJSC Surgutneftegas as Specially Designated Nationals (SDNs) under Executive Orders 13662 and 14024, alongside more than 180 oil-carrying vessels (the bulk of Russia's "shadow fleet"), dozens of opaque oil traders, two major Russia-based oilfield service providers, marine insurance companies, and senior Russian energy-sector officials. The package included a new EO 14024 sectoral determination authorizing future designations against any person operating in the Russian energy sector, plus a new EO 14071 determination prohibiting the provision of US petroleum services (extraction, drilling, production support) to persons located in the Russian Federation, effective 12:01 a.m. EST on February 27, 2025. OFAC simultaneously issued General Licenses 117 (wind-down of transactions with the newly blocked entities) and 118 (debt/equity/derivatives wind-down), both expiring February 27, 2025. The action was the largest single Russia energy-sector designation since the 2022 invasion regime began and was coordinated with parallel UK OFSI shadow-fleet designations issued the same week. The action was finalized in the closing days of the Biden administration as a deliberate tightening of the oil-revenue and shadow-fleet vectors before the January 20 transition. Subsequent enforcement and any rollback decisions fell to the incoming Trump administration.

FinCEN issued a final order, published in the Federal Register on 11 October 2024 (signed 26 September 2024), prohibiting US covered financial institutions from engaging in transmittals of funds to or from PM2BTC, a virtual-currency exchange operating outside the United States and identified as a primary money-laundering concern in connection with Russian illicit finance. The order is the first use of FinCEN's special- measure authority under Section 9714(a) of the Combating Russian Money Laundering Act, as amended by the FY 2022 NDAA (codified at 31 U.S.C. 5323). The action was coordinated with same-day OFAC SDN designations of related entities (Cryptex) and individuals (Sergey Sergeevich Ivanov of Taleon Holdings).

The US Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register reporting instructions implementing Section 104(a) of the Rebuilding Economic Prosperity and Opportunity (REPO) for Ukrainians Act (P.L. 118-50, Division F, enacted April 24, 2024). All US financial institutions at which Russian sovereign assets are located — or that know or should know of such assets, including in correspondent or payable-through accounts — must report those holdings to OFAC using Form TD-F 93.09. Initial reports were due by August 2, 2024, with rolling reports required within 10 days of detecting newly identified Russian sovereign assets. The notice is the predicate step for any future US seizure or transfer of frozen Russian central bank, National Wealth Fund, or Russian Ministry of Finance assets to benefit Ukraine.

OFAC final rule (FR Doc 2024-11618, 89 FR 46518) amending the Cuban Assets Control Regulations at 31 CFR Part 515 to further implement the May 2022 Biden administration policy of expanded support for the Cuban people. The rule reinstates the "U-turn" general license (authorizing US banks to process funds transfers that originate and terminate outside the US, neither originator nor beneficiary a US person); replaces "self-employed individual" with the broader "independent private sector entrepreneur" (covering Cuban private businesses up to 100 employees, including private cooperatives); authorizes Cuban nationals in the private sector and located in Cuba to open and operate accounts at US financial institutions (including via online/mobile banking); and expands authorizations for internet-based services to support Cuban civil society and private-sector entrepreneurs. Effective 29 May 2024.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a final rule amending 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate, with amendments, General License (GL) D-2 — originally issued on OFAC's website on September 23, 2022 — which authorizes the export, reexport, and provision of certain services, software, and hardware incident to communications over the internet to persons in Iran. The codification preserves the GL D-2 expansion (cloud-based services; third-country importation of hardware/software previously exported to Iran; ex-Iran installation, repair and replacement services; case-by-case licensing for internet-freedom activities) and updates the § 560.540 List of Services, Software, and Hardware Incident to Communications. Effective June 17, 2024, the List is amended to exclude laptops, tablets, and personal computing devices with an Adjusted Peak Performance (APP) exceeding 1 Weighted TeraFLOP (WT) — narrowing the consumer-electronics authorization to lower-performance devices and aligning the carve-out with broader BIS-style compute thresholds. The rule does not relax primary ITSR prohibitions; it codifies a humanitarian / internet-freedom exception while inserting a narrow high-performance-compute carve-out.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register "Directive 1 under Executive Order 14014, 'Prohibitions Related to Financial Services to or for the Benefit of Myanma Oil and Gas Enterprise.'" The Directive — originally issued on OFAC's website on 2023-10-31 with a 2023-12-15 effective date — determines that MOGE is a political subdivision, agency, or instrumentality of the Government of Burma and prohibits U.S. persons from providing, exporting, or reexporting, directly or indirectly, financial services to or for the benefit of MOGE. The Federal Register publication codifies notice of the Directive in the formal record of agency action; the underlying prohibition has been operative since December 2023.

OFAC issued two determinations under Executive Orders 14068 and 14071 banning the import into the United States of Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024, and separately prohibiting the provision of warranting/deliverable services for these metals on global exchanges (LME, CME) and their use to settle over-the-counter derivative contracts. Metal produced before the effective date is grandfathered. The action was coordinated with the United Kingdom, which imposed parallel exchange-listing prohibitions the same day, following G7 statements on reducing Russia's metals revenue.

OFAC amended § 510.512 of the North Korea Sanctions Regulations (31 CFR Part 510) to broaden the scope of authorized humanitarian activities for NGOs operating in North Korea, including permitting transactions with certain Government of North Korea entities where necessary to deliver authorized services. Three new general licenses were added: one for exports and re-exports of items licensed by the Commerce Department; one for agricultural commodities, medicine, and medical devices; and one for journalistic activities in North Korea. NGOs relying on the authorization must notify the State Department at least 30 days before commencing activity.