Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

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.

On 4 December 2025, OFAC assessed a near-statutory-maximum civil monetary penalty of USD 7,139,305 against Gracetown Inc., a New York-based property-management company, for 24 apparent violations of Russia-related sanctions under EO 13660, EO 13661, and EO 14024 between April 2018 and May 2020, and for separately failing to report blocked assets for over 45 months in violation of 31 CFR §501.603. Gracetown was established in 2006 to manage three luxury real-estate properties in Manhattan and Washington DC ultimately owned by sanctioned Russian oligarch Oleg Deripaska; after Deripaska's April 2018 SDN designation — which OFAC communicated directly to Gracetown — the company continued processing 24 payments totalling USD 31,250 on behalf of a Deripaska-linked British Virgin Islands entity (Baufinanz). OFAC found the violations egregious and not voluntarily self-disclosed, driving the penalty to 80% of the USD 8,906,358 statutory ceiling; the ratio of penalty (USD 7.14M) to underlying transaction value (USD 31,250) underscores OFAC's strict liability approach to post-notice dealings.

On 24 November 2025, OFAC assessed a civil monetary penalty of USD 4,677,552 — the statutory maximum and the largest single OFAC penalty ever imposed against an individual — against an Atlanta-based real-estate investor operating through King Holdings LLC. Between April 2023 and March 2024 the respondent willfully purchased, mortgaged, renovated, and resold US residential property beneficially owned by a family member of a Russian oligarch sanctioned under EO 14024, in direct violation of a prior OFAC cease-and-desist order and in defiance of an administrative subpoena. OFAC found the violations egregious and non-self-disclosed; both aggravating factors drove the penalty to the statutory ceiling.

Switzerland's State Secretariat for Economic Affairs (SECO) and the US Treasury Office of Foreign Assets Control (OFAC) signed a Memorandum of Understanding on 9 May 2025 (jointly published 16 May 2025) establishing a framework for information-sharing, coordinated investigations, designated points of contact, regular bilateral meetings, joint training, and exchange of technical expertise on sanctions enforcement. The MoU is not legally binding and neither side is obliged to share information, but it formalises an enforcement-cooperation channel that previously operated only ad-hoc. It is the first sanctions-enforcement MoU Switzerland has concluded with a third country (the US has a comparable arrangement with the UK's OFSI), and SECO has indicated more such MoUs will follow.

The Office of Foreign Assets Control (OFAC) issued a final rule on 19 December 2024 amending 32 parts of 31 CFR chapter V to modernize the general licenses authorizing payments for legal services from funds originating outside the United States. The rule replaces the annual reporting requirement that had applied to such payments with a 10-year recordkeeping requirement, aligning the legal-services general licenses with the new 10-year statute of limitations for IEEPA/TWEA violations and OFAC's parallel 5→10-year recordkeeping extension (31 CFR 501). The rule also standardises legal-services general-license language across programs — removing legacy letter-of-engagement prerequisites in certain parts (e.g., 31 CFR 594, 597), updating 31 CFR 549 (Lebanon) and 31 CFR 576 (Iraq Stabilization and Insurgency) to remove the requirement that payments for authorised legal services be separately specifically licensed, and harmonising the 31 CFR 591 (Venezuela-related) authorisation language. The rule was effective 19 December 2024 with an applicability date of 12 March 2025.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register (89 FR 84472–84474, FR Doc 2024-24524) three general licenses issued under the Western Balkans Stabilization Regulations (31 CFR Part 588): GL 3A, GL 4, and GL 5. All three were originally issued on 18 June 2024 concurrent with OFAC's expansion of Republika Srpska / Dodik-network designations; the 23 October 2024 Federal Register notice formalises them per the Administrative Procedure Act notice requirements. GL 3A (which superseded GL 3 of 16 November 2023) authorises transactions involving certain WBSR-blocked entities that are ordinarily incident and necessary to the exportation or re-exportation of agricultural commodities, medicine, medical devices, replacement parts and components, software updates, or activities involving medical prevention, diagnosis, treatment, or clinical trials. GL 4 authorises wind-down transactions with entities blocked on 18 June 2024 through a defined cutoff. GL 5 authorises transactions ordinarily incident and necessary to the manufacture, distribution, operation, installation, or maintenance/repair of drinking-water pumps manufactured or distributed by the WBSR-blocked Bosnian Serb entity Kaldera Company EL PGP d.o.o. (and 50%-or-more-owned subsidiaries), preserving municipal water supply continuity.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register (89 FR 16400, FR Doc 2024-04856) two general licenses issued under the Western Balkans Stabilization Regulations (31 CFR Part 588): GL 2 and GL 3. Both were originally issued on 16 November 2023 concurrent with OFAC's initial round of Republika Srpska / Dodik-network designations; the 7 March 2024 Federal Register notice formalises them per the Administrative Procedure Act notice requirements. GL 2 authorises wind-down transactions with newly blocked WBSR entities through 15 March 2024. GL 3 authorises exports and re-exports of agricultural commodities, medicine, medical devices, replacement parts, and services for medical prevention and treatment to WBSR-blocked persons; GL 3 was subsequently superseded by GL 3A on 18 June 2024.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register (89 FR 15769, FR Doc 2024-04500) renaming the Darfur Sanctions Regulations (31 CFR Part 546) to the Sudan Stabilization Sanctions Regulations and amending them to implement Executive Order 14098 of May 4, 2023. E.O. 14098 broadened US sanctions authority beyond the Darfur-specific frame to cover all persons destabilising Sudan and undermining democratic transition, responding to the SAF–RSF armed conflict that erupted in April 2023. The rule adds new general licenses covering legal-service payments (§ 546.508), African Union transactions (§ 546.511), and agricultural/medical exports (§ 546.513), and introduces an interpretative provision clarifying that entities are not automatically blocked solely because a blocked individual holds a leadership position.

OFAC reissued the Western Balkans Stabilization Regulations (31 CFR Part 588) in their entirety on 29 September 2022, updating the framework that implements Executive Orders 13219 (2001), 13304 (2003), and 14033 (2021). The reissuance added three new definitions, expanded interpretive guidance, incorporated three new general licenses, and explicitly operationalised E.O. 14033's expanded emergency — which extended the Western Balkans sanctions perimeter to cover corruption and anti-democratic destabilisation, not just armed-conflict threats. The regulations apply to persons in or linked to the territory of the former Socialist Federal Republic of Yugoslavia and the Republic of Albania.