Sanctions in a Snap: Developments in Sanctions

Hughes Hubbard’s “Sanctions in a Snap” provides a clear and concise summary of recent developments from the United States' Office of Foreign Assets Control (OFAC) and is designed to help you quickly assess U.S. economic sanctions compliance risks in light of current government designation and enforcement priorities. 

Monthly Newsletters

March 2026: US Edition

Highlights from March 2026 include unprecedented authorizations involving Russian and Iranian oil, a sanctions advisory providing factors that will lead to aggressive enforcement, and a $1.1 million civil monetary penalty demonstrating the importance of the testing and auditing component of sanctions compliance programs.

February 2026: US Edition

Highlights from February 2026 include the largest civil monetary penalty assessed against an individual, the first civil monetary penalty assessed against an academic institution unrelated to Cuba travel and designations of government officials that signal upcoming economic pressure on Nicaragua.

January 2026: US Edition

Highlights from January 2026 include OFAC authorizations for certain downstream activities involving Venezuelan oil and negotiations for the eventual acquisition of Lukoil’s international assets.

December 2025: US Edition 

Highlights from December 2025 include the third-largest civil monetary penalty ever assessed against an individual and a designation that significantly enhances Colombia-related risk and may portend coming actions targeting Colombia.

November 2025: US Edition

Highlights from November 2025 include the largest-ever OFAC civil monetary penalty issued against an individual and continued responses to the blocking of Lukoil and the Foreign Terrorist Organization designation of the Venezuela-based Cartel de los Soles.

October 2025: US Edition

Highlights from October 2025 include the first Russia-related sanctions imposed by the second Trump administration and U.S. designations targeting the Colombian President.

September 2025: US Edition

Highlights from September 2025 include civil monetary penalties against a freight forwarder and a digital asset platform that set forth clear compliance expectations. Companies should also carefully consider the Mexican cartel and fentanyl-related designation actions described below, which portend significant OFAC focus on Rosarito, Mexico, and online pharmacies.