- Key Takeaway #1: The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule (the “Rule”), effective September 25, 2026, creating the “Sanctions Penalties Regulations” under 31 CFR Part 505: the agency’s first-ever single, unified codification of civil and criminal penalty rules applicable across multiple sanctions programs.
- Key Takeaway
FinCEN Finalizes BOI Reporting Rule: What U.S. Companies Need to Know
Key Takeaway: Domestic reporting companies—meaning entities formed under the laws of any U.S. state or Tribal jurisdiction—have no beneficial ownership information reporting obligations to FinCEN under the final rule.
What happened: On August 14, 2026, the Financial Crimes Enforcement Network (“FinCEN”) published a final rule revising its previous rules implementing the Beneficial Ownership Information (“BOI”)
Following the Money: FinCEN Maps the Financial Footprint of Human Smuggling
What You Need to Know
Key takeaway #1: On August 13, 2026, FinCEN issued a Financial Trend Analysis showing 67,540 Bank Secrecy Act (BSA) reports filed between 2023 and 2025 involved more than $4.9 billion in reported suspicious activity potentially related to human smuggling.
Key takeaway #2: Money services businesses (MSBs) filed approximately 97%
Reminder: 2026 OFAC Annual Report of Blocked Property Due September 30, 2026
The deadline to file OFAC’s Annual Report of Blocked Property (“ARBP”) is approaching fast. All “U.S. persons” — including U.S. financial institutions, companies, and individuals — who hold property blocked pursuant to any OFAC sanctions program should take a moment to assess their reporting obligations, as set forth in 31 C.F.R. § 501.603.
This
OFAC Expands Venezuela Sanctions Relief: New General Licenses 56 and 57, and Guidance on Reporting Obligations
On April 14, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela” (GL 56), and Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals” (GL
OFAC Sanctions Cartel-Linked Casinos and Financial Enablers on the Southern Border
- The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and entities tied to Cartel del Noreste (CDN)—one of Mexico’s most violent drug trafficking organizations—including two CDN-affiliated casinos used for money laundering and drug operations near the U.S.-Mexico border.
- OFAC’s actions are the latest examples of a broader
Eight Takeaways After Seven Weeks of OFAC’s Six, wait Seven, New and Updated General Licenses for Venezuela
Introduction
Over the last two months, OFAC has issued and updated a series of general licenses and Frequently Asked Questions (FAQs) that allow for a variety of activities in the Venezuela oil, gas, petrochemical products, electricity, and gold sectors when they involve persons sanctioned pursuant to the Venezuela sanctions regulations, including the Government of Venezuela
Key Takeaways from a Consequential Month of Russia-Related Sanctions
The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions the past month, including the Trump Administration’s first sanctions directly imposed on Russia. These coordinated actions—which particularly target the Russian energy sector—indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those
Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System
Reflecting the administration’s continued focus on transnational cartels, on June 25, 2025, FinCEN identified three Mexican financial institutions as “primary money laundering concerns,” and imposed restrictions on U.S. financial institutions from engaging in transactions with these entities.
Click here to continue reading the full version of this alert.
Client Alert: U.S. Departments of State and Treasury Issue Immediate Sanctions Relief for Syria
On May 23, 2025, the U.S. Departments of State (“State”) and the Treasury (“Treasury”) took actions that resulted in immediate sanctions relief for Syria. Specifically, Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”) pursuant to the Syrian Sanctions Regulations (“SySR”), the Weapons of Mass Destruction Proliferators Sanctions Regulations (“NPWMD”), the