March 16, 2026

Jessica Carey, Roberto Gonzalez, Nicole Succar and Sam Kleiner Author Article on OFAC Sanctions Enforcement Trends

Litigation partners Jessica Carey, Roberto Gonzalez and Nicole Succar, and counsel Sam Kleiner published an article in Corporate Compliance Insights about sanctions enforcement actions taken by the Office of Foreign Assets Control in 2025 and enforcement expectations for 2026. In “The State of OFAC Sanctions Enforcement in 2025-26,” published on March 16, the authors discuss OFAC’s recent focus on cartels and counternarcotics, Southeast Asia-based scam networks, and certain nation-state-related activities.

“We expect that the administration will continue to utilize sanctions as a primary instrument for advancing its foreign policy and national security objectives,” the authors say. “As such, financial institutions and other companies (including those that are largely domestic) should consider refreshing their risk assessments and their sanctions controls in light of the administration’s priorities.”

» read the article