Companies should expect the Trump administration to continue to rely heavily on sanctions and sanctions enforcement as a foreign policy tool in 2026, including through new designations to pressure countries in the Western Hemisphere and penalties on gatekeepers that enable evasion, law firms said this month. They also said it's still unclear how the U.S. will approach its sanctions regime against Venezuela, although the administration would likely be able to easily roll back many of those restrictions.

The Office of Foreign Assets Control this week removed two Russians from its Specially Designated Nationals List that it had originally sanctioned for either helping to provide Russia with export controlled items or for operating in Russia's technology sector.

The U.S. government’s “economic statecraft” tools, including export controls and sanctions, are “fragmented” across multiple agencies, and Congress should consider consolidating them into a single entity to increase coordination, focus and accountability, the congressionally mandated U.S.-China Economic and Security Review Commission said in its new 2025 annual report.

The Office of Foreign Assets Control this week sanctioned a network of people and entities for their ties to North Korean money laundering, sanctions evasion and information technology worker fraud. The agency said the network has helped North Korea generate revenue for its weapons programs.

The Office of Foreign Assets Control this week sanctioned more than 50 people, entities and ships for helping move and sell Iranian oil and liquefied petroleum gas, earning the Iranian government "billions of dollars" for its support of terrorism, the agency said. The designations targeted nearly two dozen shadow fleet vessels and their owners, a China-based crude oil terminal, a Chinese refinery and others.

A new interim final rule released by the Bureau of Industry and Security this week introduces a 50% ownership threshold rule for the Entity List and Military End-User List, a change that’s expected to drastically increase the number of companies subject to stringent export licensing restrictions. BIS also is adopting the rule, which it calls the “Affiliates rule,” for export transactions involving certain parties sanctioned by the Office of Foreign Assets Control, which BIS said will “align more closely” OFAC’s 50% rule with the new restrictions under the Export Administration Regulations.

The Office of Foreign Assets Control this week redesignated Garantex, a virtual currency exchange with operations in Moscow, and sanctioned other companies and people that it said are involved in malicious cyber activities.

The Office of Foreign Assets Control sanctioned more than 115 people, entities and vessels for their ties to Iran, including for their part in a “vast shipping empire” controlled by Mohammad Hossein Shamkhani, the son of a top political adviser to the Supreme Leader of Iran, Ali Shamkhani. The designations -- which target a network generating tens of billions of dollars for Iran by moving oil and petroleum products from Iran and Russia to buyers around the world -- represent the U.S.'s largest Iran-related sanctions action since 2018, OFAC said.

The Office of Foreign Assets Control this week designated North Korea-based Korea Sobaeksu Trading Company and three people working closely with the company for helping North Korea evade sanctions. OFAC said Kim Se Un, Jo Kyong Hun and Myong Chol Min are either employed by the company or work with it to help generate revenue for the North Korean government, including by deploying information technology workers overseas to earn money.

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