An in-depth March 2026 analysis from Corporate Compliance Insights documents OFAC’s enforcement posture under the second Trump administration: more than 1,300 individuals and entities were sanctioned in 2025, with priority given to counter-narcotics (cartels), Southeast Asia scam networks, Iran’s shadow fleet, and China-linked illicit activity.
However, 2026 has introduced a new complexity — the administration simultaneously issued significant sanctions relief to the Russian oil sector (via a general license covering crude oil on the water as of March 12, 2026) in response to rising oil prices following Iran’s closure of the Strait of Hormuz. For compliance functions, this dual-track approach — escalating designations in some areas while quietly de-listing in others — creates heightened monitoring obligations.
The quiet removal of Russia-linked SDN entities in March 2026 without public explanation underscores that compliance programs cannot rely solely on automated alerts triggered by designation additions; de-listing surveillance and residual risk assessment for removed entities must also be built into compliance workflows. OFAC’s March 31, 2026 sham transaction guidance, which expands the definition of sanctions-relevant ‘property interest’ beyond equity ownership to include economic control and benefit, further elevates compliance risk for institutions operating in high-risk jurisdictions with complex ownership structures.
By FCCT Editorial Team
, an independent military force, and allied militias in Sudan raped several dozen women and girls in West Darfur’s capital, El Geneina, and those fleeing to Chad between late April and late June 2023, Human Rights Watch said today. The assailants appear to have targeted people because of their Massalit ethnicity and, in some cases, because they were known activists.){kind=link}