2026 Enforcement Trends to Expect in Maritime and Int'l Trade

Maritime attorney Sean Pribyl, International Trade attorney Stephanie Connor and Litigation attorney Ashley Akers co-authored a Law360 article previewing federal enforcement trends affecting the maritime and trade sectors. The article focuses on three areas: U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) sanctions on the shipping industry, U.S. Department of Justice (DOJ) Tariff Fraud Task Force activity and U.S. Coast Guard initiatives. The authors elaborate on sanctions targeting shipping networks used by Iranian oil-associated entities, OFAC guidance on detecting and mitigating sanctions evasion, and tips for building compliance programs to address emerging threats. They also summarize notable cases handled by the DOJ's task force, such as a False Claims Act lawsuit accusing a company of evading duties on products imported from China, and list government priorities for 2026, including heightened liability exposure for intermediaries and use of data analytics and supply chain tracking. Finally, the attorneys highlight ways organizations can prepare for an expected uptick in Coast Guard enforcement: conducting regular risk assessments, engaging with federal agencies and implementing robust internal controls. Overall, they advise, stakeholders should expect increased regulatory scrutiny and interagency collaboration, but proactive compliance strategies provide an effective response to manage risk and maintain operational resilience.

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