OFAC Sanctions: Top 5 Trends for 2026

Sanctions have dominated the U.S. foreign policy landscape in recent years, as the U.S. sought to advance its global interests while avoiding costly foreign wars. As national security challenges grew in number and complexity, so too did the regulations administered and enforced by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), a small but mighty agency at the heart of U.S. sanctions policymaking. The expectations for what sanctions could accomplish increased as well, as decision-makers looked to OFAC to end wars and topple regimes with nary a boot on the ground. That changed in 2025, when the Trump Administration embraced a more aggressive approach to foreign policy that combines robust sanctions, broad tariffs and the increasing use of military force.

Those expecting a quiet year in sanctions should think again, as challenges abound. U.S. authorities must recalibrate Venezuela sanctions to encourage investment while maintaining leverage, balance the aggressive use of sanctions and tariffs against competition from U.S. adversaries such as China, coordinate with allies, counter an evasive maritime shadow fleet and defend against any number of legal challenges. Indeed, if the U.S. Supreme Court decides that the International Emergency Economic Powers Act (IEEPA) – the statutory foundation for most sanctions – does not authorize President Donald Trump's expansive tariffs, then U.S. sanctions will be forced to carry even more weight in the months ahead.

This Holland & Knight alert discusses the top five trends in OFAC sanctions that are expected in 2026.

Venezuela: A Precarious Balance

After a decade of relying on sanctions to pressure Venezuela's brutal regime – with limited success – U.S. military forces captured Venezuelan ruler Nicolás Maduro in a nighttime raid on January 3, 2026. Hours later, with Maduro en route to face charges in New York, President Trump promised that U.S. oil and gas companies would soon return to Venezuela to invest in the deteriorating infrastructure. Such investments will require powerful incentives and immediate sanctions relief – a tall order given the significant time and resources required to bring Venezuela's systems back online.

Sanctions relief must address three immediate challenges. First, the U.S. must figure out what to do with the Venezuelan crude sitting idle on tankers due to the recent blockade, which cratered Venezuelan exports. Second, U.S. policymakers must strike the right balance between providing reliable sanctions relief for U.S. companies and maintaining leverage over Venezuelan authorities – a difficult task given that U.S. companies will be reluctant to rely on short-term sanctions relief, and removing sanctions altogether would dilute America's considerable leverage over the Venezuelan regime. Third, even with sanctions relief, financial institutions and insurers will be leery of reengaging in the country until the political and economic situation has stabilized. U.S. businesses are likely to be even more wary of investing in Venezuela, given the U.S. government's history of offering and revoking sanctions authorizations.

Because these measures were imposed by executive action (not legislation), they can be licensed, suspended or revoked by the president at any time – unlike the Syria sanctions removed earlier this year, which had been mandated in part by the U.S. Congress.

The Wild Western Hemisphere: Risks Expand

The U.S. issued strongly worded warnings to other leaders in the Western Hemisphere in the immediate aftermath of Maduro's capture, threatening the leaders of Colombia and Cuba with similar fates, urging Mexico to get its "act together" in the fight against drug cartels and reiterating an interest in annexing the Danish territory of Greenland. The operation to oust Maduro is the most recent example of the U.S. administration's focus on the Western Hemisphere – a "Trump Corollary" to the Monroe Doctrine designed to discourage mass migration to the U.S., combat narcotics trafficking and keep U.S. adversaries such as China at bay.

In 2026, the U.S. will continue to rely on counterterrorism and counternarcotics sanctions to advance its security interests in the region – efforts that are now reinforced by the threat of kinetic action. The Trump Administration has already designated numerous cartels and gangs as Foreign Terrorist Organizations (FTOs), creating additional secondary sanctions risks in addition to criminal and civil liability. In October 2025, OFAC designated Colombia's sitting president, Gustavo Francisco Petro Urrego, under its counternarcotics authorities, increasing the risks for U.S. persons engaging with the Colombian leader. The Trump Administration also revoked the prior administration's rescission of Cuba's designation as a State Sponsor of Terrorism and reimposed sanctions on entities linked to Cuba's military, intelligence or security services.

Russia and Ukraine: All Eyes on Oil

Although Moscow quickly condemned U.S. strikes on Venezuela, its longtime ally, it remains to be seen how the U.S. focus on the western hemisphere will impact ongoing negotiations to resolve the war in Ukraine. As set forth in the National Security Strategy, the U.S. remains committed to the resolution of hostilities in Ukraine and "strategic stability" with Russia. U.S. sanctions on Russia remain in place, and in 2026, multinational companies may be forced to contend with a divergence in the measures imposed by the U.S., United Kingdom and European Union with respect to Russia and Ukraine.

Notably, the potential deluge of Venezuelan crude into a saturated market may create new opportunities for actions against Russia's oil sector, which is struggling in the wake of sanctions imposed on two of Russia's largest energy firms, OJSC Rosneft and PJSC Lukoil. All entities owned 50 percent or more, directly or indirectly, by the sanctioned companies are also considered to be blocked, including a sprawling global network of international subsidiaries and assets. Concurrent with the designations of Rosneft and Lukoil, OFAC issued general licenses authorizing transactions ordinarily incident and necessary to the wind-down of activities involving the blocked entities, as well as for the contingent divestment of their non-Russian assets. These actions kickstarted numerous private and public sector efforts to divest the international assets – negotiations that will continue in the year ahead.

Iran: Targeting the Shadow Fleet

In Iran – as in Venezuela – the Trump Administration has backed up strong sanctions pressure with the use of military force. The Trump Administration reimposed "maximum pressure" sanctions on Iran in early 2025, targeting a shadow fleet responsible for shipping Iranian oil, as well as numerous facilitators and Chinese teapot refineries. Although Iran scarcely appeared in the administration's National Security Strategy, President Trump warned in late December 2025 that there would be consequences if Iran rebuilds its ballistic or nuclear weapons programs and threatened intervention if Iran's leadership kills protestors who have taken to Iran's streets.

Although Iran's economy has weathered years of U.S. sanctions, its currency is currently in freefall despite ongoing exports of crude oil (mostly to China). In the year ahead, the U.S. will continue to tighten the screws on the shadow fleet of tankers and facilitators that enable that trade, including dark fleet crude carriers previously engaged in Venezuela.

Enforcement and Compliance: Increasing Risks for Gatekeepers

In 2026, OFAC will intensify its enforcement crackdown on gatekeepers – professional service providers such as investment advisors, accountants, attorneys and providers of trust and corporate services – who fail to properly understand and mitigate sanctions risks associated with their provision of services. In 2025, numerous enforcement actions highlighted the risks of transacting with entities whose structures obscured a blocked person's interest – a term that OFAC defines broadly – and OFAC repeatedly emphasized that gatekeepers must undertake robust diligence that looks beyond mere corporate formalities. OFAC enforcement actions targeted players in the private equity, venture capital, real estate and legal markets – a focus that will continue in the year ahead.

Conclusion

In response to the heightened geopolitical, regulatory and enforcement risks, companies should familiarize themselves with the relevant red flags for sanctions evasion, evaluate their risk exposure and, where necessary, consider updating their compliance policies and procedures appropriately.

For more information on the implications of these recent geopolitical shifts, enforcement actions and regulatory changes, or for assistance in conducting a risk assessment or developing compliance policies and procedures, please contact the authors or another member of Holland & Knight's International Trade Group, Latin America Team or Anti-Money Laundering Team.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.