OFAC Sanctions Will Intensify Amid Global Tensions in 2026

International Trade attorneys Stephanie Connor and Tahlia Townsend, along with Financial Services attorney Andres Fernandez, authored a Law360 article on how U.S. sanctions are shifting under a more aggressive foreign policy approach that pairs Office of Foreign Assets Control (OFAC) measures with tariffs and greater use of military force. They explain that 2026 sanctions risks are likely to grow as the U.S. recalibrates its restrictions on Venezuela-based individuals and entities to spur investment while preserving leverage, targets maritime "shadow fleets" and manages coordination with allies on Russia-related measures. They additionally flag expanded designations, continued pressure on Iran's oil trade and tougher enforcement against gatekeepers and hidden ownership.

The attorneys also published a Holland & Knight alert on this topic.

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