Sanctions Update -
Hughes Hubbard's "Sanctions in a Snap" is intended to provide a clear and concise summary of recent developments from the Office of Foreign Assets Control (OFAC). We hope you find it helpful in assessing U.S. economic sanctions compliance risk against current U.S. government designation and enforcement priorities.
Highlights from September 2025 include civil monetary penalties against a freight forwarder and a digital asset platform that set forth clear compliance expectations. Companies should also carefully consider the Mexican cartel and fentanyl-related designation actions described below, which portend significant OFAC focus on Rosarito, Mexico, and online pharmacies.
In total, OFAC issued 123 designations and identified four vessels as blocked property in September. Those designations primarily focus on Mexico, Yemen, the United Arab Emirates (UAE) and China.
Please see full publication below for more information.
