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Office of Foreign Assets Control (OFAC)

Pillsbury - Global Trade & Sanctions Law

New Cuba Executive Order Creates an IEEPA-Based Sanctions Program and Secondary Sanctions Risk

On May 1, 2026, President Trump issued Executive Order (EO) 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” authorizing sanctions...more

Bradley Arant Boult Cummings LLP

FinCEN’s IRGC Alert: What Financial Institutions Need to Know About Iran’s Oil Smuggling and Shadow Banking Networks

On May 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert designed to help financial institutions identify and disrupt funding streams and procurement networks...more

King & Spalding

Brazil: The Next Front in the Battle Against FTOs? Implications for U.S. and Brazilian Businesses of the Potential Designation of...

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The Trump Administration has made eradication of criminal cartel organizations a top law enforcement priority. Since 2025, several Mexican and other Latin American cartels have been designated Foreign Terrorist Organizations,...more

Holland & Knight LLP

New IEEPA Executive Order Expands Cuba Sanctions Risks

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President Donald Trump on May 1, 2026, issued Executive Order (EO) 14404 to authorize additional sanctions with respect to Cuba pursuant to the International Emergency Economic Powers Act (IEEPA), 50 U.S.C. 1701 et seq. –...more

Blank Rome LLP

Trump Administration Imposes First-Ever Secondary Sanctions on Cuba

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The Trump Administration recently broke new ground in the seven-decade history of U.S. sanctions against Cuba, clearing the way for “secondary” sanctions against non-U.S. persons that engage in certain Cuba-related business....more

DLA Piper

US Treasury issues Venezuela general licenses related to contingent contract negotiations with the Government of Venezuela and...

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On April 14, 2026, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses that expand the scope of authorized activities involving the Government of Venezuela (GoV)...more

Bracewell LLP

FinCEN Alert Spotlights Risk of Evasive IRGC Tactics

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On May 11, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Alert warning financial institutions about the Islamic Revolutionary Guard Corps’ (IRGC) use of facilitators such as...more

The Volkov Law Group

China’s Expanding Countersanctions Framework and the Growing Divide Between Beijing and Washington

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The regulatory and compliance tensions between the United States and China continue to intensify as Beijing expands its legal framework for countering foreign sanctions, export controls, and other forms of what it...more

Friling Law

Semiconductor Export Controls in 2026: Dual-Use Risk, Re-export, Sanctions Exposure, and Compliance Strategy

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Semiconductors are among the most strategically sensitive products in global trade. In 2026, exporting semiconductors is no longer a routine commercial matter: it is a legal, geopolitical, and compliance issue involving...more

WilmerHale

President Trump Issues New Executive Order Significantly Increasing Sanctions Risk for Non U.S. Companies and Financial...

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On May 1, President Trump issued Executive Order 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy” (the “Order”), authorizing the...more

McDermott Will & Schulte

[Webinar] Enforcement Outlook | Sanctions Trends and Emerging Risks - May 20th, 12:00 pm - 1:00 pm EDT

Sanctions enforcement is intensifying amid heightened geopolitical tensions, rapid innovation in digital assets, and unprecedented coordination among US enforcement authorities. The US Department of the Treasury (Treasury),...more

Morrison & Foerster LLP

New Cuba Sanctions Broaden Targeting Authorities—and Risk to Foreign Financial Institutions

On May 1, 2026, the Trump Administration escalated U.S. sanctions on Cuba by issuing Executive Order (E.O.) 14404, which, in part: (i) provides broad authority to designate parties determined to participate in key sectors of...more

Morgan Lewis

New Executive Order Threatens Sanctions Against Non-US Persons Doing Business with Cuba

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The White House’s new executive order substantially expands the scope of an already comprehensive sanctions framework on Cuba, authorizing sanctions on non-US persons doing business with Cuba, as well as non-US...more

Stikeman Elliott LLP

Canada, Cuba, and New U.S. Sanctions

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On May 1, 2026 the White House announced a new executive order titled Imposing Sanctions On Those Responsible For Repression In Cuba And For Threats To United States National Security And Foreign Policy which asserts that the...more

Mayer Brown

United States Targets Dealings of Foreign Companies and Financial Institutions with Cuba

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On May 1, 2026, President Donald Trump signed Executive Order 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy” (the “EO 14404” or...more

Paul Hastings LLP

Potential US Designation of Brazilian Criminal Networks as Terrorist Organizations: Compliance Risks for Companies

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Brazilian and other multinational companies with operations in Latin America can no longer be focused exclusively on exposure to Mexican cartels when considering the risks associated with foreign terrorist organizations...more

Morrison & Foerster LLP

Treasury Proposes New AML/CFT and Sanctions Obligations for Payment Stablecoin Issuers Under the GENIUS Act

On April 8, 2026, the U.S. Department of the Treasury issued a joint notice of proposed rulemaking (the NPRM or Proposed Rule) through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control...more

Wilson Sonsini Goodrich & Rosati

North Korea-Linked Schemes to Obtain Employment in U.S. Tech Companies: What You Need to Know and How to Respond

During the past few years, operatives associated with the Democratic People’s Republic of Korea (North Korea or the DPRK) have reportedly infiltrated hundreds of U.S. companies by fraudulently posing as legitimate remote IT...more

Akerman LLP

U.S. Issues First Designations Under Cuba EO 14404

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On May 7, 2026, the U.S. Departments of State and Treasury took the first concrete enforcement steps under Executive Order 14404, the new Cuba sanctions authority discussed in our prior post. Acting pursuant to EO 14404, the...more

Braumiller Law Group, PLLC

IEEPA Refunds Update with Adrienne Braumiller

Braumiller Law Group Managing Partner Adrienne Braumiller provides an update on the IEEPA refund process....more

Akerman LLP

New Cuba Executive Order Adds Targeted Sanctions Authority While Preserving CACR Licenses

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On May 1, 2026, the President issued a new Executive Order (EO 14404 ) adding targeted sanctions authorities related to Cuba. EO 14404 is issued under several authorities, including the International Emergency Economic Powers...more

Paul Hastings LLP

Caught in the Cartel Crossfire: Rising US Corporate Enforcement Risks for Companies and Financial Institutions

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On April 29, in a remarkable escalation in the United States’ war against drug cartels, the U.S. Department of Justice (DOJ) charged the sitting governor of the Mexican state of Sinaloa, along with other current and former...more

King & Spalding

New Cuba Sanctions Present Increased Sanctions Risk For Foreign Financial Institutions and Foreign Persons Operating in Targeted...

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On May 1, 2026, President Trump issued an Executive Order (the “Executive Order”) under the International Emergency Economic Powers Act (“IEEPA”) authorizing new, targeted sanctions related to Cuba, including blocking...more

Paul Hastings LLP

New US Sanctions Against Cuba Expand Sanctions Risks for Global Multinationals

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In a move that signals a fundamental change in the U.S. regulatory and enforcement risk calculus for multinational companies and financial institutions that operate in or facilitate transactions with the Cuban economy, the...more

Akin Gump Strauss Hauer & Feld LLP

Cuba Executive Order Exposes Non-U.S. Companies and Financial Institutions to Significant New Sanctions Risk

The May 1 Executive Order (E.O.) significantly expands the authority of the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), and the U.S. Department of State to sanction foreign companies and...more

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