OFAC’s new Sanctions Penalties Regulations, effective September 25, 2026, consolidate the enforcement procedures and penalty provisions for IEEPA- and UNPA-based sanctions programs in 31 C.F.R. Part 505. Although OFAC describes the rule as non-substantive, it has immediate compliance consequences: entity settlements and civil penalties must be disclosed publicly at least monthly; respondents have 30 days to contest a Pre-Penalty Notice or initial Finding of Violation; and criminal violations now carry an express willfulness standard, while civil liability remains strict.
This item is available in full to subscribers.
To continue reading, you will need to either log in to your subscriber account, below, or purchase a new subscription.
If you are a current subscriber, and had an account on our previous site, you already have an account. If you have not yet logged into our new site, click here to reset your password.
Otherwise, click here to view your options for subscribing.
Please log in to continue |