OFAC Sanctions Enforcement Priorities in 2025-26
The through-line in OFAC‘s 2025 enforcement priorities isn’t a single country or industry — it’s the expectation that companies look past legal formalities to the underlying economic reality of their relationships. Paul Weiss attorneys Jessica Carey, Roberto Gonzalez, Nicole Succar and Sam Kleiner survey a year of sanctions activity spanning cartels, scam networks and Russian oil majors, and identify what compliance teams should be revisiting heading into 2026.
In the first year of the second Trump Administration, Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on over 1,300 individuals and entities, prioritizing certain areas like cartels and counternarcotics, Southeast Asia-based scam networks, Iran’s shadow fleet and shadow banking networks and China. Although this number of designations is substantial, it is less than the number of designations each year from 2022-24, when Russia-related sanctions increased significantly.
Enforcement Actions in 2025
For most of 2025, the Trump Administration refrained from sanctioning new Russian entities while it prioritized negotiations to end the conflict; but in October 2025, the administration sanctioned major Russian oil companies Rosneft and Lukoil and threatened additional sanctions if peace was not achieved. 2025 also saw the lifting of comprehensive sanctions on Syria, while Venezuelan sanctions are in a state of transition following the apprehension of President Nicolás Maduro.
On the enforcement front, OFAC took 14 public enforcement actions in 2025, with a focus on violations of Russian sanctions by US non-bank “gatekeepers,” such as private equity funds, real estate companies and attorneys. The total value of these enforcement actions was $266 million, with $215 million of that total representing OFAC’s penalty notice issued against GVA Capital.
Sanctions Program Developments
As part of the administration’s multi-agency effort to target cartels, OFAC designated numerous individuals and entities associated with cartels’ money-laundering and revenue diversification efforts, including designations focused on the cartels’ huachicol fuel theft and crude oil smuggling, arms trafficking, human trafficking, extortion and timeshare fraud schemes. OFAC continued this focus in early 2026, designating numerous persons related to a timeshare fraud network led by a Mexican cartel. The actions underscored that the administration is focused not only on the cartels’ narcotics activities but also on their alternative revenue sources.
Notably, in February 2025, the State Department designated a number of Mexican, Salvadoran and Venezuelan drug cartels — almost all of which were already sanctioned by OFAC under counternarcotics authorities — as foreign terrorist organizations (FTOs), and specially designated global terrorists (SDGTs). These unprecedented FTO designations expose companies and financial institutions that operate in Latin America where cartels play significant roles in the licit and illicit economies to heightened risks of criminal and civil liability. For its part, the DOJ has prioritized the “total elimination” of cartels and transnational criminal organizations and has reassigned prosecutors and made organization changes to further this priority.
Utilizing its counter-narcotics authorities, OFAC also targeted the regimes of Venezuela and Colombia. In October 2025, OFAC added Colombian President Gustavo Francisco Petro Urrego to the SDN List and in December 2025 it imposed sanctions on associates of then-President Maduro (himself sanctioned since 2019).
Original Article: The State of OFAC Sanctions Enforcement in 2025-26 — Corporatecomplianceinsights