OFAC Sanctions: Top 5 Trends For 2026

• Published date: 08 January 2026
• Law Firm: Holland & Knight
• Author: Stephanie L. Connor, Andres Fernandez, Noah Curtin and Molly B. O'Casey

Highlights

• U.S. sanctions policy is facing a complicated year as officials navigate shifting geopolitical pressures, evolving strategies and potential legal constraints. U.S. policymakers must strike the right balance between providing reliable sanctions relief and maintaining leverage over Venezuelan authorities - a difficult task.
• The U.S. will continue to rely on counterterrorism and counternarcotics sanctions to advance its interests in the Western Hemisphere - efforts that are now reinforced by the threat of force.
• U.S. sanctions on Russia remain in place, and in 2026 multinational companies may have to contend with increasing divergence in the measures imposed by the United States, United Kingdom and European Union with respect to the ongoing war in Ukraine. Meanwhile, the U.S. will maintain "maximum pressure" sanctions on Iran, targeting the shadow fleet and facilitators moving Iranian oil and warning of further action if Iran escalates its nuclear or ballistic weapons programs or violently suppresses its critics.
• The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) will intensify its enforcement crackdown on gatekeepers - professionals such as investment advisors accountants, attorneys, and trust and corporate service providers who fail to properly understand and mitigate sanctions risks.

Sanctions have dominated the U.S. foreign policy landscape in recent years, as the U.S. sought to advance its global interests while avoiding costly foreign wars. As national security challenges grew in number and complexity, so too did the regulations administered and enforced by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), a small but mighty agency at the heart of U.S. sanctions policymaking. The expectations for what sanctions could accomplish increased as well, as decision-makers looked to OFAC to end wars and topple regimes with nary a boot on the ground. That changed in 2025, when the Trump Administration embraced a more aggressive approach to foreign policy that combines robust sanctions, broad tariffs and the increasing use of military force.

Those expecting a quiet year in sanctions should think again, as challenges abound. U.S. authorities must recalibrate Venezuela sanctions to encourage investment while maintaining leverage, balance the aggressive use of sanctions and tariffs against competition from U.S. adversaries such as China, coordinate with allies, counter an evasive maritime shadow...