U.S. Office of Foreign Assets Control (OFAC) Archives - Customs & International Trade Law Firm

OFAC Extends Cuba Sector Sanctions Risk to Electronics, Manufacturing, Marine, and Technology
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OFAC Extends Cuba Sector Sanctions Risk to Electronics, Manufacturing, Marine, and Technology
Cuba, International Trade, U.S. Office of Foreign Assets Control (OFAC)

OFAC Extends Cuba Sector Sanctions Risk to Electronics, Manufacturing, Marine, and Technology

On November 5, 2026, the Office of Foreign Assets Control (OFAC) determined that the sector-based sanctions authority in Executive Order (E.O.) 14404 applies to the electronics, manufacturing, marine, and technology sectors of the Cuban economy. Any foreign person that the State Department or Treasury determines operates, or has operated, in those sectors is now exposed to blocking sanctions. U.S. importers, exporters, carriers, and logistics providers are affected through their foreign suppliers, vessel operators, and customers, which is where screening and contract reviews should start.

KEY TAKEAWAYS

Effective November 5, 2026, OFAC determined that the sector-based sanctions authority in Section 2(a)(i)(A) of E.O. 14404 applies to the electronics, manufacturing, marine, and technology sectors of the Cuban economy.
These four sectors join the five named in the Executive Order itself: energy, defense and related materiel, metals and mining, financial services, and security.
Operating in a listed sector does not trigger sanctions automatically. Sanctions attach only when the State Department or Treasury makes a determination about a specific foreign person (OFAC FAQ 1256).
The same day, the State Department designated Cuban and third-country companies, individuals, and tanker vessels under E.O. 14404, including two Chinese electronics companies.
Importers, exporters, carriers, and logistics providers should […]

By Jennifer Diaz|2026-11-10T12:16:05-05:00November 10, 2026|Cuba, International Trade, U.S. Office of Foreign Assets Control (OFAC)|0 Comments

OFAC’s Extreme Networks Settlement: Why Screening Names Alone Is Not Enough
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OFAC’s Extreme Networks Settlement: Why Screening Names Alone Is Not Enough
U.S. Office of Foreign Assets Control (OFAC)

OFAC’s Extreme Networks Settlement: Why Screening Names Alone Is Not Enough

On October 27, 2026, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $1,529,685 settlement with Extreme Networks, Inc. for nine apparent violations of the Ukraine-/Russia-Related Sanctions Regulations. The customer was a Russian missile and air defense manufacturer that was not on the SDN List when the transaction closed, but was deemed a blocked person by OFAC at all times by virtue of its majority owner being a a designated entity. Exporters, acquirers, and any company selling through foreign distributors in high-risk markets should test whether their screening looks past the name on the order.

KEY TAKEAWAYS

OFAC treated a Russian defense manufacturer as a blocked person at all relevant times because a designated Russian state-owned company held majority ownership, even though the manufacturer itself was not added to the SDN List until June 2022, after the conduct ended.
According to OFAC, Extreme Networks’ U.S.-led compliance function reviewed the 2018 purchase agreement that named the manufacturer as an end user, and screened all nine later purchase orders, without identifying the blocked party.
OFAC determined the nine apparent violations were egregious and voluntarily self-disclosed. The settlement is $1,529,685, against a base penalty of $1,699,650.
OFAC’s compliance guidance in this case centers on three areas: sanctions diligence in acquisitions (including asset purchases), […]

By Jennifer Diaz|2026-10-29T12:52:53-04:00October 29, 2026|U.S. Office of Foreign Assets Control (OFAC)|0 Comments

U.S. Government Continues to Signal Sanctions Enforcement as a Priority: Three Recent Cases
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U.S. Government Continues to Signal Sanctions Enforcement as a Priority: Three Recent Cases
U.S. Department of Justice (DOJ), U.S. Office of Foreign Assets Control (OFAC)

U.S. Government Continues to Signal Sanctions Enforcement as a Priority: Three Recent Cases

The U.S. government continues to demonstrate its commitment to enforcing sanctions and export control laws, with three recent announcements from the Department of Justice (DOJ) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) highlighting the risks businesses and individuals face when compliance obligations are overlooked.

Between October 9 and October 14, 2026, federal authorities announced a five-year prison sentence involving North Korean sanctions violations, a settlement with an international freight forwarding company, and an $11.6 million settlement with one of the nation’s largest banks.

Although the cases involve different industries and circumstances, they reinforce a common message: sanctions enforcement extends across the global supply chain.

DOJ: Five-Year Prison Sentence for North Korean Sanctions Violations

On October 14, 2026, DOJ announced that Sasa Micev, a Bosnian national and international arms dealer, was sentenced to 60 months in federal prison after pleading guilty to violations of the International Emergency Economic Powers Act (IEEPA) and North Korean Sanctions Regulations.

According to DOJ, Micev conspired with others to broker the purchase of North Korean SA-18 Igla portable surface-to-air missiles without the required authorization from OFAC. The scheme involved discussions about pricing, efforts to obtain the weapons using falsified documentation, and a meeting in Turkey to complete the transaction. The proposed sale ultimately fell through following a pricing dispute.

OFAC: Freight Forwarder Agrees to $175,015 Settlement

On October 9, 2026, OFAC announced a $175,015 settlement […]

By Jennifer Diaz|2026-10-15T17:10:37-04:00October 15, 2026|U.S. Department of Justice (DOJ), U.S. Office of Foreign Assets Control (OFAC)|0 Comments

Getting Off the SDN List: A Practical Guide to OFAC’s Administrative Reconsideration Process
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Getting Off the SDN List: A Practical Guide to OFAC’s Administrative Reconsideration Process
Export, U.S. Office of Foreign Assets Control (OFAC)

Getting Off the SDN List: A Practical Guide to OFAC’s Administrative Reconsideration Process

Landing on the Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List) is one of the most consequential things that can happen to a company or individual doing business in or with the United States. Assets are frozen, U.S. persons are barred from dealing with you, and banking relationships evaporate almost overnight.

The good news is that SDN designations are not necessarily permanent. OFAC maintains a formal process – administrative reconsideration – for petitioning to have a person, entity, or piece of property removed from an OFAC-administered sanctions list. This article walks through how that process works, what to expect at each stage, and where clients most often stumble.

Step One: Confirm You’re Using the Right Process

Before filing anything, it’s worth pausing to confirm which removal process actually applies to your situation, because OFAC’s administrative reconsideration process is not a one-size-fits-all remedy.

You are the designated party. If you, your organization, or your property appear on an OFAC-administered list because OFAC itself made the designation, the administrative reconsideration process under 31 C.F.R. § 501.807 is the correct path, and it runs through OFAC’s Reconsideration Portal.
The designation was made by the State Department. Some names appear on OFAC-administered lists because the Department of State designated them (for example, under certain terrorism-related authorities). Removal in those cases goes through […]

By Jennifer Diaz|2026-08-27T16:16:18-04:00August 27, 2026|Export, U.S. Office of Foreign Assets Control (OFAC)|0 Comments

New OFAC Advisory: Signs of Sham Transactions and Sanctions Evasion
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New OFAC Advisory: Signs of Sham Transactions and Sanctions Evasion
Enforcement, International Law, International Trade, Investigation, U.S. Office of Foreign Assets Control (OFAC)

New OFAC Advisory: Signs of Sham Transactions and Sanctions Evasion

On March 31, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an important advisory addressing the growing use of sham transactions to evade U.S. sanctions. The guidance highlights how sanctioned individuals and entities often attempt to disguise their continuing interest in property through opaque legal structures, proxies, and other intermediaries. OFAC’s message is clear: transactions that merely appear to transfer ownership but do not genuinely extinguish a blocked person’s interest remain prohibited.

What OFAC Defines as a “Sham Transaction”

Sham transactions occur when blocked persons “give up their property on paper only,” while continuing to benefit from or control the asset. These arrangements often involve:

Proxies, straw owners, or front companies acting on behalf of sanctioned individuals.
Opaque legal structures, including multi‑layered LLCs, partnerships, or trusts.
Transfers to family members or close associates who may serve as facilitators.
Commercially unreasonable transfers, such as those lacking adequate consideration.
Continued use or control of the asset by the blocked person after the purported transfer.

Pro Tip: Look beyond legal formalities and identify the economic realities of the transaction.

Red Flags Identified by OFAC

The advisory outlines several indicators that a transaction may be a sham designed to evade sanctions. These include:

By Jennifer Diaz|2026-04-07T16:53:01-04:00April 3, 2026|Enforcement, International Law, International Trade, Investigation, U.S. Office of Foreign Assets Control (OFAC)|0 Comments

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