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ARTICLE · 15 JULY 2025

Lessons From The First Four OFAC Sanctions Enforcement Actions Under The Second Trump Administration

Foley Hoag LLP
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After a five-month pause, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") has announced four very substantial enforcement actions, summarized below...

United StatesInternational Law
Anthony D. Mirenda
Anthony D. Mirenda
Luciano Racco
Luciano Racco
Shrutih Tewarie
Shrutih Tewarie
Zihan Mei
Zihan Mei
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Key Takeaways:

  • After a 5-month pause, OFAC recently announced four sanctions enforcement actions, making clear it is rigorously enforcing sanctions violations across a wide range of programs (including Russia, Iran, Venezuela and Cuba), especially in cases involving willful misconduct, senior management involvement and failures in compliance and cooperation with OFAC. Interestingly, all of the announced enforcement actions by OFAC involved U.S. companies.
  • In June 2025, OFAC announced the imposition of a $215,988,868 penalty on GVA Capital Ltd., a California-based venture capital firm, for willful violations of Russia/Ukraine-related sanctions and failure to comply with an OFAC subpoena.

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