USA Trends and Developments Contributed by: Bruce G. Paulsen, Brian Maloney and Hannah Thibideau, Seward & Kissel LLP
Introduction The first half of 2026 has seen rapid and dynamic geopolitical developments, including notable shifts concerning US foreign policy and national security priorities. These developments reflect the complexity of sanctions compliance for entities and individuals navigating a landscape that is evolving in real time. While sanctions regulations are evolving in several regions, it is essential for all entities and individuals subject to US sanctions law to monitor these changes to remain in compliance. With respect to Iran, the United States’ “maximum pressure” campaign has entered a period of uncer - tainty following the war and the subsequent memo - randum of understanding signed in June 2026. While recent measures under the memorandum may sig - nal temporary sanctions relief, the durability of these changes remains contingent on ongoing negotiations over Iran’s nuclear programme and broader regional stability. In Venezuela, the removal of Nicolás Maduro has prompted a significant shift in US sanctions policy, with the Office of Foreign Assets Control (OFAC) of the US Department of Treasury moving quickly to author - ise expanded activity in the country’s energy, mining and financial sectors. These developments reflect a broader effort to encourage economic re-engagement and investment, while still imposing strict compliance obligations and due diligence expectations on market participants. Meanwhile, trade controls against China continue to expand through legislative and executive action, par - ticularly for investments by US persons into the region. The enactment of the Comprehensive Outbound Investment National Security Act (the “COINS” Act) in December 2025 also promises regulatory changes that will broaden restrictions on US investments in new categories of sensitive technologies and to addi - tional countries of concern. This indicates that the US government may use investment controls as a more widespread instrument of leverage in conjunction with traditional sanctions programmes and other economic trade controls, such as tariffs.
Sanctions on Russia have held in place as the conflict in Ukraine persists, with ongoing enforcement actions targeting the energy sector and extending existing authorisations through general licences. These meas - ures illustrate continued reliance on sectoral sanctions and time-limited relief mechanisms as the Administra - tion continues to put pressure on Russia’s energy sec - tor, while also allowing select transactions to proceed. Finally, the Treasury Department’s OFAC modernisa - tion efforts signal a shift towards a more streamlined, focused framework. By removing outdated desig - nations and reassessing the effectiveness of exist - ing sanctions programmes, OFAC has taken steps towards refining its regulatory approach and enabling a more efficient allocation of compliance resources while maintaining pressure on current national security threats. Iran: Will “Maximum Pressure” Continue After the War? On 4 February 2025, the Trump Administration issued a national security memorandum directing members of the new Administration’s cabinet and other eco - nomic advisers to review various aspects of the Unit - ed States’ foreign policy towards Iran, with a focus on “impos[ing] maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups”. Approximately a year later, on 28 February 2026, the United States and Israel launched strikes across Iran, killing Iran’s supreme leader, Ayatollah Ali Khamenei. Since then, the Trump Administration’s campaign of maximum pressure has continued. However, on 17 June 2026, President Trump and Pres - ident Masoud Pezeshkian of Iran signed a memoran - dum of understanding (MOU) aiming to end the war between the two countries. The MOU included terms regarding reopening the Strait of Hormuz, a USD300 billion plan for Iran’s “reconstruction”, and a com - mitment by the United States to terminate sanctions on Iran. The MOU called for an end to hostilities and started a 60-day negotiating clock to reach a final deal on the future of Iran’s nuclear programme. This MOU has had an immediate impact on sanc - tions: on 22 June 2026, OFAC issued a broad general
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