USA Trends and Developments Contributed by: Bruce G. Paulsen, Brian Maloney and Hannah Thibideau, Seward & Kissel LLP
have not delivered “measurable outcomes”, while also prioritising sanctions that have a discernible economic and national security impact. In May 2026, OFAC removed sanctions on 76 “outdat - ed” targets, which were removed off the SDN List. The removals were cited as part of the Treasury Depart -
ment’s modernisation initiative. The outdated entries included deceased individuals, scrapped or decom - missioned vessels, persons designated as part of illicit financial networks that are no longer in operation, and individuals who were designated more than ten years ago who lack sufficient identifiers for continued screening and do not appear to be an ongoing threat.
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