Sanctions 2026

USA – WASHINGTON, DC Trends and Developments Contributed by: Stephanie L. Connor, Andrew K. McAllister, Matt Rosenbaum and Manny Levitt, Holland & Knight LLP

US Economic Sanctions: Top Trends for 2026 Economic sanctions have dominated the US foreign policy landscape in recent years, and 2026 is no exception. As national security challenges have grown in number and complexity, so too have the regula - tions administered and enforced by the US Depart - ment of the Treasury’s Office of Foreign Assets Control (OFAC), a small but powerful agency at the heart of US sanctions policymaking. Sanctions enforcement has remained a notable exception to a broader pull-back in regulatory enforcement activity during the second Trump Administration, with OFAC issuing five enforce - ment actions in 2026, roughly maintaining pace with the 14 public settlements or civil monetary penalties announced by OFAC in 2025. This article surveys the key enforcement and designation trends shaping US sanctions practice in 2026. A Year of Geopolitical Flux: Rapidly Changing Sanctions Policy Towards Venezuela, Iran, Cuba, and Cartels The sanctions landscape is in significant transition across multiple jurisdictions. The US government’s Venezuela sanctions programme remains in a state of flux following the January 2026 apprehension of President Nicolás Maduro, with the promulgation of multiple general licences authorising activities in the oil and gas, electricity and mining sectors, and relief efforts in the wake of a devastating earthquake, among other transactions. After months of escalating sanctions pressure on the actors involved in the illicit sale of Iranian oil, the United States and Iran entered into a fragile peace agreement calling for the end to all sanctions, and OFAC authorised the temporary pro - duction, delivery and sale of Iranian oil, petrochemical products and petroleum products. The United States also imposed additional sanctions on Cuba, target - ing many foreign companies and banks that have had long-standing operations on the island despite the broad US embargo. Venezuela: Maduro Out, General Licences In The US military captured Venezuelan ruler Maduro in a nighttime raid on 3 January 2026. Hours later, Presi - dent Trump promised that US oil and gas companies would soon return to Venezuela to invest in the dete - riorating infrastructure. Since then, OFAC has issued over a dozen Venezuela-related general licences (GLs)

focused on facilitating, among other things, US invest - ment in the oil and gas, petrochemical, and miner - als sectors. Most recently, OFAC issued a broad GL authorising transactions related to earthquake relief efforts. Key authorisations include GL 46C (permitting estab - lished US entities to buy, sell, transport, store, and refine Venezuelan-origin oil), GL 47A (authorising the export of US-origin diluents to Venezuela), GL 48B (authorising goods, technology, and services nec - essary for oil and gas exploration and production), and GL 52A (authorising established US entities to engage in transactions with Petróleos de Venezuela , SA (“PdVSA”)). GL 51B extended authorisations to permit transactions ordinarily incident and necessary to the exportation, re-exportation, sale, resale, supply, storage, purchase, delivery, or transportation of Ven - ezuelan-origin minerals, including gold, and GL 54A authorised certain transactions with CVG Compania General de Mineria de Venezuela CA (“Minerven”), a Venezuelan state-owned gold-mining company. GL 59 was issued to authorise the supply of certain items and services to the Consorcio Venezolano de Indus- trias Aeronáuticas y Servicios Aéreos , SA (“Convia - sa”), Venezuela’s state-owned airline. More recently, GL 60 authorised earthquake relief efforts through to 23 October 2026. Many of these GLs are subject to various requirements, including that payments to sanctioned Venezuelan entities made in connection with certain GLs be deposited in US government- controlled accounts, as specified in Executive Order (EO) 14373. Most of these new authorisations are subject to nota - ble limitations and conditions, including that they exclude transactions involving persons or entities organised or located in Russia, Iran, North Korea, or Cuba, and in some cases, US or Venezuelan entities owned or controlled by persons in China. Strict report - ing requirements often apply. As such, compliance teams navigating business in Venezuela must care - fully track the conditions and limitations of each GL while ensuring compliance with reporting and record- keeping requirements.

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