Sanctions 2026

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

Sanctions Whistle-Blower Programme Takes Shape In February 2026, FinCEN launched a dedicated web - page to confidentially accept whistle-blower tips on money laundering, sanctions violations, and other illicit finance activity, which follows an announcement in May 2025 by the US DOJ that identified sanctions evasion as a priority area for whistle-blower tips under its expanded Criminal Division Corporate Whistle - blower Awards Pilot Program. On 1 April 2026, FinCEN’s publication of its Notice of Proposed Rulemaking established a comprehensive framework for its whistle-blower award and protec - tion programme, as mandated by the Anti-Money Laundering Act of 2020 and the Anti-Money Laun - dering Whistleblower Improvement Act of 2022. The programme covers violations of IEEPA, under which most OFAC sanctions are administered, meaning that sanctions violations of nearly any type are within the programme’s scope. The proposed programme would provide whistle-blowers with 10–30% of col - lected monetary sanctions in successful enforcement actions exceeding USD1 million, with a presumptive award at the 30% level when the total collected sanc - tions yield an award of USD15 million or less. The proposed rule also includes a waiting period intended to give companies the opportunity to assess potential violations and consider submitting a voluntary self- disclosure.

front companies, commercially implausible pricing, and documents referencing ports that do not export the stated commodity. A substantial portion of sanctions designations across several sanctions programmes have targeted ves - sels, companies, and individuals directly or indirectly involved in the shadow fleet ecosystem. Sanctions targets in 2026 have included dozens of vessel ser - vice providers, shadow banking entities (eg, foreign currency exchanges), trading houses, vessel manage - ment and chartering companies, port terminal opera - tors, independent oil refineries, and oil and gas trading firms, along with key management personnel at these entities. Geographically, the targets of these sanctions have reportedly been based or have operated in, Sin - gapore, Hong Kong, China, the UAE, Oman, Iraq, the EU, the British Virgin Islands, and other locations in South and South-East Asia. Advisories from both OFAC and FinCEN have empha - sised that companies in the maritime and energy trad - ing sectors should continuously monitor new trends in sanctions evasion and proactively adapt compliance protocols to address these risks. The use of stable - coin payments has been a major new area of red flags highlighted by FinCEN. Furthermore, in announcing a significant enforcement action against an Indian com - pany that purchased Iranian oil, OFAC noted that the majority of the vessels involved in the apparent viola - tions were later designated by OFAC, underscoring that the absence of a vessel from the SDN List does not immunise it from liability for transactions involving Iranian- or Russian-origin commodities transported by that vessel.

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