Chambers Sanctions 2026: OFAC Enforcement Pace Maintained Despite Broader Deregulation

Chambers' 2026 Sanctions practice guide — updated August 17 — notes that sanctions enforcement has been "a notable exception to a broader pull-back in regulatory enforcement activity" under the second Trump administration, with OFAC issuing five enforcement actions in 2026, maintaining pace with the 14 settlements or civil monetary penalties imposed in 2025. The Squire Patton Boggs August briefing documents the full arc of the Iran situation: a temporary sanctions waiver (GL X, June 22 through August 21) authorizing Iranian oil transactions collapsed as hostilities resumed, replaced by the current maximum-pressure posture. The Sanctioning Russia Act of 2026 — introduced in the Senate on July 14 — proposes secondary tariffs of up to 100% on goods from the five largest purchasers of Russian crude oil, with broad bipartisan support but no scheduled floor vote before recess. Law firms advising on any sanctions-adjacent matter should note that OFAC's enforcement posture has not softened with the change in administration; settlements are flowing at historical rates even as other federal enforcement agencies have scaled back.