OFAC centralizes sanctions penalties in new Part 505

On September 25, 2026, the U.S. Treasury Department's Office of Foreign Assets Control made its new Sanctions Penalties Regulations effective, consolidating previously dispersed enforcement procedures and penalty provisions into 31 CFR Part 505. The final rule says it makes no substantive change, but it standardizes the path from pre-penalty notice to final agency action and identifies a maximum IEEPA civil penalty of the greater of $377,700 or twice the transaction value. Counsel should update compliance manuals, investigation protocols and voluntary-disclosure playbooks to cite the new part even where the underlying risk analysis is unchanged. Centralization will also make cross-program comparisons easier for enforcement teams, which may increase expectations that multinational businesses apply consistent escalation standards across business units.