Five Key Takeaways From 2025 U.S. Sanctions Enforcement

U.S. sanctions enforcement activity in 2025 underscored the U.S. government’s continued commitment to robust enforcement of the various sanctions programs primarily administered and enforced by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC). OFAC’s 2025 enforcement actions also signaled the agency’s substantive priorities and, perhaps most important, highlighted its compliance expectations.

Although the overall number of enforcement actions remained relatively consistent with recent years (14 actions, up from the 12 actions in 2024 and down from the 17 in 2023), the frequency of OFAC’s announcements accelerated over the course of the year after a slow start. Two actions were announced prior to President Donald Trump’s inauguration on January 20, 2025, while the next action was not announced until mid-June 2025. The dearth of activity in the first months of the administration was likely the result of an effort to align with the new administration’s enforcement priorities and agenda.

As in prior years, OFAC relied predominantly on settlements, resolving 11 matters through settlement agreements. However, OFAC issued three penalty notices in 2025, compared with only one each in 2023 and 2024. Total penalties and settlements in 2025 exceeded $265 million, compared with approximately $49 million in 2024, although over $215 million (or approximately 81%) resulted from a single enforcement action brought against GVA Capital Ltd. (GVA Capital), a San Francisco–-based venture capital firm.

As described below, OFAC’s 2025 enforcement actions highlight several important enforcement trends. There was a continued focus on apparent violations of Russia-related sanctions programs. OFAC also offered its clearest (to date) articulation of its expectations around over-reliance on corporate formalities and provided a more explicit than ever rejection of form over substance when it comes to indirect dealings with sanctioned persons or their property. In addition, OFAC’s 2025 enforcement actions demonstrate an increased willingness to impose liability on individuals and professional intermediaries, as well as enhanced scrutiny of nonbank financial institutions, including digital asset businesses. Across these cases, OFAC repeatedly emphasized that sanctions compliance obligations extend beyond formal corporate boundaries and that structuring transactions or business arrangements to evade or avoid sanctions can lead to violations. Together, these developments provide important guidance for companies, advisers, and financial institutions seeking to assess and mitigate sanctions risk in an evolving regulatory environment.

1. Continued enforcement of Russia-related sanctions, including through actions brought against individuals

In 2025, eight of the 14 actions announced by OFAC related to violations of U.S. sanctions targeting Russia. As efforts to broker an end to Russia’s war in Ukraine have taken center stage, President Trump’s approach to sanctions targeting Russia has not yet fully crystalized.  However, the multiple Russia-related enforcement actions in 2025, including its largest dollar-amount action against GVA Capital, together with the designations of Lukoil and Rosneft in October 2025, appear to signal a continued commitment to Russia sanctions.

Individual liability featured prominently in OFAC’s enforcement of Russia-related sanctions in 2025, with three of the publicly announced enforcement actions directed against individuals. All three matters involved dealings with sanctioned Russian oligarchs or their property or interests in property. Two of the three cases specifically involved Suleiman Kerimov, a wealthy Russian investor, signaling OFAC’s continued focus on high-profile oligarchs and the assets connected to them.

2. Heightened emphasis on advisers and intermediaries as sanctions gatekeepers

A consistent theme emerging from OFAC’s 2025 enforcement actions was the agency’s focus on advisers and intermediaries as gatekeepers. Several of these actions centered on professional service providers whose activities facilitated access to assets or markets, including investment advisers, real estate managers, and attorneys. For example, OFAC imposed the maximum civil monetary penalty in the enforcement action against GVA Capital, reflecting OFAC’s willingness to levy significant penalties on investment and advisory firms that knowingly manage or deploy capital connected to sanctioned persons. According to OFAC, this action “highlights the risks that arise when gatekeepers fail to properly understand the risks associated with the provision of their services.” These cases collectively signal that OFAC views advisers not as peripheral actors but as essential participants whose conduct can either prevent or enable sanctions violations.

3. Enforcement actions against parties that relied on overly formalistic ownership arrangements in their compliance assessments

In addition to, and often in connection with, OFAC’s focus on gatekeepers, 2025 OFAC enforcement activity highlighted the imperative of looking beyond formalistic information about a transaction and the parties involved to understand the indirect touchpoints to sanctioned parties and their property. In these cases, OFAC highlighted the use of intermediaries or proxies, opaque ownership structures, or transactional workarounds designed to create distance from or obfuscate a sanctioned party’s interest.

In an enforcement action announced on December 9, 2025, OFAC settled with an unnamed individual for $1,092,000 over apparent violations arising from the provision of fiduciary services to a trust affiliated with a sanctioned Russian oligarch. The individual, who is a lawyer and former U.S. government official, had received advice from counsel advising that the trust was not blocked property. However, according to OFAC, the SDN retained control over decisions made by the trust through a family member who acted as a proxy in investment-related matters. OFAC stated that this use of a proxy “indicat[ed] that [the SDN] maintained a property interest in the [t]rust.” OFAC also stated that the counsel’s incorrect view regarding the trust’s status as blocked property was predicated on the apparently false understanding that the proxy had no substantive role in the trust’s management or operations.

This enforcement action demonstrates the limits of relying on overly formalistic ownership structures and underscores the importance of interrogating the extent of indirect dealings with an SDN or blocked person or with property or interests in property of such persons. Such dealings are prohibited for a U.S. person in nearly every case. One could argue that this is at odds with — or at least creates a tension with — OFAC’s 50 Percent Rule, a formulaic ownership test created to serve as a presumptive proxy for property of the sanctioned person. While that argument is tempting, we suggest that through this line of cases, what OFAC is reinforcing is that the status of an entity or corporate structure is only the first line of inquiry and needs to be immediately followed by an analysis of what touchpoints — direct and indirect — the SDN or blocked person has to the contemplated activity and what interest, however remote or tangential, the SDN or blocked person has in the assets or corporate structure at issue. After all, OFAC’s various sanctions programs generally prohibit U.S. persons from engaging in any transaction or dealing in which the sanctioned person (SDN or blocked person) has an interest of any nature whatsoever, future, contingent, or otherwise.

4. Focus on nonbank financial institutions

OFAC’s 2025 enforcement reflected a sustained and expanding focus on nonbank financial institutions. Enforcement actions against a digital asset exchange a financial technology company, and a global electronic broker-dealer demonstrate that OFAC’s sanctions compliance expectations apply broadly across the financial ecosystem.

These enforcement actions related to digital asset transactions involving individuals located in comprehensively sanctioned jurisdictions, highlighting the sanctions risks involved in dealing with digital assets at scale. In both cases, OFAC emphasized the importance of implementing effective compliance controls tailored to the risks of the business, including detecting and screening geographic IP address information.

5. Compliance obligations of non-U.S. persons

As in prior years, OFAC continued to bring enforcement actions against non-U.S. persons and foreign subsidiaries of U.S. companies, underscoring the agency’s longstanding position that U.S. sanctions compliance obligations can apply to entities located outside the United States if a U.S. jurisdictional nexus exists. Enforcement actions against ShapeShift AG, Key Holdings and others illustrate this point where the respondent operated outside the United States or through non-U.S. entities, yet OFAC asserted jurisdiction based on U.S. ownership, U.S. person involvement, or reliance on U.S.-based systems and infrastructure. These matters reinforce that companies must ensure sanctions compliance is effectively implemented across global operations.

Sidley’s Global Arbitration, Trade, and Advocacy team is actively advising many of its clients on sanctions-related issues and can assist with navigating this dynamic enforcement landscape.