Five Key Takeaways from 2025 U.S. Sanctions Enforcement

This article examines key enforcement trends from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) in 2025 and what they signal for sanctions compliance. It highlights an enhanced focus on Russia-related sanctions, professional intermediaries as gatekeepers, and nonbank financial institutions, including digital asset businesses. Readers will gain insight into OFAC’s expectations to look beyond formal ownership structures and identify indirect exposure to sanctioned parties. The analysis provides practical considerations for companies, advisers, and financial institutions seeking to assess risk and strengthen compliance programs.