OFAC Streamlines Sanctions Regulations

The US Office of Foreign Assets Control (OFAC) has published two final rules designed to consolidate and streamline its regulations. These updates do not substantively change applicable law, but are intended to improve readability and promote consistency across OFAC’s regulations.

OFAC’s regulations (which are found in Title 31, Chapter V of the US Code of Federal Regulations), are currently divided into “Parts.” Each Part generally corresponds to one of the various sanctions programs administered by OFAC, along with a few Parts which address administrative matters. Before this update, many of the program-specific Parts included unique references to penalties that could be applied for violating those Parts, some of which did not fully reflect applicable law.

On September 25, 2026, OFAC published the Sanctions Penalties Regulations, adding a new Part 505 to the regulations. The Sanctions Penalties Regulations consolidate and update existing information regarding enforcement procedures and penalties previously dispersed amongst the other program-specific regulations.[1]

On September 30, 2026, OFAC published corresponding updates to the remainder of Chapter V to remove the duplicative and outdated references to penalties from those program-specific regulations.[2] OFAC also inserted a cross-reference in each affected Part to direct readers to the new Sanctions Penalties Regulations. Finally, OFAC reorganized several subparts to consolidate general provisions (regarding delegations of authority, records and reports, and the like) into one subpart A within each Part and made corresponding technical changes.

This reorganization ensures that all penalties-related regulations can be found in one place. Companies subject to US sanctions may consider familiarizing themselves with the reorganized and clarified regulations so that they have the most up-to-date understanding of potentially applicable penalties.