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Wire · regulatory

OFAC's 'Should‑Have‑Known' Standard Drives 2026 Enforcement, Lawyer Says

30 July 2026 · By · Wire by Fusion42

Published

30 July 2026

Topic

regulatory

◆ Sectors

Generalist

◆ Source

Read at exportcompliancedaily.com →

◆ Verified

Fusion42 · 30 July 2026 · Fusion42 review

The US sanctions regulator, OFAC, is increasingly enforcing a "should-have-known" standard, focusing on the economic reality of transactions and penalising companies for ignoring red flags, as shown by recent large settlements. Concurrently, China is implementing its own export-control countermeasures, creating a compliance conflict for multinational companies navigating between US and Chinese regulations.

This Wire brief sits within Fusion42's coverage of Generalist.

◆ ◆ The Wire takeaway

Regulators now assume you know what your suppliers' suppliers are doing. The "should have known" standard means your sanctions compliance must go beyond paperwork, even if it puts you at odds with new Chinese counter-sanctions laws.

◆ Coverage

1 source · 30 Jul 2026

◆ Related on Wire

◆ Topics

Generalistsanctionsofacexport-controlscomplianceus-chinasupply-chain-risk