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

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.

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