The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has imposed its largest Russia-related monetary penalty to date, fining travel technology company Sabre Global Technologies more than £1 million (approximately $1.3 million) for sanctions violations involving Russia’s Ural Airlines. Beyond the size of the penalty, however, the enforcement action is significant because it represents OFSI’s first sanctions circumvention case and provides a detailed roadmap of...

The Office of the U.S. Trade Representative (USTR) has launched what may be the most sweeping use of Section 301 authority in the history of American trade law. On June 2, 2026, USTR released its report and proposed action in 60 parallel investigations targeting forced labor enforcement failures across virtually every major U.S. trading partner. The proposal—covering economies that account for an estimated 99.4% of...

On June 23, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorizing a broad range of transactions ordinarily incident and necessary to the production, sale, delivery, or offloading of Iranian-origin crude oil, petrochemical products, and petroleum products through August 21, 2026. The authorization applies notwithstanding prohibitions imposed under multiple Iran-related sanctions authorities and expressly...

If you read Parts I and II of this series and concluded that the AI governance problem is primarily an internal one — about what your employees do with AI inside your organization — you have only identified half the exposure. The other half lives outside your walls. It lives in your vendors, your service providers, your agents, your supply chain. And for the vast...

If Part I of this series described the governance gap at the organizational level, Part II describes the crisis that is already unfolding inside your organization right now — whether you know it or not. Shadow AI is real, it is pervasive, and the statistics are alarming. According to Gartner research across 500 companies, 68% of employees use unauthorized AI tools at work — a...

There is a crisis unfolding in corporate boardrooms and compliance departments across America, and most organizations are not responding with anywhere near the urgency the situation demands. The crisis is AI governance — or more precisely, the near-total absence of it. The numbers are striking. According to a Compliance Week 2026 survey, 83% of organizations are using AI tools, but only 25% have implemented a...

Part 1 of this series examined the legal framework underlying OFAC’s new Venezuela general licenses—General License 46B, GL 51B, and GL 52—and the Foreign Government Deposit Fund payment mechanism that sits at the center of the authorized transaction structure. Part 2 turns to the practical compliance program question: what does a company actually need to build to execute Venezuela-related transactions safely, accurately, and in a...