Last Week's Major Developments in Sanctions - December 29, 2025, to January 2, 2026

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You can now listen to the audio version of our weekly sanctions updates here.

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Monday, December 29

• There was no major development on this day.

  
  

Tuesday, December 30

• OFAC imposed blocking sanctions against six individuals and four entities under its Iran sanctions program for contributing to Iran’s unmanned aerial vehicle trade with Venezuela.  (Here, the Department of the Treasury's press release, and the Department of State's press release)

Wednesday, December 31

• OFAC imposed blocking sanctions against three entities in Hong Kong, one in Marshal Islands, and four vessels under its Venezuela sanctions programs for operating in Venezuela’s oil sector. (Here, the Department of the Treasury's press release, and the Department of State's press release)

• In an AML-related development, FinCEN issued a final rule pushing the effective date for Investment Adviser rule from January 1, 2026, to January 1, 2028. This extension follows a proposal made in September 2025 and an earlier exemptive relief order from August. (Here)

  
  

Thursday, January 1

• There was no major development on this day.

Friday, January 2

• There was no major development on this day.

Recommendation of the Week

• With the significant developments over the weekend in Venezuela, this is an opportunity to refresh your memory on the current U.S. sanctions framework applicable to Venezuela, which may change in the near term depending on how events unfold in the coming days and weeks. Here is an overview U.S. sanctions program against Venezuela: Overview of U.S. Sanctions Policy (2026).