On May 1, 2026, a sweeping new Executive Order fundamentally reshaped U.S. sanctions policy toward Cuba. Moving beyond the traditional list-based approach, this new framework introduces Sectoral Sanctions and high-stakes Secondary Sanctions for Foreign Financial Institutions (FFIs). In this brief, we analyze the "Russia Playbook" application to Cuba and what it means for global compliance programs.

In this episode, we cover:

• The Sectoral Pivot: Identifying the five newly targeted sectors: Energy, Defense, Metals/Mining, Financial Services, and Security.
• The FFI "Death Penalty": Understanding the risk of losing U.S. correspondent account access under the new secondary sanctions authorities.
• E.O. 14024 vs. The Cuba EO: Why the U.S. is mirroring the Russian Harmful Foreign Activities framework.
• Compliance Red Flags: New triggers for human rights abuses and public corruption.
• Operational Checklist: Immediate steps for KYC updates and screening for "Adult Family Members" of designated persons.

Despite Western trade restrictions, luxury goods are still making their way into Russia. This episode breaks down Poland's recent enforcement actions, including a €4.7 million penalty and multiple arrests, against networks illegally exporting millions of euros worth of luxury vehicles. Learn how transit routes and fraudulent documents are being used to feed the Russian market.

In this episode, we dive into the growing crisis in U.S. export licensing based on a recent survey by the CSIS . We explore how the Bureau of Industry and Security (BIS) is facing unprecedented backlogs, with more than half of surveyed tech exporters waiting over 180 days for license reviews—well beyond the 90-day statutory limit. Discover how these extended timelines and a lack of transparency are leading to billions of dollars in delayed exports and costing companies critical business to foreign competitors. Finally, we unpack practical policy solutions to align national security goals with the administrative realities of globally competitive markets.

CSIS Report: https://csis-website-prod.s3.amazonaws.com/s3fs-public/2026-04/260421_Koren_Delays_Uncertainty.pdf?VersionId=tiMPZcvtOn7Pgapw7Ake8GQKfAyG2inA

The UK’s Office of Financial Sanctions Implementation (OFSI) has entered its second decade with a high-stakes mandate.

In this episode, we break down the newly released OFSI Strategy 2026-29, a roadmap that shifts the UK from a reactive posture to a proactive, intelligence-led enforcement powerhouse. If your organization operates in or through the UK, the "PERC" framework is your new compliance North Star.

We analyze the strategic shifts every Trade Compliance Officer must know:

• The PERC Model: A deep dive into Promote, Enable, Respond, and Change—and what "visibly costly" non-compliance actually looks like in 2026.
• AI-Enabled Enforcement: How OFSI is integrating Artificial Intelligence and data analytics to identify circumvention typologies and "zombie" financial networks.
• New Performance Targets: Discussion of the aggressive new KPIs, including a commitment to close 50% of licensing cases within 6 months and submit 90% of investigations within 18 months.
• Intelligence-Led Outcomes: Why the era of relying solely on voluntary self-disclosures is over, as OFSI moves toward proactive case origination.
• International Cooperation: The "Enhanced Partnership" with OFAC (US) and the EU, aiming to eliminate jurisdictional arbitrage for multinational firms.

OFSI Strategy Report: https://assets.publishing.service.gov.uk/media/69df6b6d53469bbcdf408e9f/OFSI_Strategy_2026-29.pdf

Analysis of the new OFAC "Functional Reality" standard. We discuss the December 2025 enforcement precedents and the 2026 advisory on sham transactions. Essential listening for Trade Compliance and KYC professionals.

The Swiss Federal Supreme Court has just changed the rules of the game for international trade compliance.

In this episode, we provide a comprehensive analysis of the landmark March 2026 judgment in Case 4A_305/2025. This ruling establishes a "statutory moratorium" (Stundung) for debts linked to sanctioned entities under the Swiss Ukraine Ordinance, fundamentally altering how multinational companies (MNCs) manage cross-border liabilities and legal risks in Switzerland.

We break down the critical compliance shifts, including:

• The "Statutory Suspension" Doctrine: Why sanctioned debts are now legally "paused" rather than extinguished under Article 119 CO.
• Piercing the Corporate Veil: How the Court identified "effective control" behind an Angolan entity to enforce Russian sanctions.
• Mandatory Public Law: Why Swiss judges must now investigate sanctions status ex officio (on their own motion).
• Arbitration Enforcement: The new hurdles for enforcing LCIA and international arbitral awards in Swiss courts.
• MNC Risk Management: Strategies for handling "Zombie Debts" and updated KYB (Know Your Business) protocols for 2026.

Whether you are a Chief Compliance Officer, General Counsel, or Trade Sanctions Specialist, this episode offers the legal clarity needed to navigate the intersection of Swiss private law and global geopolitical sanctions.

In this episode, we break down the April 2026 BIS enforcement action against Coastal PVA Technology, Inc.. Learn how 18 violations involving EAR99 semiconductor brushes led to a $1.7 million civil penalty. We explore the dangers of "knowledge" in third-party distributions , the specific risks of shipping to SMIC Beijing and SMIC North , and why "no formal compliance program" is a defense the government won't accept.

Charging Letter: https://www.bis.gov/media/documents/coastal-pva-technology-inc-4-13-2026-rev.pdf

In this episode, we break down the 20th package of EU restrictive measures against Russia, adopted in April 2026. This isn't just another list of names; it’s a fundamental shift in enforcement strategy.

We analyze the operational impact for Trade Compliance Professionals, including:

• The Shadow Fleet Crackdown: Understanding the new legal basis for maritime service bans and the 'No Russia' clause for tanker sales.
• Energy Infrastructure: The countdown to the January 1, 2027, ban on Russian LNG terminal services and the immediate freeze on icebreaker maintenance.
• Anti-Circumvention Tool (Pillar 11): Why the EU is now restricting exports to specific third-country jurisdictions for 'systemic circumvention' of metalworking and high-tech goods.
• Financial Hardening: The transaction ban on 20+ Russian banks and the new restrictions on crypto-asset service providers.
• Legal Protections: How EU firms can now use Member State courts to claim damages against Russian 'abusive lawsuits.'

Keywords: 20th EU Sanctions Package, Trade Compliance 2026, Shadow Fleet vessels, Russian LNG ban, Anti-Circumvention Tool, Regulation (EU) 2026/506, Sanctions Evasion, Crypto-asset service providers.

In a landmark move, the UK’s Office of Financial Sanctions Implementation (OFSI) has fined Apple Distribution International (ADI) £390,000. Despite being based in Cork, Ireland, the tech giant fell under UK jurisdiction—but how?

In this episode, we break down the March 2026 enforcement case involving Russian streaming service Okko, Sberbank, and the "strict liability" trap. We explore how Apple’s automated App Store payouts triggered a violation, why their £1.3M potential fine was slashed, and what this means for global tech compliance in an era of heightened Russia sanctions.

Following the February 2026 escalation, the Swiss Bundesrat has invoked strict neutrality laws. We break down the Swiss War Materiel Act (WMA), the Goods Control Act (GCA) for dual-use items, and the Interdepartmental Expert Group's new review process. Learn how to manage contract frustration and compliance red flags in this changing regulatory landscape.