OFAC Sanctions Law CLE: Continuing Education for Compliance Attorneys in 2026

Sanctions law — administered primarily by the Office of Foreign Assets Control (OFAC) but encompassing EU, UN, and UK sanctions regimes — has become one of the most rapidly evolving areas of law affecting legal practitioners across practice groups. Corporate attorneys who advise on M&A and joint ventures need to understand sanctions screening obligations. Litigation attorneys encounter sanctions issues in asset freezing and forfeiture proceedings. Criminal defense attorneys face sanctions-related charges in federal prosecutions. And in-house compliance counsel at financial institutions and multinationals must navigate an increasingly dense regulatory landscape. CLE programs on sanctions law are a meaningful investment for practitioners in any of these contexts — and for most state bars, they qualify as substantive general CLE credit.

Why Sanctions Law CLE Has Become Essential in 2026

The period from 2022 through 2026 has seen the most significant expansion of US sanctions authorities in decades. Russia-related sanctions following the February 2022 invasion of Ukraine added thousands of designated individuals and entities to the SDN List, imposed sectoral sanctions on major Russian industries, and extended secondary sanctions to financial institutions that facilitate significant transactions with sanctioned Russian entities. Simultaneously, OFAC has maintained and expanded its Iran, Venezuela, Cuba, North Korea, and China-related programs, while rolling out new authorities under the International Emergency Economic Powers Act (IEEPA) for emerging technology controls.

For attorneys whose clients have any international dimension to their business — and in 2026, that includes virtually every significant commercial enterprise — sanctions compliance has moved from a specialist niche to a general business law competency. The legal risks are concrete: OFAC civil penalties can reach the greater of $356,579 per violation or twice the value of the underlying transaction, and willful violations carry criminal exposure of up to 20 years imprisonment and $1 million in fines per count.

Core Topics in Sanctions Law CLE Programs

High-quality CLE programs on sanctions law cover several foundational topics that provide the analytical framework attorneys need to advise clients and identify issues:

• The OFAC regulatory framework: How the SDN List is structured, the difference between comprehensive sanctions programs (Iran, Cuba, North Korea) and list-based programs, what blocking means in practice, and the licensing process for authorized transactions.
• The 50 Percent Rule and beneficial ownership: OFAC's rule that entities owned 50% or more by SDN-listed persons are themselves blocked even without separate listing — the most common source of inadvertent sanctions violations in complex transactions involving layered corporate structures.
• Secondary sanctions: How OFAC secondary sanctions authorities differ from primary sanctions, which programs currently have secondary sanctions (Russia, Iran, Venezuela), and the implications for non-US entities transacting in US dollars through US correspondent banks.
• Sanctions screening for law firms: The applicability of OFAC rules to legal service providers, the "U-turn" exception for certain transactions, and how law firms should build client screening processes proportionate to their practice area risk profile.
• Voluntary self-disclosure and OFAC enforcement: The mechanics of the OFAC enforcement process, when voluntary self-disclosure is advisable, and how OFAC weighs egregious versus non-egregious violations in determining penalty amounts.

Russia Sanctions Updates: What Attorneys Need to Know for 2026

Russia-related sanctions have generated the most significant compliance burden for US attorneys and their clients since 2022. For 2026, the key developments practitioners need to understand through CLE and ongoing education include: the expansion of OFAC's Russia-related SDN List to cover additional financial institutions, defense sector entities, and technology companies; the implementation of price cap mechanisms for Russian oil under the G7 framework and the legal exposure for non-compliant transactions; new restrictions on imports from Russia and exports to Russia under both OFAC and Commerce Department export control authorities; and the enforcement of secondary sanctions against non-US financial institutions that have continued to process transactions with sanctioned Russian entities.

Practical CLE programming on Russia sanctions should cover deal structure due diligence, the sanctions implications of ruble-denominated transactions and offshore Russian assets, and the intersection of Russia sanctions with FARA (Foreign Agents Registration Act) obligations for attorneys representing Russian clients on non-prohibited matters.

Finding Accredited Sanctions CLE Programs

Several organizations consistently offer accredited CLE on sanctions law. The American Bar Association's Business Law Section and International Law Section both offer programming on OFAC and international sanctions. The Association of Certified Anti-Money Laundering Specialists (ACAMS) offers compliance training that qualifies for CLE in many states. Law firms' in-house CLE programs on sanctions topics often qualify as accredited CLE for participants from outside firms. Federal agencies — including Treasury's OFAC and the Commerce Department's Bureau of Industry and Security — offer free public webinars and training that may qualify as CLE credit depending on your state's approval of the specific program.

The intersection of sanctions law with extradition, asset forfeiture, and international criminal proceedings is an area where CLE programs specifically designed for federal criminal defense practitioners may be particularly valuable. Federal court bar associations — including the criminal law sections of district bar associations in major federal enforcement centers like the Southern District of New York, the Northern District of Illinois, and the Eastern District of Louisiana — develop programming that addresses these practical overlaps. For practitioners in the Eastern District of Louisiana specifically, EDLA-focused programming on federal financial crime defense covers money laundering, BSA violations, and the international dimensions of OFAC-related criminal prosecutions. See our article on CLE requirements for international law attorneys for the broader multi-jurisdictional compliance picture.

Ethics Dimensions of Sanctions Law Practice

Representing clients who face OFAC sanctions — whether contesting a designation, seeking a specific license, or defending a criminal prosecution — raises professional responsibility issues that can form the basis of ethics CLE credit. Key ethics questions include: the duty of candor when OFAC disclosure obligations conflict with attorney-client confidentiality; representing foreign clients whose transactions may implicate sanctions without direct US nexus; conflicts of interest when representing multiple parties in a sanctions investigation; and the ethical obligations of attorneys who discover that a client has engaged in sanctions violations in the course of representation. The ABA's ethics opinions addressing OFAC issues and the Model Rules' application to sanctions practice have generated substantial ethics CLE programming in recent years.