Mr. Sanctions

Category: Legislation

  • Burning Question: In Every E.O. – What is Proclamation 8693 of July 24, 2011?

    Proclamation 8693, officially titled Suspension of Entry of Aliens Subject to United Nations Security Council Travel Bans and International Emergency Economic Powers Act Sanctions, was issued by President Obama on July 24, 2011, and published in the Federal Register on July 27. If you have read any OFAC-related Executive Order issued after that date, you have almost certainly seen a sentence saying that blocked persons “shall be treated as persons covered by section 1 of Proclamation 8693.” That reference is doing meaningful legal work, and it is worth understanding exactly what it means.

    What Section 1 Does

    Section 1 is the operative heart of the Proclamation. Issued under the President’s authority in Section 212(f) of the Immigration and Nationality Act (INA) — which gives the President broad power to suspend entry of any class of foreign nationals whenever their entry would be detrimental to national interests — it suspends entry into the United States, as either immigrants or nonimmigrants, of two categories of people:

    (a) Any alien who meets the criteria for a travel ban imposed by a UN Security Council resolution listed in Annex A to the Proclamation; and

    (b) Any alien whose property and interests in property have been blocked by a IEEPA-based Executive Order listed in Annex B to the Proclamation.

    In plain English: if you are on the OFAC SDN List because your assets have been frozen under an IEEPA-based Executive Order, you are also barred from entering the United States under Proclamation 8693. The financial sanction and the travel ban become a package deal. The State Department’s Foreign Affairs Manual (9 FAM 302.14) makes this link explicit, noting that PP8693 suspends entry of applicants designated under IEEPA, and that OFAC’s SDN List is the operative mechanism for identifying such persons.

    What the Other Sections Do

    The remaining sections provide the administrative infrastructure around Section 1.

    Section 2 gives the Secretary of State, or a designee, sole discretion to identify which persons are actually covered by Section 1, and to establish the procedures for doing so.

    Section 3 assigns overall implementation responsibility to the Secretary of State, in consultation with the Secretary of the Treasury and the Secretary of Homeland Security.

    Section 4 is the waiver provision: Section 1 does not apply where the Secretary of State determines that a particular person’s entry would not be contrary to US interests. In practice this provides important flexibility, including for law enforcement objectives where allowing travel may serve US interests. The Secretary must consult DHS on matters within DHS’s admissibility authority.

    Section 5 preserves US obligations under applicable international agreements — an important carve-out, since the UN Headquarters Agreement sometimes requires the United States to permit entry of individuals who would otherwise be barred.

    Section 6 is the standard no-private-right-of-action clause: the Proclamation creates no enforceable legal rights or benefits against the US government for any party.

    Section 7 states that the Proclamation is effective immediately and remains in force until the Secretary of State determines it is no longer necessary and publishes that determination in the Federal Register. Unusually, there is no expiration date — it runs indefinitely until actively terminated.

    Before the Proclamation: How Were Travel Bans Handled?

    Before 2011, there was no single consolidated mechanism linking IEEPA-based sanctions designations to entry suspension across all programs. The tools that existed operated in a fragmented, program-by-program way.

    The underlying legal authority — INA 212(f) — has always existed and gives the President broad power to suspend entry of foreign nationals. Presidents used it for specific purposes before 2011: for example, Proclamation 7750 (2004) suspended entry of persons engaged in or benefiting from corruption, and earlier proclamations targeted specific country affiliations or conduct. But none of these created a horizontal mechanism linking all IEEPA designations to travel ban consequences as a class.

    For IEEPA-based sanctions programs, the approach before 2011 was inconsistent. Some IEEPA Executive Orders included their own entry suspension provisions directly within the order itself, invoking INA 212(f) on a program-specific basis. But at least some older programs — including some established in the 1990s — did not include such language. The Congressional Research Service has noted, for example, that Proclamation 8693 was issued to suspend entry of persons sanctioned under E.O. 12978 (the 1995 narcotics trafficking order), implying that order lacked a sufficient standalone entry suspension mechanism. This left a gap: a person could have their US-based assets frozen but face no formal presidential proclamation barring their entry.

    For UN Security Council travel bans, the situation was similarly unsystematic. Before the Proclamation, giving domestic effect to UNSC travel ban obligations in the US immigration context depended on State Department guidance and consular practice rather than a standing presidential proclamation. Proclamation 8693 remedied that by creating a formal, standing legal instrument to implement UNSC Chapter VII travel ban obligations in US immigration law.

    How Was the Proclamation Made Applicable to Pre-2011 Executive Orders?

    The Proclamation addressed the pre-existing gap through its two annexes. Annex A listed the then-current UNSC resolutions imposing travel bans. Annex B listed the IEEPA-based Executive Orders then in existence, bringing all persons already blocked under those programs within the Proclamation’s entry suspension framework on the day it issued.

    For Executive Orders issued after July 24, 2011, the mechanism is different and has become standardized: each new IEEPA-based EO includes a provision stating that blocked persons “shall be treated as persons covered by section 1 of Proclamation 8693.” This “refer-out” technique plugs each new sanctions program into the Proclamation’s administrative infrastructure — the Secretary of State’s identification authority, the waiver process, the international obligations carve-out — without each EO having to recreate it from scratch.

    The Proclamation’s scope has also been extended dynamically: some subsequent EOs include language providing that new UNSC resolutions “shall be treated as resolutions listed in Annex A of Proclamation 8693,” meaning the Proclamation’s UNSC travel ban coverage grows as the Security Council acts, without requiring a new proclamation each time.

    The result is a durable, cross-administration framework. Proclamation 8693 has been cited and relied upon in Executive Orders issued under the Obama, Trump, and Biden administrations, and into the present. Because it remains in force until the Secretary of State affirmatively terminates it, it functions as standing infrastructure rather than a time-limited instrument — which is precisely why you see it cited in virtually every IEEPA-based sanctions order issued in the years since.

    And here is Claude’s source list and check for accuracy:

    Sources

    1. Proclamation 8693, full text — American Presidency Project, UC Santa Barbara (presidency.ucsb.edu/node/290727)
    2. State Department Foreign Affairs Manual, 9 FAM 302.14 (fam.state.gov) — INA 212(f) ineligibility and PP8693 operational guidance
    3. Congressional Research Service, IF10909, U.S. Sanctions: Targeting International Illicit Drug Production and Trafficking (congress.gov)
    4. Executive Order 13726 (Libya expansion, April 2016) — OFAC/govinfo
    5. Executive Order 13818 (Global Magnitsky, December 2017) — American Presidency Project
    6. Executive Order 13849 (CAATSA implementation, September 2018) — American Presidency Project
    7. Executive Order 13660 (Ukraine/Russia, March 2014) — govinfo/OFAC
    8. Executive Order 13606 (Iran/Syria abusive technology, April 2012) — IRP/FAS
    9. Executive Order 13608 (Foreign Sanctions Evaders, May 2012) — Obama White House archives
    10. E.O. 14203 (2025) — OFAC PDF, confirming continued use of Proclamation 8693 reference formula
    11. Executive Order 14115 (West Bank, February 2024) — American Presidency Project and White House

    Accuracy Check

    Well-supported by sources

    Date, title, and publication. Confirmed directly in the Proclamation text: issued July 24, 2011; the American Presidency Project notes it was released by the Press Secretary on July 25 and published in the Federal Register on July 27.

    Legal authority (INA 212(f)). Confirmed verbatim in the Proclamation’s preamble: “including section 212(f) of the Immigration and Nationality Act of 1952, as amended (8 U.S.C. 1182(f)), and section 301 of title 3, United States Code.”

    The two categories in Section 1 (UNSC Annex A / IEEPA EOs Annex B). Confirmed exactly in the Proclamation text.

    All sections 2 through 7. Confirmed verbatim in the Proclamation text.

    State Dept FAM operational link. Confirmed in 9 FAM 302.14: “PP8693 also suspends entry of applicants designated under IEEPA: OFAC implements and enforces IEEPA sanctions. Designated individuals and organizations are listed on OFAC’s searchable SDN list.”

    Proclamation 7750 (2004) as a pre-existing INA 212(f) proclamation. Confirmed in 9 FAM 302.14, which lists PP7750 alongside PP8693 as separate proclamations.

    Post-2011 “refer-out” formula. Confirmed across dozens of EOs from three administrations. The formula “shall be treated as persons covered by section 1 of Proclamation 8693” appears in orders covering Ukraine, Libya, Nicaragua, North Korea, Venezuela, Global Magnitsky, CAATSA, the West Bank, and many others.

    Annex A expansion via subsequent EOs. Confirmed: the Libya expansion EO (E.O. 13726, 2016) explicitly states “United Nations Security Council Resolution 2174 shall be treated as a Resolution listed in Annex A of Proclamation 8693.”

    Continued use across administrations through 2025. Confirmed by citation in E.O. 14203 (2025 OFAC PDF).

    E.O. 12978 lacking standalone entry suspension. Confirmed by inference from the CRS report, which states that Proclamation 8693 was issued “to suspend U.S. entry of foreign individuals sanctioned under E.O. 12978” — implying the 1995 order did not already have adequate entry suspension coverage of its own.

    Inferential but reasonable

    “Some older IEEPA EOs did not include entry suspension language.” The claim is supported by the CRS note about E.O. 12978, and by the fact that the Proclamation was created at all — if every IEEPA EO already had adequate entry suspension provisions, a consolidated proclamation would have been unnecessary. That said, I did not retrieve the full text of every pre-2011 IEEPA EO to verify this comprehensively. The claim is well-grounded but not exhaustively sourced.

    UNSC travel bans implemented through “State Department guidance and consular practice” before 2011. Supported by the Proclamation’s preamble, which frames it as necessary to carry out US obligations under the UN Charter. But the specific mechanisms the State Department used before 2011 are not detailed in the sources retrieved. This is a reasonable inference, not a sourced factual claim.

    Things not verified from retrieved sources

    The specific list of EOs in Annex B. I retrieved the Proclamation text but not the full text of its annexes as published in the Federal Register on July 27, 2011. The claim that Annex B listed the IEEPA-based EOs then in existence is correct in structure but the specific list was not verified. Readers who need the precise original list should consult 76 Fed. Reg. 44751 (July 27, 2011).

    Nothing in the main response rises to the level of a factual error.

    The main areas of uncertainty are (1) the comprehensiveness of the pre-2011 gap (well-supported but not exhaustively verified) and (2) the exact contents of Annex B (structurally correct but not retrieved). The core analysis — what the Proclamation does, what each section means, how it plugs into the IEEPA framework, and how subsequent EOs reference it — is solidly sourced throughout.

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  • Burning Question – continued: What Alternatives Were There to the FCPIAA?

    The Short Answer

    Before the FCPIAA, agencies did not have legal authority to adjust civil monetary penalties directly. Any such modification had to be made by the passage of new legislation. This sentence from the 2012 ACUS report on the Inflation Adjustment Act is the crux of it. Before 1990, there were no genuine non-legislative mechanisms for adjusting the level of civil penalties. What did exist were a handful of partial workarounds — none of which addressed the underlying structural problem.

    What Options Existed

    1. Ad hoc congressional amendment — the only real mechanism

    The formal, correct answer to “how do you raise a civil penalty?” before 1990 was: you go back to Congress and get the statute amended. Due to the slow pace of amendments of agency organic statutes in recent years, substantial periods of time could elapse between specific statutory adjustments of civil monetary penalty amounts, and the deterrent effect of the penalties could be diminished by the effects of inflation in the interim period. This was the problem Congress was explicitly trying to solve with the FCPIAA.

    2. Agency discretion within statutory maximums

    Agencies did have discretion over how much to assess within the floor and ceiling set by statute. In theory, an agency could push assessed penalties toward the statutory maximum — effectively getting more deterrent value without changing the ceiling itself. But this was a blunt instrument: it offered no relief once the ceiling itself had eroded, and it was inconsistent across agencies and cases.

    Experience has shown that agencies play a crucial role and exercise broad discretion in the administration of civil penalty programs. Agencies possessing such authority have found it efficient to try to resolve cases before the formal hearing stage through settlement and negotiation. Indeed, agencies settle well over 90 percent of their cases by means of compromise, remission, or mitigation. That settlement discretion ran almost entirely in the downward direction — agencies were softening penalties case by case, not inflating them upward.

    3. ACUS recommendations to Congress

    The Administrative Conference of the United States (ACUS) — a federal advisory body — repeatedly flagged the problem and pushed for structural fixes. In Recommendation 84-7, Administrative Settlement of Tort and Other Monetary Claims Against the Government, the Conference encouraged Congress to “systematically raise ceilings on all agency authority to settle claims where inflation has rendered obsolete the present levels.” ACUS Recommendation 79-3, issued in 1979, examined agency penalty assessment and mitigation practices more broadly. These recommendations were advisory only — they had no legal force and required Congress to act, which it was slow to do.

    4. Penalty matrices and assessment standards

    ACUS Recommendation 79-3 also urged agencies to develop structured penalty schedules and formulas for individual case assessment. Agencies enforcing regulatory statutes should establish standards for determining appropriate penalty amounts for individual cases — specifying the factors to be considered in determining the appropriate penalty amount in a particular case. A well-designed matrix could incorporate economic conditions as a factor — but this operated only within the statutory ceiling and could not solve the ceiling’s erosion over time.

    How Effective Were These Options?

    Not very, and the record shows it clearly. Congressional amendment was the only mechanism with legal force, and it was slow, sporadic, and dependent on legislative bandwidth. Many penalty amounts went unchanged for decades. By the time the FCPIAA was being debated, some penalties had been set in statutes from the 1950s, 1960s, and early 1970s, accumulating inflation gaps that ran to several hundred percent — as GAO-03-409 data showed (FAA gaps as high as 418%).

    Agency discretion and settlement practices were structurally incapable of solving an inflation problem: you can negotiate a penalty down within the cap, but you cannot negotiate it above the statutory maximum. And ACUS’s advisory recommendations, however well-reasoned, simply waited on congressional action that was chronically delayed.

    The consistent conclusion in the legislative history — reflected in Senator Levin’s 1988 Senate hearing statement, the OMB Deputy Director’s testimony, and the ACUS record — was that the pre-1990 system had no effective self-correcting mechanism. The FCPIAA was the first attempt to build one in, though as discussed in the previous post, it took the 2015 reforms to make it work properly.

    This is Claude’s accuracy check (I find this essential for real research and analysis projects — not so much for reformatting OFAC update contents):

    Accuracy Check Against Sources

    Directly cited material — accurately rendered

    The core ACUS quote establishing that agencies had no legal authority to adjust penalties is pulled accurately from the 2012 ACUS proposed recommendation. The full passage in the source reads exactly as cited.

    The passage about the “slow pace of amendments” and eroding deterrent effect is accurately paraphrased and cited. The ACUS quote about agency discretion and settlement is accurate. The figure that agencies settle well over 90 percent of their cases by means of compromise, remission, or mitigation is accurately pulled — though worth noting it comes from ACUS Recommendation 72-6 (1972), a much older document than the others. It’s real, but it describes practice as of 1972, not specifically the pre-1990 landscape generally. The ACUS 84-7 and 79-3 characterizations, including titles and dates, check out against the source footnotes in the ACUS 2012 document. The ACUS quote about penalty standards is accurately reproduced.

    Things that are inferential but presented as if sourced

    The “downward only” claim about settlement discretion. The characterization that settlement discretion “ran almost entirely in the downward direction” is a logical inference — you cannot settle above the statutory maximum — but no source actually says this. It is analytically sound but was stated as a factual characterization without flagging it as independent reasoning.

    Penalty matrices as an inflation workaround. The description of penalty matrices as a mechanism that “could theoretically incorporate inflation factors in the actual penalty assessed” is not supported by the sources. ACUS Recommendation 79-3 addresses consistency and procedural fairness, not inflation-proofing. This is an analytical stretch, and penalty matrices probably should not have appeared as a distinct inflation-adjustment option at all.

    One characterization that needs a nuance flag

    ACUS Recommendation 84-7. This was presented as primarily an inflation-focused recommendation. In fact its full title — Administrative Settlement of Tort and Other Monetary Claims Against the Government — shows it was primarily about settlement authority. The inflation-ceiling language appears within it as one element, and the way the 2012 ACUS document deploys it gives the impression it was more specifically about inflation than the original 1984 recommendation probably was. The characterization follows the ACUS 2012 framing, which itself uses it selectively — not wrong exactly, but a second-order characterization rather than a direct reading of the 1984 recommendation.

    One data point imported from earlier research

    The “FAA gaps as high as 418%” figure comes from GAO-03-409, which appeared in the earlier research session on the FCPIAA itself. It is real and accurate, but it was not retrieved in this search session — it was carried forward from the prior search. Worth knowing the provenance.

    Summary

    The directly cited text is accurate throughout. The main weaknesses are: (1) the penalty matrix point is inferential and poorly supported; (2) the “downward only” characterization of settlement discretion is logical but unsourced; and (3) the framing of Rec. 84-7 as an inflation-focused document follows ACUS 2012’s selective use of it rather than a direct reading of the 1984 original. None of these rise to the level of factual errors, but they are places where the response overstated the certainty of the analytical conclusions relative to what the sources actually establish.

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  • Burning Question: What is the FCPIAA, and Why Should We Care?

    Federal civil monetary penalties are set by statute, written in dollars. A $10,000 penalty enacted in 1972 remained a $10,000 penalty in 1992 — even though inflation had eroded its purchasing power (and deterrent effect) by roughly 60 percent over those two decades. Congress recognized this problem and passed the Federal Civil Penalties Inflation Adjustment Act of 1990 (FCPIAA, or simply “the Act”) to address it. Subsequent amendments have refined and strengthened the Act, but the underlying logic has remained consistent: penalties that don’t keep pace with inflation lose their bite.

    The Problem the Act Was Designed to Solve

    Civil monetary penalties (CMPs) are dollar fines that federal agencies impose for violations of law and regulation — everything from workplace safety violations to financial crimes to violations of U.S. sanctions. When Congress enacts these penalties, it sets them in nominal dollar terms at the time. Inflation erodes their real value over the years: a $10,000 fine is a much less significant deterrent in an economy that has doubled in size than it was when the penalty was first written into law.

    Congress passed the FCPIAA (Public Law 101-410) in 1990 precisely to fix this. The Act’s stated purposes were to:

    • Allow for regular, inflation-based adjustment of civil monetary penalties;
    • Maintain the deterrent effect of those penalties; and
    • Improve the federal government’s collection of CMPs.

    What the Act Does — and Who It Covers

    The FCPIAA requires federal agencies to periodically increase the dollar amounts of civil monetary penalties within their jurisdiction to reflect inflation. It applies broadly — to virtually all federal agencies with statutory authority to assess CMPs. This includes the Department of Labor, the Environmental Protection Agency, the Federal Trade Commission, the Commodity Futures Trading Commission, the Consumer Financial Protection Bureau, and many others.

    Notably, the Act applies to OFAC — the Treasury Department’s Office of Foreign Assets Control, which administers and enforces U.S. economic sanctions programs. OFAC civil penalties, which can run to tens of millions of dollars per violation under certain sanctions programs (particularly those enacted under the International Emergency Economic Powers Act, or IEEPA), are subject to the same annual inflation adjustment requirement as any other federal civil monetary penalty. OFAC has now adjusted its CMPs annually each January since the 2015 reform took effect.

    What the Act Originally Required — and When

    The 1990 Act, as subsequently amended by the Debt Collection Improvement Act of 1996, required federal agencies to issue regulations adjusting their civil monetary penalties for inflation by October 23, 1996 — a six-year runway from passage. Thereafter, agencies were required to make adjustments at least once every four years, using the June Consumer Price Index (CPI) published by the Bureau of Labor Statistics.

    There was a significant catch: the maximum permissible first adjustment was capped at 10 percent, regardless of how much inflation had actually accumulated since the penalty was last set. For penalties that had sat unchanged since the 1970s or early 1980s, the accumulated inflation gap was often enormous — sometimes hundreds of percent — but agencies could only bridge 10 percent of it in that first round.

    What Actually Happened — Delays, Variation, and Non-Compliance

    In practice, agencies were slow to comply, and the timing of first adjustments varied widely. The EPA, for example, made its first round of adjustments on December 31, 1996 — just barely after the statutory deadline. Other agencies were later still, and some took years, making their subsequent quadrennial adjustments on irregular schedules that bore little resemblance to the statute’s intent.

    Several factors contributed to this inconsistency:

    Weak enforcement mechanisms. The original Act required agencies to act but imposed no meaningful consequences for delay. There was no automatic trigger, no penalty for non-compliance, and no centralized mechanism to ensure agencies actually published their adjustments on time.

    Administrative rulemaking requirements. Under the Administrative Procedure Act (APA), regulatory changes typically require notice-and-comment periods — a time-consuming process. Agencies had to treat each penalty adjustment as a full regulatory action subject to those requirements, adding months or years to implementation.

    The 10% cap created perverse incentives. If a penalty had accumulated 40, 100, or 200 percent of inflation since it was last set, a 10% adjustment barely made a dent. This reduced the perceived urgency of acting quickly, since the first adjustment wouldn’t meaningfully restore the penalty’s real value in any case.

    Differing interpretations. GAO subsequently documented that agencies had differing interpretations of how to apply the statute’s rounding rules, how to identify the base year for calculation, and which penalties fell within its scope. Without clear, centralized guidance from OMB, agencies went their own ways — and some simply didn’t go at all.

    The result was that by the mid-2000s, despite two rounds of required adjustments, many federal civil penalties remained significantly below their inflation-adjusted levels. The Act had the right idea but lacked the mechanics to deliver on it.

    The 2015 Reform: Starting Over Properly

    Congress addressed these failures directly in the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (enacted November 2, 2015, as Section 701 of the Bipartisan Budget Act of 2015, Public Law 114-74). The 2015 Act made three major changes:

    A “catch-up” adjustment. Recognizing that penalties had fallen far behind, the 2015 Act required agencies to make an initial catch-up adjustment calculated from the year the penalty was last set or adjusted by substantive legislation (not by a prior inflation adjustment) through October 2015. This was a potentially large, one-time adjustment designed to close the accumulated gap. It was capped at 150 percent of the penalty’s November 2015 value — meaningful, but far less restrictive than the original 10 percent ceiling.

    Annual adjustments going forward. After the catch-up, agencies were required to adjust their penalties annually, no later than January 15 of each year.

    OMB guidance and streamlined rulemaking. The 2015 Act directed OMB to issue annual implementation guidance and exempted inflation adjustments from the APA’s normal notice-and-comment requirements — meaning agencies could implement adjustments immediately by final rule, without the multi-year delay that the rulemaking process had previously caused.

    Did the 2015 First Adjustments Go Smoothly?

    Mostly — but not entirely. The 2015 Act required agencies to publish their catch-up adjustment (in the form of an interim final rule) by July 1, 2016, with an effective date no later than August 1, 2016. Most agencies met this deadline. However, a 2017 GAO report (GAO-17-634) found that six federal agencies had still not published their catch-up inflation adjustments by December 31, 2016 — six months after the statutory deadline had passed. The reasons were familiar: administrative complexity, differing interpretations of OMB guidance, and the organizational challenge of identifying and coordinating across multiple penalty statutes within a single large agency. The GAO also found that some agencies had included penalties in their financial reports that should have been excluded, and vice versa.

    This variation in timing also reflected the fact that the catch-up adjustment was genuinely complex for some agencies: unlike the mechanical annual adjustment, it required each agency to trace every covered penalty back to the year it was last set by Congress, apply OMB’s multiplier table for that year, and verify the results — a significant administrative task for agencies with dozens of distinct penalty amounts.

    How the Amounts Are Actually Adjusted

    Under the 2015 Act, the annual cost-of-living adjustment works as follows:

    • The adjustment equals the percentage change between the Consumer Price Index for All Urban Consumers (CPI-U) for October of the year preceding the adjustment and the CPI-U for October of the year before that.
    • In plain terms: for the 2025 adjustment, October 2024 CPI-U (315.664) was divided by October 2023 CPI-U (307.671), giving a multiplier of 1.02598 — a 2.598% increase.
    • Each current penalty amount is multiplied by that figure and rounded to the nearest dollar.
    • If an agency has already increased a covered penalty during the preceding 12 months for reasons other than the inflation adjustment, no inflation adjustment is required for that year.

    The catch-up formula used for the initial 2016 round was different: agencies identified the year each penalty was last set or substantively adjusted by law, then applied OMB’s pre-calculated multiplier table reflecting cumulative CPI-U growth from that year through October 2015.

    Why CPI-U? How It Compares to Other Inflation Benchmarks

    The choice of CPI-U as the benchmark for civil monetary penalty adjustments is worth pausing on, because the federal government does not use a single inflation measure across all programs. Different statutes use different benchmarks, each reflecting different legislative histories and policy choices:

    Social Security cost-of-living adjustments use the CPI-W (Consumer Price Index for Urban Wage Earners and Clerical Workers), a narrower index dating to 1917 that was originally designed to reflect blue-collar spending patterns. The CPI-W tends to run slightly higher than the CPI-U, meaning Social Security benefits tend to increase slightly faster than they would under the broader index.

    Federal income tax brackets now use the Chained CPI (C-CPI-U), following the Tax Cuts and Jobs Act of 2017. The chained CPI is generally considered more technically accurate because it accounts for consumer substitution — the tendency to buy more chicken when beef prices rise, for instance. Because it captures this behavior, the chained CPI tends to grow more slowly than the standard CPI-U, meaning tax brackets adjust less quickly and more people are pushed into higher brackets over time, generating additional revenue.

    The Federal Reserve focuses on the Personal Consumption Expenditures (PCE) price index, a broader measure that includes not just what consumers pay directly, but also what is paid on their behalf — such as employer-provided health insurance. The PCE tends to run somewhat below the CPI-U and is preferred by the Fed for its comprehensive economic coverage.

    The CPI-U used for civil monetary penalties sits in the middle of this landscape: broader than CPI-W, more widely understood than PCE, and without the downward substitution adjustments built into the chained CPI. Its adoption reflects when the FCPIAA was written and OMB’s preference for a transparent, easily available, and publicly legible benchmark. The goal of the adjustment is not macroeconomic precision — it is a practical, defensible mechanism to prevent enforcement penalties from eroding in real value over time. For that purpose, the CPI-U is more than adequate.

    The Bottom Line

    The FCPIAA is one of those pieces of legislation that seems technical and administrative until you realize what it is actually doing: preserving the deterrent power of the federal government’s enforcement toolkit. A civil penalty that does not keep pace with inflation is, in real terms, a declining penalty — one that becomes easier to absorb and less likely to change behavior with each passing year. The 1990 Act recognized this problem; the 2015 reform gave it teeth. For practitioners in sanctions, export controls, financial regulation, or any other field where federal civil penalties are a live enforcement risk, understanding the FCPIAA is part of understanding the actual exposure — not just the nominal dollar figure on the statute books.

    I asked Claude to check its work and supply a source list – it actually caught an error (the text above reflects the fix):

    Research Sources Used

    1. Federal Register, DOL 2025 Annual Adjustments (Jan. 10, 2025)
    2. CFPB, Civil Penalty Inflation Adjustments page
    3. DOL, Civil Money Penalty Inflation Adjustments page
    4. Treasury/CFIUS, Notice on Inflation Adjustment to Max Civil Monetary Penalty (PDF)
    5. OFAC, Implementation of FCPIAA (2023 action)
    6. Federal Register, FTC — FCPIAA and DCIA (Oct. 13, 2000)
    7. OMB Memorandum M-25-02 (Dec. 17, 2024)
    8. Congress.gov, Public Law 114-74 (2015 Act full text)
    9. 28 U.S.C. § 2461 (uscode.house.gov — current codified statute)
    10. GAO, letter on EPA’s FCPIAA compliance (B-290021)
    11. GAO-17-634, Civil Penalties: Certain Federal Agencies Need to Improve Efforts to Comply with Inflation Adjustment Requirements (2017)
    12. GAO-03-409, Civil Penalties: Agencies Unable to Fully Adjust Penalties for Inflation Under Current Law
    13. Federal Register, Federal Maritime Commission interim final rule (June 30, 2016)
    14. Federal Register, CFTC Annual Adjustment 2024 and 2025
    15. Federal Register, OPM final rule (May 2025)
    16. Federal Register, NRC annual adjustment (Jan. 15, 2025)
    17. Congress.gov, S.535 (original 1990 bill summary)
    18. OFAC, 2025 annual adjustment PDF
    19. Federal Register, FTC correction (Nov. 2000)
    20. Federal Register, DOT annual adjustment (Mar. 2022)
    21. SSA, Social Security COLAs and the CPI
    22. BLS, CPI FAQ
    23. Wikipedia, United States Consumer Price Index
    24. St. Louis Fed, CPI vs. PCE: Choosing a Standard Measure
    25. CBO, Use an Alternative Measure of Inflation
    26. Brookings, The Hutchins Center Explains: The Chained CPI
    27. CBO, Differences Between the Traditional CPI and the Chained CPI
    28. EPIC for America, CPI and PPI explainer
    29. GovFacts, PCE vs. CPI

    Claim-by-Claim Assessment

    ✅ Well-supported

    • FCPIAA passed in 1990 as Public Law 101-410 — confirmed across many sources
    • The Act’s three stated purposes (regular adjustment / deterrence / collection) — directly quoted verbatim in GAO-03-409, the NRC rule, and the CFTC rule
    • OFAC is subject to the FCPIAA — confirmed in multiple OFAC Federal Register entries
    • OFAC has made ten annual adjustments since the 2015 Act — directly stated in the OFAC 2025 PDF
    • Original deadline of October 23, 1996 — confirmed in the GAO/EPA letter
    • The original Act required adjustments at least every four years using the June CPI — confirmed in the FTC 2000 Federal Register entry
    • The original Act capped the first adjustment at 10 percent — confirmed in the GAO/EPA letter and GAO-03-409
    • Inflation gaps after adjustment were sometimes in the hundreds of percent — GAO-03-409 table shows FAA had a gap as high as 418%, EPA as high as 266%, even after the 10% first adjustment
    • EPA made its first adjustment December 31, 1996 — directly from the GAO/EPA letter
    • The 2015 Act was enacted November 2, 2015, as Section 701 of Public Law 114-74 — confirmed in multiple sources
    • The 2015 Act required catch-up IFR published by July 1, 2016, effective by August 1, 2016 — confirmed in the 2015 Act text and the FMC rule
    • Annual adjustments required no later than January 15 each year — confirmed across many sources
    • APA notice-and-comment exemption — explicitly stated in multiple sources
    • Six agencies failed to publish catch-up by December 31, 2016 — GAO-17-634 directly
    • Annual adjustment formula: October CPI-U year-over-year — confirmed in 28 U.S.C. § 2461 and multiple agency rules
    • 2025 multiplier of 1.02598 (315.664 ÷ 307.671) — confirmed in OMB M-25-02 and CFTC 2025 rule
    • Rounded to nearest dollar — confirmed in statute and multiple rules
    • Catch-up formula based on October CPI-U from penalty’s last statutory adjustment through October 2015 — confirmed in FMC rule and OMB guidance
    • Social Security uses CPI-W — confirmed in multiple sources
    • CPI-W tends to run slightly higher than CPI-U — confirmed in EPIC and SSA sources
    • Tax brackets now use chained CPI since the 2017 Tax Cuts and Jobs Act — confirmed in Brookings and CBO sources
    • The Federal Reserve uses PCE — confirmed in St. Louis Fed, CBO, and GovFacts
    • PCE tends to run below CPI-U — confirmed in St. Louis Fed source

    ⚠️ Partially supported or inferential

    • Reasons for original non-compliance (the four-factor analysis) — This is where I’m most exposed. The APA rulemaking burden is well-supported by inference (the 2015 Act explicitly stripped it away, implying it was the problem). The 10% cap reducing urgency is my own analytical reasoning, not stated in any source. The weak enforcement mechanism point is a reasonable inference from the fact that agencies missed deadlines with no apparent consequences, but no source states it explicitly. The “differing interpretations” point is documented for the 2015 Act in GAO-17-634 and OMB M-25-02 — but I used it to explain original 1990 Act non-compliance, which is a looser application of that evidence.
    • “Some agencies took years… irregular schedules” — Partially supported. The FTC’s 2000 adjustment (four years after 1996) shows this, as does GAO-03-409’s general findings, but I don’t have a comprehensive breakdown of all agencies’ compliance timelines.
    • The 12-month exception to annual adjustment — Referenced in 28 U.S.C. § 2461 and OMB M-25-02, but both sources are truncated in my search results and don’t show the complete rule text. The claim is almost certainly correct but not fully verified from what I retrieved.

    ❌ Errors or unsupported claims

    • “roughly 60 percent” erosion from 1972 to 1992 — No source for this figure. Ironically, the actual inflation over that period was considerably more than 60% (the CPI roughly tripled, implying real value erosion closer to 65–70%), so the number is in the right ballpark but is still an unsourced assertion I inserted as an illustrative opening.
    • “OFAC civil penalties… can run to tens of millions of dollars per violation… particularly those enacted under IEEPA” — This is general sanctions practitioner knowledge, not something I retrieved and verified in these searches. It’s accurate, but it’s not sourced.
    • The 150% cap description is imprecise. I wrote it was “capped at 150 percent of the penalty’s November 2015 value,” which implies the total adjusted penalty is 150% of the original. What the statute actually says (and what both the 2015 Act text and 28 U.S.C. § 2461 confirm) is that the increase cannot exceed 150% of the penalty’s value at enactment — meaning the adjusted penalty can be up to 250% of the original (the base, plus an increase of up to 150% of that base). The Federal Maritime Commission rule in my sources explicitly frames it as 250% of the November 2015 amount as the ceiling for the total adjusted figure. This is a material error that could mislead a reader about the size of the catch-up adjustment.

    Summary

    The article is well-grounded on the statutory framework, the history of the 1990 and 2015 Acts, the OFAC applicability, the mechanics of the annual adjustment formula, and the CPI-U vs. other benchmarks comparison. The weakest section is the explanation of why agencies were slow to comply with the original Act — that analysis is reasonable but is more inferential than sourced. The one clear factual error is the 150% cap description, which should say the increase is capped at 150% of the base amount (making the maximum total adjusted penalty 250% of the original), not that the total is capped at 150%. That’s worth correcting before you publish.

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  • Plain-Language Summary of GE Settlement for DDTC Settlement

    Note: The Consent Agreement and Order documents were both not machine-readable, but Claude says the Proposed Charging Letter is more detailed anyhow.

    GE Aerospace’s $36 Million Export Violation Settlement — Plain-Language Summary

    What Happened?

    On April 17, 2026, the U.S. Department of State announced that GE Aerospace (the jet-engine arm of General Electric) agreed to pay $36 million to settle 116 violations of U.S. arms export law. The violations took place over a roughly six-year window, from April 2018 through late 2024.

    The relevant law is called ITAR — the International Traffic in Arms Regulations. Think of it as the strict rulebook that governs who American defense companies can share military technology with, and how. Violating ITAR is serious: it can harm national security and, in theory, expose a company to penalties exceeding $1.27 million per violation.

    The Four Categories of Violations

    1. Sending Sensitive Military Data to China (the most serious)

    China is on America’s “do not share” list for arms and military technology. Despite this, GE had three separate incidentsof sending controlled technical data to China without authorization:

    • In 2018, an employee traveling to China carried a company laptop containing data related to F-35, F-16, F-15, and U-2 aircraft engines — and then left the laptop unattended with Chinese university officials for 90 minutes.
    • In 2021, an employee emailed a technical drawing of a component from the F118 military engine to a Chinese supplier, mistakenly thinking it was governed by a less-restrictive export rule (Commerce Department rules, rather than ITAR).
    • In 2023, GE shipped maintenance manuals for the F110 engine to Singapore on three occasions — but routed the packages through China, which itself is prohibited. Nobody had configured the shipping account to flag that as a problem.

    The U.S. government determined that at least one of these incidents — the F118 engine drawing — actually provided China with useful military information.

    2. Mismanaging Export Licenses and Agreements (the largest category — 103 charges)

    GE held many government-approved licenses and agreements covering what military technology it could share with foreign partners, and under what conditions. It repeatedly failed to follow the fine print. Examples include:

    • Shipping repaired military components to the UK Ministry of Defense when the UK MoD wasn’t listed as an authorized recipient on the relevant agreement.
    • Allowing Japanese partners to pass military engine components to 31 unauthorized sub-suppliers over five years, because GE didn’t properly verify who was in the chain.
    • Sending technical data to suppliers in Mexico that went beyond what the license actually permitted.
    • Using a license exemption to ship turbine blade castings to Canada 30 times when a specific government condition required obtaining separate licenses for each shipment — and then failing to track the quantities properly.
    • Having a Swedish partner share engine maintenance data with an unauthorized entity in South Africa.
    • Failing to notify Congress of certain defense exports to Sweden, as required by law.
    • Repeatedly failing to submit required paperwork — things like purchase orders, amendment notifications, and lists of parties to agreements — on time or at all.

    The root causes cited repeatedly: outdated internal procedures (some not updated in over 10 years), inadequate training, and insufficient oversight of foreign partners.

    3. Exporting Defense Hardware Without Authorization (4 charges)

    • A wrong engine combustion liner (for the F404-400) was accidentally shipped to Sweden because commercial paperwork got mixed up between two different items.
    • 15 machined chassis for the F-35 aircraft were temporarily exported to Israel across three shipments because an employee misclassified them under the wrong export control regime.

    4. Failing to Update Its Government Registration (3 charges)

    GE repeatedly failed to report material changes to its registration statement with the government’s defense trade regulator, as required within five days of any such change. This kind of administrative failure can obscure the government’s visibility into who a company is and what it’s doing.

    The Settlement Terms

    GE Aerospace will pay a civil penalty of $36 million. The Department of State agreed to suspend $18 million of that amount on the condition that those funds are used for remedial compliance improvements instead. For at least 24 months, GE must also engage an external Special Compliance Officer to oversee its compliance program, and must submit to at least one independent external audit. The full consent agreement runs for 36 months.

    Why Wasn’t the Penalty Larger?

    The maximum theoretical penalty for 116 violations would be enormous. The penalty was reduced significantly because:

    • GE voluntarily disclosed all 116 violations itself — it found the problems and reported them, rather than waiting to be caught.
    • GE fully cooperated with the government’s review.
    • GE had already started fixing its compliance program before the settlement.

    That said, the government also noted aggravating factors: some of the exports involved Significant Military Equipment, violations were systemic across multiple business units, and the China incidents caused real national security harm.

    Key Takeaways for Non-Expert Professionals

    1. Self-disclosure matters enormously. GE’s decision to report its own violations — all 116 of them — likely saved the company hundreds of millions of dollars in potential penalties and avoided debarment from government contracting.
    2. Compliance programs need maintenance. A recurring theme here is procedures that hadn’t been updated in a decade. Regulations change; compliance infrastructure has to keep pace.
    3. You’re responsible for your partners’ compliance. Many violations occurred not at GE directly, but through foreign partners and sublicensees. Under ITAR, the U.S. license-holder is responsible for ensuring the whole chain follows the rules.
    4. China is a red line. Any unauthorized sharing of military-related technical data with China — even routing a package through a Chinese airport — is treated as a serious aggravated violation.
    5. Paperwork isn’t optional. A surprisingly large number of the 116 charges were essentially administrative failures: late filings, missing notifications, wrong forms. These are avoidable with proper systems.

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  • April 17, 2026: GE gets ITARed and feathered by DDTC

    U.S. Department of State Concludes $36 Million Settlement Resolving Export Violations by General Electric Company

    MEDIA NOTE

    OFFICE OF THE SPOKESPERSON

    APRIL 17, 2026

    The U.S. Department of State has concluded an administrative settlement with General Electric Company (GE Aerospace) to resolve 116 violations of the Arms Export Control Act (AECA), 22 U.S.C. § 2751 et seq., and the International Traffic in Arms Regulations (ITAR), 22 C.F.R. parts 120-130. The Department of State and GE Aerospace reached this settlement following an extensive compliance review by the Office of Defense Trade Controls Compliance in the Department’s Bureau of Political-Military Affairs.

    The administrative settlement between the Department of State and GE Aerospace, concluded pursuant to ITAR § 128.11, addresses multiple categories of ITAR violations, including GE Aerospace’s unauthorized exports of technical data to the People’s Republic of China; violations of terms, conditions, and provisos of several Directorate of Defense Trade Controls authorizations involving various countries; unauthorized exports of defense articles to two countries; and failure to report material changes to its ITAR registration.

    GE Aerospace voluntarily disclosed all the alleged violations, a substantial portion of which predate 2023. GE Aerospace also fully cooperated with the Department’s review of this matter and has implemented numerous improvements to its ITAR compliance program since the conduct at issue.

    Under the terms of the 36-month Consent Agreement, GE Aerospace will pay a civil penalty of $36 million. The Department has agreed to suspend $18 million of this amount on the condition that the funds will be used for the Department-approved Consent Agreement’s remedial compliance measures to strengthen GE Aerospace’s compliance program. In addition, for an initial period of at least 24 months, GE Aerospace will engage an external Special Compliance Officer to oversee the Consent Agreement, which will also require at least one external audit of its ITAR compliance program and implementation of additional compliance measures.

    This settlement demonstrates the Department’s role in furthering the national security and foreign policy of the United States by controlling the export of defense articles. The settlement also highlights the importance of exporting defense articles pursuant only to appropriate authorization from the Department. 

    The Consent Agreement and related documents will be available for public inspection in the Public Reading Room of the Department of State and on the Penalties and Oversights Agreements section of the DDTC’s website. 

    For additional information, please contact the Office of the Under Secretary for Arms Control and Internal Security at T_Outreach_PM@state.gov.

    and here are the documents from the DDTC site:

    Proposed Charging Letter GE Aerospace 20260417Download
    Consent Agreement GE Aerospace 20260417Download
    Order GE Aerospace 20260417Download

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  • Burning Question: What exactly is TSRA?

    Claude explains:

    The Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA)

    TSRA is Title IX of Public Law 106-387, signed into law on October 28, 2000. Its core function is straightforward: it provides that the President shall terminate any unilateral agricultural sanction or unilateral medical sanction in effect as of the date of enactment. In plain terms, the U.S. had been using sanctions to block the sale of food and medical goods to certain countries, and TSRA directed that those particular restrictions be lifted.

    What it covers — and what it doesn’t

    The goods covered are agricultural commodities, medicine, and medical devices. The definition of agricultural commodities is broad: it includes food commodities, feed, fish, shellfish and fish products, beer, wine and spirits, soft drinks, livestock, fiber including cotton, wool and other fibers, tobacco and tobacco products, wood and wood products including lumber and utility poles, seeds, and reproductive materials. However, the term does not include furniture made from wood, clothing manufactured from plant or animal materials, agricultural equipment, pesticides, insecticides, herbicides, or cosmetics unless derived entirely from plant materials.

    The lifting of sanctions is not unlimited. TSRA does not direct the termination of any unilateral agricultural or medical sanction that prohibits, restricts, or conditions the use of any agricultural commodity, medicine, or medical device that is controlled on the United States Munitions List, controlled on any control list established by the Export Administration Act of 1979 or any successor statute, or used to facilitate the development or production of chemical or biological weapons or weapons of mass destruction.

    Which countries are affected, and how

    The law operates differently depending on the country involved. Section 906(a)(1) requires that an export licensing requirement apply to sales to those countries that the Secretary of State has determined have repeatedly provided support for acts of international terrorism — in practice, Cuba, Iran, and Sudan. Though the Secretary of State has also determined that the governments of North Korea and Syria are sponsors of international terrorism, Section 906(a)(2) explicitly states that the license requirement does not apply to sales to those two countries.

    For Iran specifically, OFAC applies the licensing procedures required by Section 906 of the TSRA to all exports and reexports of agricultural commodities, medicine, and medical devices to Iran, covering exports to the government, any entities in the country, individuals in the country, and persons in third countries purchasing specifically for resale to any of the foregoing. These licenses are issued for one-year periods.

    The financing restrictions

    Alongside the licensing requirement, TSRA imposes strict limits on how these transactions can be paid for. No U.S. government assistance — including foreign assistance, export assistance, and any U.S. credit or guarantees — shall be available for exports to Cuba or for commercial exports to Iran, Libya, North Korea, or Sudan, though the President may waive this for the latter four countries on national security or humanitarian grounds. For Cuba specifically, exports can only be paid in cash-only sales that are paid in advance and must be financed by third-country financial institutions. The statute further specifies that nothing in the financing provisions authorizes payment terms or trade financing involving a debit or credit to an account of a person located in Cuba or of the Government of Cuba maintained on the books of a United States depository institution.

    The quarterly reporting requirement

    TSRA’s Section 906(b) requires OFAC to report periodically to Congress on the licenses it has processed. Under the procedures established in its TSRA-related regulations, OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran under the specific licensing regime set forth in Section 906 of the TSRA. The quarterly report referenced in the OFAC update you processed covers activities undertaken from October through December 2025, and is a direct fulfillment of this statutory reporting obligation.

    Sudan’s current status

    Worth noting as a practical update: as of December 14, 2020, no license from OFAC is required for exports or reexports of agricultural commodities, medicine, or medical devices to Sudan or the Government of Sudan, or for financing such exports or reexports, meaning Sudan has effectively been moved out of the specific licensing regime, leaving Iran as the primary country to which the active TSRA licensing process currently applies.

    And is anything being inferred?

    Potentially unsupported or imprecise:

    1. Libya in the financing restriction paragraph. I cited the statutory text from the Cornell LII source (index 31) which does include Libya in the list of countries covered by the U.S. government financing prohibition. That is directly sourced. However, Libya appears in the original 2000 statute but U.S. sanctions on Libya were subsequently lifted. I noted this without flagging the uncertainty, which could mislead a reader. I should have flagged that Libya’s current status under TSRA is unclear from my sources.
    2. “One-year periods” for licenses. I stated Iran licenses are issued for one-year periods. This appears in search result index 25 (“one-year specific licensing regime”) and index 33 (references to “one-year license” multiple times), so this is actually well-supported.
    3. The sentence “leaving Iran as the primary country to which the active TSRA licensing process currently applies.” This is an inference I drew from the Sudan delisting fact, combined with Libya’s ambiguous status and the current OFAC update’s language referring only to Iran. It is a reasonable inference but goes beyond what any single source explicitly states, and I presented it as a definite conclusion rather than an inference.
    4. The quarterly report covering “October through December 2025.” This came directly from the OFAC update page itself, so it is fully supported.
    5. North Korea and Syria carve-out. This came from the Congressional Research Service report (index 30), which is an authoritative secondary source rather than the statute itself. It is reliable but I should note the sourcing is a CRS report rather than the statute’s text directly.

    Those are the main items I would flag. The rest of the explanation is well-grounded in the retrieved sources.

    Yeah, I buy those caveats…

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  • February 20, 2026: Sanctions-Adjacent: State Imposes Visa Restrictions on Chilean Officials

    Visa Restrictions on Chilean Nationals Undermining Regional Security

    PRESS STATEMENT

    MARCO RUBIO, SECRETARY OF STATE

    FEBRUARY 20, 2026

    The United States is committed to countering attempts to undermine regional security and subvert sovereignty.  Today, the Department of State is announcing it has taken steps to impose visa restrictions on three Chilean government officials who knowingly directed, authorized, funded, provided significant support to, and/or carried out activities that compromised critical telecommunications infrastructure and undermined regional security in our hemisphere.  These individuals and their immediate family members will be generally ineligible for entry into the United States, and any U.S. visas held by them have been revoked. 

    These actions reaffirm President Trump’s commitment to protect America’s economic prosperity and national security interests in our region.  We continue to promote accountability for Chilean nationals who intentionally work to destabilize our hemisphere. In its twilight, the Boric government’s legacy shall be further tarnished by actions that undermine regional security at the ultimate expense of the Chilean people.  We look forward to advancing shared priorities, including those that strengthen security in our hemisphere, with the incoming Kast Administration.

    We continue to use all available tools to promote safety and security of our region.

    These actions are being taken pursuant to Section 212(a)(3)(C) and Section 221(i) of the Immigration and Nationality Act.

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  • February 19, 2026: Sanctions-Adjacent: State Department restricts Uzbek visa facilitators

    Imposition of Visa Restrictions on Uzbekistanis Facilitating Illegal Immigration to the United States

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, PRINCIPAL DEPUTY SPOKESPERSON

    FEBRUARY 19, 2026

    The Department of State has taken steps to impose visa restrictions on individuals in Uzbekistan identified as knowingly facilitating illegal immigration to our nation. This action applies to executives and senior officials at two Uzbekistan-based visa facilitation companies who knowingly provided travel services designed primarily for aliens intending to illegally immigrate to the United States. These actions are taken under Section 212(a)(3)(C) of the Immigration and Nationality Act (INA), which generally bars entry to those whose entry or proposed activities would have potentially serious adverse U.S. foreign policy consequences.

    Investigations indicate that individuals in Uzbekistan actively coordinated transportation for aliens, including minors, intending to illegally immigrate to the United States through airports and across borders to transit points in Central America, where many were later encountered attempting to enter the United States illegally.

    The United States will not tolerate any attempts to undermine our national security or immigration laws. The Department will ensure those who profit from illegal immigration face consequences, and we will aggressively target smuggling networks to protect our borders and national security. The United States reaffirms its deep appreciation to the Government of Uzbekistan for its close cooperation to shut down the criminal networks that facilitate illegal immigration to the United States.

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  • February 18, 2026: Sanctions-Adjacent: Visa Restrictions for Iranian officials & telecom officials

    Announcement of Additional Visa Restriction Targets for Individuals Involved in Inhibiting Iranians’ Rights to Freedom of Expression

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, PRINCIPAL DEPUTY SPOKESPERSON

    FEBRUARY 18, 2026

    During Iran’s nationwide protests in December 2025 and January 2026, the Iranian regime has unleashed violence and repression against tens of thousands of peaceful demonstrators. The regime imposed a near-total nationwide internet shutdown, unprecedented in scope and duration, that severely restricted independent documentation of abuses and cut Iranians off from the world. Even today, the regime continues to restrict the ability of Iranians to exercise their basic freedoms. As President Trump has made clear, the United States stands with the Iranian people.

    Today, pursuant to his authority under Section 212(a)(3)(C) of the Immigration and Nationality Act, Secretary Rubio is taking steps to impose visa restrictions against 18 Iranian regime officials and telecommunications industry leaders, as well as their immediate family members. This visa restriction policy will target individuals who are complicit, or believed to be complicit, in serious violations of human rights, particularly inhibiting the right of Iranians to free expression and peaceful assembly. 58 individuals have now been targeted by this policy.

    The United States will continue to stand with the right of the Iranian people to free expression. We reaffirm our unwavering support for Iranians and their demand for peace and dignity. We will continue to use all tools available to expose and promote accountability for the abuses by Iranian regime officials and other individuals.

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  • February 3, 2026: DFAT updates its Iran sanctions

    Notice of Changes to the Consolidated List – 3 February 2026

    DFAT updated the Consolidated List on 3 February 2026 pursuant to the below listed legislative instrument made by the Minister for Foreign Affairs.

    The updated Consolidated List can be downloaded from the following page:Consolidated List | Australian Government Department of Foreign Affairs and Trade

    Australian Sanctions Office

    _______________________________

    Australian Sanctions Office | Regulatory and Legal Policy Division

    Department of Foreign Affairs and Trade

    dfat.gov.au | X | Facebook | Instagram | LinkedIn

    F2026L00077Download

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