OFAC's enforcement focus has shifted. It is no longer primarily about whether you knowingly dealt with a sanctioned party. It is about whether your business relationships and banking arrangements create exposure you have not assessed, and whether your legal and compliance functions can demonstrate they looked past corporate formalities to the underlying economic reality. For GCs, that is a materially higher bar than most programs are built to meet.

• Understand where your company's business relationships, banking arrangements, and supply chain create sanctions exposure you may not have assessed, including the secondary sanctions risks in corridors like China, the UAE, Turkey, and India that are drawing significantly more OFAC scrutiny in 2026.
• Learn how OFAC's expanding gatekeeper enforcement posture puts legal and professional service functions directly in the crosshairs, and what "looking past corporate formalities" means for how you structure and document transactions.
• Walk away with a gap assessment framework you can run against your current sanctions and AML program, focused on the specific failure patterns regulators are finding most actionable right now.