On 12 February 2026, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a US$1,720,000 civil settlement with a Florida-based elite boarding school and athletic training complex.1 The settlement resolved apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations2 from routine tuition enrollment and payment activity involving sanctioned individuals. The following day, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced the launch of a new, dedicated whistleblower portal to receive confidential tips relating to fraud, money laundering, and sanctions violations.3
Viewed together, these developments underscore a coordinated enforcement strategy: broaden the universe of regulated actors subject to sanctions risk, and simultaneously expand the government’s ability to learn about violations through incentivized whistleblowers. Institutions that historically viewed sanctions compliance as peripheral—and that rely heavily on third party payment arrangements—now face heightened regulatory and whistleblower reporting risk. These risks are further amplified where business activity touches Latin America, a region that remains a focal point of US counter narcotics, anti money laundering, and sanctions enforcement efforts.
Indeed, as US authorities intensify their efforts against drug...
What the Department of Justice’s 2025 FCA Recoveries Signal for 2026: Health Care, Cyber, and Customs The DOJ and relators’ bar continues to aggressively deploy the False Claims Act across a varie...