Ongoing efforts to end the war in Ukraine, the construction and demolition of international trade barriers, the reassimilation of Syria into the global economy and other significant geopolitical events continue to dominate headlines as we head into 2026. Economic sanctions remain a key foreign policy tool for responding to international crises, but as sanctions regimes grow more nuanced and compliance expectations mount, how can organizations keep their footing on shifting sands? We outline key areas to watch in the coming year.
1. Russia remains a priority as new policy areas of focus emerge and grow in significance.
The U.S., U.K. and EU have continued to direct sanctions implementation and enforcement efforts toward Russia, particularly as political pressure mounts to find a resolution to the war in Ukraine. However, the Trump administration has also aggressively imposed sanctions against cartels, foreign terrorist organizations and other transnational criminal organizations. We expect this focus to continue, along with the administration’s “maximum pressure” campaign against Iran, which is now the target of additional U.K. and EU sanctions following the recent United Nations Security Council snapback process. Companies need to continue to proactively monitor sanctions risks across geographies as policy priorities change.
2. Enforcement activity remains high and is likely to increase.
Enforcement activity was high but relatively steady in 2025. As authorities in the U.S., U.K. and EU increase spending and allocate additional resources to enforcement units, and the tools available to enforcement agencies continue to grow, the volume and scope of sanctions enforcement is likely to grow apace. As enforcement risks expand, companies will want to make sure that compliance teams and programs are appropriately resourced.
3. Countries are balancing China’s dual roles as key trading partner and geopolitical rival.
Authorities in the U.S., U.K. and EU will continue grappling with China’s growing geopolitical assertiveness in light of its unique role as a critical economic partner. China remains integral to global supply chains and a major market for exports and investments, but is increasingly focused on technological superiority and advancing its national security interests. While the second Trump administration is using a host of policy measures, particularly tariffs and export controls, to manage the United States’ economic relationship with China and protect the ongoing viability of the fledgling U.S.-China trade deal, whether and to what extent the EU and U.K. will follow remains to be seen.
4. Points of divergence between U.S., U.K. and EU sanctions may grow amid differing policy priorities and frustration with the pace of Russia-Ukraine negotiations.
Since the start of Russia’s invasion of Ukraine, considerable international coordination has occurred among the U.S., U.K. and EU, and more broadly among the G7, regarding the implementation of sanctions against Russia. This collaboration has extended to other sanctions programs, such as the recent designations by U.S. and U.K. authorities of the Prince Group and certain of its affiliated individuals and entities. While we expect collaboration to continue, differences in policy priorities, economic realities and legal frameworks will likely lead to increasing divergence in the scope of future measures and enforcement activity. The desire for a swift and comprehensive resolution to the war in Ukraine could exacerbate any such divergences.
5. The legal fate of U.S. tariffs may change the Trump administration’s current approach to trade policy.
The Trump administration has increasingly turned to tariffs to advance foreign policy and international trade objectives. The U.S. Supreme Court is considering a legal challenge to the administration’s use of the International Emergency Economic Powers Act — one of the key statutory authorities underlying most U.S. sanctions programs — to implement tariffs. The outcome of the case may significantly influence the Trump administration approach to trade policy, potentially by raising the profile of sanctions, export controls and other measures as means to influence global trading partners.
6. Authorities will continue to expand sanctions’ extraterritorial reach.
The U.S. has historically taken a broad view of the applicability of sanctions outside its borders. For many years, so-called secondary sanctions — which do not require a U.S. jurisdictional nexus to apply — have been a key factor in the pressure that U.S. sanctions can exert to influence the actions of non-U.S. parties. The U.K. and EU have followed suit (though to a lesser extent), particularly with respect to their Russia-related sanctions regimes, as evidenced by the EU’s focus on non-EU subsidiaries. We expect this trend to continue into 2026 as the U.S., EU and U.K. bolster efforts to intensify Russia and Iran sanctions. Companies should continue to monitor sanctions risks wherever they are doing business, but particularly in jurisdictions associated with sanctions evasion in parts of the Commonwealth of Independent States (CIS region) and Asia.
7. Compliance remains a struggle under growing regulatory requirements and expectations.
Although the imposition of sanctions typically drives increased compliance challenges, the lifting of sanctions can also require close monitoring, particularly where some restrictions remain in place. Syria provides the most recent example. Although the U.S., U.K. and EU have to varying degrees relaxed their respective Syria sanctions programs in recent months — and significantly so, in the case of U.S. sanctions — commercial activities or investments in Syria continue to present risk. A number of individuals and entities tied to the former Assad regime remain sanctioned, and Syria’s geographic proximity and historical commercial ties to jurisdictions such as Russia and Iran mean activities in or involving Syria can potentially implicate those other sanctions programs as well. Organizations considering entry into the Syrian market should therefore continue to exercise caution when capitalizing on new opportunities.
8. Whistleblowing will continue to serve as a key method of intelligence gathering as the U.K. follows the U.S. and enters the whistleblower sweepstakes.
Whistleblowing is an increasingly important tool by which authorities uncover sanctions violations, gather intelligence and bring enforcement actions. With the U.K. Serious Fraud Office and His Majesty’s Revenue and Customs both considering launching incentive schemes for whistleblowers in the coming year, the U.K. appears to be following the United States’ lead in expanding efforts to incentivize whistleblowers to come forward. Organizations in the U.K. and beyond should assess the robustness of their whistleblower policies and processes to encourage internal reporting of issues for prompt investigation and addressing.
9. Authorities will increasingly use economic tools beyond sanctions to address foreign policy and national security threats.
While authorities have historically used sanctions as the preferred economic policy tool in responding to foreign policy and national security threats, sanctions are seldom used in isolation. We expect this trend to accelerate. In addition to expanded export controls, authorities will likely deploy more novel tools in conjunction with, or as an alternative to, sanctions. Such tools include tariffs, “special measures” under U.S. anti-money laundering authorities, supply chain restrictions and more onerous inbound and “outbound” foreign investment reviews, among others. Wherever possible, companies should break down silos within their compliance functions to ensure they can review and address potential issues holistically.
10. Governments are using, and will likely continue to use, sanctions in novel ways.
Authorities are turning to sanctions to address foreign policy issues traditionally handled through diplomacy. For example, shortly after coming into office, the second Trump administration launched the International Criminal Court sanctions program, targeting several judges and prosecutors at the court. The United States has also used human rights-related sanctions authorities to sanction a justice of the Brazilian Supreme Federal Court. We expect U.S. authorities, as well as those in the U.K. and EU, to continue to expand the scope of traditional sanctions targets.