OFAC continued active enforcement in the first quarter of 2026. OFAC’s Q1 enforcement actions involved a range of industries, underscoring the continued importance of effective policies, controls, screening, and testing. We highlight one of OFAC’s three Q1 enforcement actions below.

TradeStation Securities: On March 17, OFAC announced a $1.11 million settlement with TradeStation Securities, a Florida-based brokerage firm, to resolve 481 apparent violations of the Iran, Syria, and Ukraine-/Russia-related sanctions programs. According to OFAC, between June 2021 and June 2022, TradeStation’s mobile platform processed 481 trades worth approximately $4.4 million for users located in Iran, Syria, and Crimea. Notably, the violations were not the result of an absence of sanctions controls altogether. OFAC found that TradeStation had a sanctions compliance program, but that failures in TradeStation’s IP address detection and geo-blocking controls, as well as inadequate testing of those controls, allowed users in sanctioned jurisdictions to continue accessing TradeStation’s mobile platform and executing trades. OFAC determined that the matter was non-egregious. TradeStation also voluntarily self-disclosed the conduct and took significant remedial measures after it discovered the issues. The action is a reminder that even firms with carefully designed compliance systems in place can face exposure where controls are not adequately tested and maintained.