The International Enforcement Law Reporter

The International Enforcement Law Reporter is a monthly print and online journal covering news and trends in international enforcement law.

Since September 1985, the International Enforcement Law Reporter has analyzed the premier developments in both the substantive and procedural aspects of international enforcement law. Read by practitioners, academics, and politicians, the IELR is a valuable guide to the difficult and dynamic field of international law.

OFAC Designates Law Firms, Corporate Service Providers and Shipping Agents of Iran’s Shadow Fleet Networks

Friday, October 23, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
11
Abstract: 

                On October 21, 2026, the U.S. Department of Treasury Office of Foreign Asset Control (OFAC) announced that, as part of Operation Economic Outcast and pursuant to Executive Order (E.O.) 13902, it sanctioned Panama- and Greece-based law firm Karnakis and Karnakis, which allegedly has supported illicit Iranian shipping activity for years.  Hence, OFAC alleges the firm indirectly helped Tehran’s ability to generate revenue to fund its military, weapons, and nuclear programs.

Sweden Extradites Russian National Alexander Suvorov to the United States on Export-Control and Sanctions-Evasion Charges

Friday, October 23, 2026
Author: 
Ana-Lucia Chalmers
Volume: 
42
Issue: 
11
Abstract: 

                On October 15, 2026, Sweden extradited Russian national Alexander Suvorov, 52, to the Northern District of New York on export-control and sanctions-evasion charges. The case suggests the United States’ ability to obtain custody of a defendant whose alleged conduct ran through a third jurisdiction, here Hong Kong, even though Sweden did not incorporate the treaty provision that shields such offenses from dual-criminality objections.

INTERPOL’s Madre Tierra VIII Operation Successful

Friday, October 23, 2026
Author: 
Gavin Neff
Volume: 
42
Issue: 
11
Abstract: 

                Operation Madre Tierra VIII, an INTERPOL coordinated operation between nine countries in Latin America and the Caribbean, successfully dismantled several criminal networks related to environmental crime.  The operation, which took place between June 1 and July 31, 2026, made 233 arrests, the recovery of over 1,000 animals and the identification of 60,000 hectares of illegally cleared forest.  Madre Tierra VIII involved Colombia, Costa Rica, the Dominican Republic, El Salvador, Guatemala, Honduras, Mexico, Nicaragua and Panama.

U.S. Imposes $1.21 Billion in Penalties against Bank of America

Friday, October 23, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
11
Abstract: 

              On October 13, 2026, the United States Department of the Treasury announced enforcement actions taken by the Treasury, the Office of the Comptroller of the Currency (OCC), and the Office of Foreign Assets Control (OFAC) for violations of anti-money laundering and sanctions laws.  The actions include the third-largest penalty in Treasury’s history and the largest in OCC history.[1]

Trump Waives Russian Sanctions in the Lindsey Graham Act

Friday, October 23, 2026
Author: 
Gavin Neff
Volume: 
42
Issue: 
11
Abstract: 

            On October 16, 2026, President Donald Trump released an executive order waiving Russian sanctions in the Lindsey Graham Act, just days before they were to take effect. Section 115 of the Act allows for the president to waive the application of any sanctions provision with respect to a foreign person, any restriction with respect to a person, and any duty under the Graham Act, subject to the Congress of a written certification that such a waiver is in the national interest of the U.S., and a report explaining the basis.

Fugitive in Venezuelan Money Laundering Case Extradited to the U.S. to Face Trial

Friday, October 16, 2026
Author: 
Gavin Neff
Volume: 
42
Issue: 
11
Abstract: 

               Alvaro Pulido Vargas, also known as German Enrique Rubio Salas, a Colombian national of 62, was extradited to the U.S. on October 11, 2026, and faces bribery and money laundering charges. Vargas was indicted in 2019 and 2021 on charges of laundering more than $2 billion in bribery and fraud schemes tied to Venezuelan President Nicolas Maduro’s regime.  Prior to these alleged offenses, Vargas had a history of drug trafficking, including a 1997 conviction in Italy under the German Enrique alias.  Maduro was captured by the U.S. military in January 2026.

Spanish Government Allows Extradition Request for American Activist to Move to the Next Step

Friday, October 16, 2026
Author: 
John Capwell
Volume: 
42
Issue: 
11
Abstract: 

                After a September 22 decision by the Spanish Council of Ministers, the decision of whether to honor a U.S.-issued extradition request has proceeded to the Spanish courts.  James “Fergie” Cox Chambers, multi-millionaire and controversial pro-Palestine activist, was arrested in July by Spanish authorities while vacationing in Ibiza with his family.  Chambers was held after an Interpol Red Notice was issued at the request of the United States and awaits a decision by the Spanish courts as to whether to honor the U.S. extradition request.

State-Facilitated Migration and the Limits of Transnational Enforcement: Spain’s Ceuta Ruling in Comparative Perspective

Friday, October 16, 2026
Author: 
Abigail Lee
Volume: 
42
Issue: 
11
Abstract: 

               On June 29, 2026, Spain’s Supreme Court issued a landmark ruling defining the operational limits of maritime border interdiction in the enclave of Ceuta. The Court held that border control authorities cannot execute immediate summary returns of migrants intercepted at sea without initiating formal administrative removal proceedings and verifying individual legal status.  The decision targeted police practices under Spain’s Ley de Extranjería, clarifying that migrants intercepted at sea or while swimming into the enclave have not crossed a land border post where summary rejection protocols apply, thereby triggering full constitutional due process and administrative removal protections.  This ruling reinforces established jurisprudence from the Court of Justice of the European Union (CJEU), such as M.A. v. Valstybės sienos apsaugos tarnyba (C-72/22), which limits Member States’ ability to derogate from fundamental procedural safeguards during heightened border pressure.

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