OFAC says Francesca Albanese designation is not being enforced under D.D.C. injunction
→Sanctions-screening teams should treat the Francesca Albanese designation as non-operative while the D.D.C. injunction remains in effect
Change
On May 13, 2026, the U.S. District Court for the District of Columbia enjoined the U.S. Department of State, U.S. Department of the Treasury, U.S. Department of Justice and persons acting in active concert with them from implementing or enforcing the designation of Francesca Albanese under Section 1(a)(ii)(A) of Executive Order 14203 while the order remains in effect.
Why it matters
The injunction removes the operative enforcement basis for the Francesca Albanese designation during the order’s effective period. Sanctions teams that screen against OFAC-related designations need to distinguish this enjoined designation from enforceable sanctions listings to avoid treating a blocked measure as currently operative.
Implications
- → Sanctions-screening teams must treat the Francesca Albanese designation as non-operative while the D.D.C. injunction remains in effect — screening, escalation or blocking workflows that treat the designation as enforceable may misstate the current US sanctions position.
- → Financial institutions and sanctions compliance teams maintaining OFAC-related controls must update internal notes, case guidance or list-handling logic for the Francesca Albanese designation — failure to flag the injunction risks applying an enforcement status that OFAC says is not currently being implemented.
- → US government personnel at the Department of State, Department of the Treasury and Department of Justice, and persons acting in active concert with them, must not implement or enforce the Francesca Albanese designation while the injunction remains in effect — enforcement action during that period would violate the court order.
Full decision brief
See the decision layer
Use 1 free preview to unlock implications, who’s affected, what to watch, and Clarify for this brief.
2 free previews left this month · Resets 1 Jun
Source
View on OFAC