With strikes in the Middle East and Iran’s blockade of the Strait of Hormuz continuing throughout March, Iran has remained the focus of western sanctions. The US began the month with the designation of Iran as a state sponsor of wrongful detention, while the EU later added 16 people and three entities under its Iran human rights regime, renewing the programme until April 2027. Enforcement against Iranian oil networks intensified through multiple US forfeiture actions and a complaint seeking forfeiture of a tanker and 1.8 million barrels of crude oil allegedly supporting the Islamic Revolutionary Guard Corps.
Sanctions activity in March also focused heavily on Russia. Western authorities continued tightening pressure on Russia through new EU designations linked to the massacre of civilians in the Kyiv suburb of Bucha in early 2022 and foreign information manipulation, as well as through enforcement actions targeting vessels associated with Russia’s shadow fleet. Delistings in March highlighted continued legal and evidentiary scrutiny of sanctions listings, including the EU’s removal of Dutch oil trader Niels Troost. Formerly the only EU national sanctioned under the programme, Troost had been designated in December 2024 in connection with allegations that a subsidiary of his company traded Russian-origin oil above the G7 price cap.
Enforcement actions were widespread across the US, UK and Europe. France, Denmark and Belgium seized vessels connected to Russian or Iranian shadow fleet, while the UK announced that armed forces and law enforcement officers will be able to intercept sanctioned vessels in UK waters. International regulators imposed financial penalties, including OFAC’s $1.1 million settlement with TradeStation Securities and OFSI’s £390,000 fine on Apple Distribution International Ltd for Russia sanctions breaches. Elsewhere, the US and UK continued to issue designations across counterterrorism, cyber, narcotics, Belarus, Syria, Sudan and Southeast Asia scam-centre activity.
Iran
- The month began with the US designating Iran as a “state sponsor of wrongful detention,” the first designation under Executive Order 14348. The State Department said the designation reflected Iran’s detention of “innocent Americans, as well as citizens of other nations, to use as political leverage against other states” and stated that further measures could include a geographic travel restriction on US passports to, through, or from Iran.
- US enforcement against Iranian oil networks intensified during March. On 2nd March the Department of Justice filed a complaint seeking forfeiture of the M/T Skipper and the 1.8 million barrels of crude oil on board, alleging that since at least 2021 the vessel had moved crude oil from Iran and Venezuela for the IRGC’s benefit. On 10th March the DoJ filed two civil forfeiture complaints seeking $15.3 million allegedly linked to a shipping network operated by Mohammad Hossein Shamkhani, whom OFAC sanctioned in July 2025.
- The US additionally issued a General Licence on 23rd March authorising the sale, delivery, offloading and related importation into the US of Iranian-origin crude oil and petroleum products already loaded on vessels on or before 20th March 2026. The licence expires on 19th April 2026 and excludes persons located in or organised under the laws of North Korea, Cuba, Crimea, or territory controlled by the Donetsk and Luhansk People’s Republic regions of Ukraine.
- The EU also increased pressure on Iran in mid-March by adding 16 individuals and three entities to its Iran human rights sanctions regime. Those designated included members of the Iranian judiciary and the head of Tehran’s cyber police, as well as two branches of the IRGC: the Mohammad Rasulullah Corps and Imam Reza. At the end of the month, the EU renewed its Iranian sanctions regime until 13th April 2027.
Russia
- Russia remained the dominant sanctions theme of the month. On 16th March, the EU renewed its targeted Russia sanctions regime until 15th September 2026. The following day, the EU added nine individuals for alleged responsibility for the Bucha massacre, a series of killings of civilians in the Kyiv suburb of Bucha during Russia’s occupation in early 2022, including Colonel General Aleksandr Chayko, while four individuals were designated under the Russia hybrid threats regime for foreign information manipulation and interference, including British blogger Graham Phillips. The EU, however, removed two individuals, including oil trader Niels Troost, who was the only EU national on the list. Elsewhere, the UK removed two individuals from its sanctions lists, and the US removed nine individuals along with their designated companies.
- Alongside these measures, March also saw significant litigation and delisting developments. The Russian Central Bank began proceedings before the EU General Court challenging Regulation 2025/2600, which freezes the Bank’s assets and reserves held in the EU and removes the prior requirement for unanimous six-monthly renewal. Separately, the European Court of Justice held that a 50% shareholding by a designated person creates a rebuttable presumption of control for the purposes of EU asset freezes, though non-designated companies must be able to challenge national decisions freezing their funds.
- Licensing and waivers affecting Russia and related trade also featured prominently. The US issued a General Licence authorising the sale, delivery or offloading of Russian-origin crude oil and petroleum products loaded on vessels on or before 12th March 2026, valid until 11th April 2026. Earlier in the month, it had authorised the delivery and sale of Russian-origin crude oil to India until 4th April 2026 and transactions involving two German Rosneft subsidiaries. OFAC also extended the operating licence of Serbia’s NIS, a Gazprom Neft subsidiary, until 17th April 2026. The UK issued a general licence authorising activities relating to Kazakh-origin crude oil transiting Russia and extended its general licence covering bond amendments and restructurings for non-designated persons until 26th March 2028.
Enforcement
- March saw a notable escalation in vessel-related sanctions enforcement. Denmark seized the Nora, a US-sanctioned vessel found to be sailing under a false Comoros flag, while Belgian authorities, assisted by the French military, seized the Ethera, a vessel sanctioned by the US for being part of Iran’s shadow fleet. France also seized the MV Denya in the Mediterranean off the Algerian coast while it was sailing from Russia to Egypt; the vessel had been designated by the EU and UK as part of Russia’s shadow fleet. At the end of the month, the UK Prime Minister’s Office announced that UK armed forces and law enforcement officers will be able to intercept sanctioned vessels in UK waters, with each target vessel to be considered individually before an operation is executed.
- Financial and corporate enforcement was also significant. OFAC reached a $1.1 million settlement with TradeStation Securities Inc for 481 apparent breaches of US sanctions involving Iran, Syria and Crimea after failures in geo-blocking and IP monitoring allowed customers in sanctioned jurisdictions to access online investment services. In the UK, OFSI fined Apple Distribution International Ltd £390,000 for two payments totalling £636,000 made in 2022 to Okko LLC, an entity owned by a UK-designated person. OFSI described the matter as the first use of its settlement mechanism to resolve a sanctions case.
- The US also pursued a number of criminal enforcement cases. A Uruguayan national pleaded guilty to agreeing to use an unlicensed money services business to transfer $99,500 from the Dominican Republic to Florida in order to circumvent sanctions linked to a sanctioned Venezuelan government official. Separately, Tomás Niembro Concha, the former CEO of Puerto Rican bank Nodus International, pleaded guilty to conspiring to breach US Venezuela sanctions and wire fraud, agreeing to forfeit $16.9 million. Three US nationals were sentenced after pleading guilty to helping North Korean IT workers gain access to US-based computer networks under false identities in breach of US and UN sanctions.
- US authorities also continued export-control enforcement connected to China. On 20th March, three individuals were charged over alleged exports of advanced AI chips to China through Taiwan and another company in Southeast Asia, with the DoJ alleging that approximately $2.5 billion worth of servers assembled in the US were diverted to China in breach of export control laws. On 26th March, a separate case charged three individuals with conspiracy to commit export-control and smuggling violations by attempting to export servers containing controlled microchips to China through a purported Thailand-based end user.
Other Designations, De-Listings and Regulatory Updates
- The US, UK, EU and UN remained active across other sanctions regimes throughout March. In the counterterrorism sphere, the US designated the Sudanese Muslim Brotherhood as a Specially Designated Global Terrorist, warning that it also plans to designate the organisation as a Foreign Terrorist Organisation, while modifying the designation of the Al-Baraa Bin Malik Brigade to reflect its status as an armed wing of the Sudanese Muslim Brotherhood. The US also designated 10 individuals and six entities linked to a global Hizballah-financing network led by Alaa Hassan Hamieh, and sanctioned six people and six entities tied to North Korea’s IT worker scheme and Hamas sham charities.
- The UN Security Council’s ISIL/Al-Qaeda sanctions committee added Abd El Hamid Salim Ibrahim Brukan al-Khatouni and Sami Jasim Muhammad Jaata al-Jaburi to its list, while earlier in the month it had removed the Al-Nusrah Front from that regime. Meanwhile, the UK imposed sanctions under its Global Human Rights regime on six individuals and four companies said to be involved in scam centres in Southeast Asia.
- Following the release of 250 prisoners by the Government of Belarus, the US removed sanctions on three companies and authorised transactions involving the Belinvest Group. The US also rescinded a prohibition on all transactions with Belarus’s Ministry of Finance and the Development Bank of Belarus. The US also amended several licences authorising transactions and imports relating to Venezuela’s petrochemical, electricity, oil, gas, gold and wider minerals sectors.
- Elsewhere, the EU renewed its Bosnia and Herzegovina sanctions regime until 31st March 2027. The EU also renewed its sanctions regime targeting the misappropriation of Ukrainian state funds until 7th March 2027. In Syria-related litigation, the General Court rejected Samer Al Dibs’ challenge to his 2024 and 2025 relistings under the EU Syria sanctions regime, holding that the Council had lawfully established his continuing links to former Assad-era business networks.
