Sanctions in April were dominated by escalating tensions between the US and Iran, including the announcement of a US maritime blockade targeting vessels entering and exiting Iranian ports, alongside parallel negotiations on potential sanctions relief if Iran agreed to certain terms in a broader geopolitical settlement. The US significantly expanded its sanctions programme through multiple, large-scale designation waves targeting Iran’s oil, shipping and financial sectors, including networks facilitating crude oil exports, procurement of military equipment, and the operation of Iran’s shadow banking architecture.
Sanctions activity in April also focused heavily on Russia, particularly following the EU’s adoption of its 20th sanctions package. The package introduced wide-ranging measures targeting Russia’s energy, financial services, military-industrial and trade sectors, including sanctions on 36 individuals and entities and 46 vessels, transaction bans on 20 Russian banks, new crypto-asset restrictions, and the activation of the EU’s anti-circumvention tool for the first time.
Enforcement and regulatory developments were also prominent across jurisdictions. Authorities in the US, UK and EU pursued sanctions evasion and export-control cases involving Iran, Russia and North Korea, including extraditions, arrests and prosecutions linked to procurement networks and illicit financial flows. Governments also introduced new compliance-focused measures, particularly in the UK, where expanded end-use controls and new licensing requirements were implemented to address diversion risks and strengthen oversight of exports to third countries.
Iran
- The US announced a maritime blockade applying to vessels entering and exiting Iranian ports, stating that naval forces may interdict vessels in international waters linked to Iran. This was accompanied by parallel diplomatic engagement, with the US indicating that sanctions relief could be negotiated as part of a broader geopolitical settlement. The US concurrently expanded its sanctions programme through multiple designation waves targeting Iran’s financial system. On 28th April, the US designated 35 individuals and entities responsible for overseeing Iran’s shadow banking architecture. Those designated included entities linked to major Iranian financial institutions, including companies associated with Bank Melli, Bank-e Shahr, Eghtesad Novin Bank, Tourism Bank and Parsian Bank, as well as front companies used to facilitate financial transactions within Iran’s financial sector.
- Further designations targeted Iran’s oil export infrastructure and sanctions evasion networks. The US designated Hengli Petrochemical (Dalian) Refinery Co, a Chinese teapot refinery, for receiving Iranian oil shipments, alongside 19 entities operating vessels used to transport Iranian oil and 19 vessels owned by those entities. The US also designated additional individuals, entities and vessels linked to shipping networks associated with Mohammad Hossein Shamkhani, targeting a network said to facilitate the export of Iranian oil in circumvention of sanctions. Separate measures also targeted networks linked to Hizballah involved in the exchange of Iranian oil for gold.
- Enforcement activity remained significant. US authorities pursued cases involving the export of restricted military goods and other controlled items linked to Iran, including the extradition of individuals involved in procurement networks supplying defence-related equipment, and arrests linked to attempts to export weapons to Sudan in breach of US sanctions and export-control laws. At the same time, limited licensing activity continued. The UK updated its Iran general licence to permit payments for cybersecurity and IT services, including provisions for reimbursement and currency conversion, with the licence remaining valid until October 2026.
Russia
- The EU adopted its 20th Russia sanctions package, introducing extensive measures targeting key sectors of the Russian economy. The package included sanctions on 36 individuals and entities and 46 vessels linked to Russia’s shadow fleet, bringing the total number of designated vessels to 632. It also introduced a transaction ban on 20 Russian banks and a sectoral prohibition on crypto-asset service providers established in Russia. The package introduced additional trade and export restrictions, including import bans on metals, chemicals and critical minerals not previously subject to sanctions, a quota on ammonia imports, and export restrictions on goods and services related to agriculture and cybersecurity. It also imposed measures targeting Russia’s military-industrial sector, including sanctions on 58 companies and individuals involved in manufacturing and tighter export controls on 60 entities contributing to Russia’s defence sector.
- A key feature of the package was the activation of the EU’s anti-circumvention tool, enabling restrictions on the export of certain goods to third countries, including the Kyrgyz Republic, where there is a risk of re-export to Russia. The package also introduced enhanced legal protections for EU companies, including mechanisms to recover damages and legal costs arising from third-country enforcement actions linked to sanctions. The EU also continued to impose targeted designations under its hybrid threats regime, including individuals involved in foreign information manipulation and interference, such as media figures and online actors linked to pro-Russian influence campaigns.
- Licensing and waivers remained a consistent feature. US and UK authorities extended licences allowing limited transactions involving Russian-origin oil and energy infrastructure, including continued authorisations affecting Serbian energy company NIS and transactions involving Russian financial institutions and state-linked funds. Litigation meanwhile continued to shape the Russia sanctions framework. The EU General Court, for example, rejected the application of Dmitry Konov, the head of Russia’s largest petrochemical company Sibur Holding, challenging his September 2024 and March 2025 re-listings.
Enforcement
- Authorities across multiple jurisdictions continued to pursue sanctions enforcement actions, including prosecutions, extraditions and sentencing in cases involving sanctions evasion, export-control breaches and illicit procurement networks linked to Iran, Russia and North Korea. Cross-border cooperation remained a key feature of enforcement activity. Several cases involved coordination between US and foreign authorities, including the extradition of individuals from overseas jurisdictions in connection with procurement networks supplying restricted goods to Iran.
- In the US, authorities extradited an individual in connection with a procurement network supplying restricted military goods to Iran, while a separate case involved the arrest of an individual accused of attempting to export weapons to Sudan in breach of US sanctions and export-control laws.
- Enforcement action also continued in relation to cyber-enabled sanctions evasion schemes. US authorities sentenced two individuals for their roles in facilitating North Korean IT workers gaining employment with US companies under false identities. The scheme purportedly affected more than 80 individuals and over 100 companies, with DPRK nationals using stolen or fabricated identities, remote access tools and US-based financial accounts to generate income in breach of US and UN sanctions.
- Additional enforcement activity targeted intermediaries and facilitators involved in sanctions evasion. In the US, authorities pursued cases linked to Iranian procurement and oil networks, including individuals involved in coordinating the shipment of restricted goods and facilitating financial transactions connected to defence-related exports and oil sales. These cases involved the use of intermediary jurisdictions, front companies and complex payment structures to move funds and goods, including networks linked to Iranian oil exports and procurement of controlled military equipment.
Other Designations, De-Listings and Regulatory Updates
- The US imposed sanctions on Cambodian senator Kok An and 28 individuals and entities linked to a network of scam centres operating from Cambodia, which were alleged to have defrauded US citizens through digital-asset investment schemes. The US also designated 23 individuals and companies linked to a synthetic opioid supply chain associated with the Sinaloa Cartel, targeting Indian pharmaceutical suppliers of fentanyl precursors, Mexican and Guatemalan brokers and logistics companies, and individuals directly linked to cartel operations.
- The UN added four individuals to its Sudan sanctions list for their roles in procuring weapons and recruiting and financing foreign mercenaries, including Colombian nationals deployed to support the Rapid Support Forces. These designations targeted procurement, recruitment and financing functions within the network.
- The UK introduced significant regulatory changes to its sanctions framework. This included the introduction of new end-user licensing requirements across 36 regimes, revised financial monitoring thresholds to £10,000, and expanded the scope of prior obligations licensing grounds.
- The EU renewed its Myanmar sanctions regime until 30th April 2027, maintaining restrictions targeting 105 individuals and 22 entities, including members of the military-controlled State Administration Council responsible for human rights violations. The EU also extended its Moldovan sanctions programme until 29th April 2026, whilst the UN renewed its Libyan sanctions regime until August 2027.
