Sanctions in September have once again centred on Russia and Iran. The US enacted the Lindsey O. Graham Sanctioning Russia and Iran Act, providing for tariffs of up to 500% on Russian goods and further restrictions on banks, defence suppliers and energy trade. The EU extended its targeted Russia sanctions framework to September 2029, replacing six-monthly renewals, while removing several prominent business figures from its list.
Pressure on Iran broadened across trade, banking and aviation. The UK published legislation restoring sectoral restrictions, while the US designated 35 aviation-related entities and one individual, suspended aviation authorisations and introduced a presumption of denial for specific licences. Further US measures targeted banks, digital-assets businesses and intermediaries supporting the Islamic Revolutionary Guard Corps (“IRGC”) and Hizballah. Russia and China meanwhile blocked the renewal of the UN panel monitoring Iran sanctions.
Enforcement included UK corporate settlements exceeding £12 million, a £53 million London property freeze and US proceedings seeking approximately $61 million in cryptocurrency allegedly derived from Iranian oil sales. Export-control convictions and an Iran-related civil settlement added to US enforcement activity. Wider developments included an announced increase in UK financial sanctions penalties, proposed restrictions on Israeli settlement trade, and the expiry of the US Ethiopia sanctions emergency.
Russia
- The US enacted the Lindsey O. Graham Sanctioning Russia and Iran Act on 18th September 2026. The law introduces measures against Russian officials, the Central Bank and state-owned banks, foreign suppliers to Russia’s defence sector and operators of vessels carrying Russian oil. It also mandates restrictions on new US investment, US energy exports and purchases of Russian sovereign debt, an end to Russian uranium imports, and tariffs of up to 100% on countries purchasing Russian oil or gas.
- The EU renewed Russia sanctions under Regulation 269/2014 for three years, until 22nd September 2029. Annual reviews of individual listings will continue, but will no longer automatically generate new listing decisions that can be separately challenged in court. The EU removed Alisher Usmanov, Mikhail Fridman, Andrey Falaleev and Redbird Corporate Services Ltd, alongside three deceased individuals. Reuters and the Financial Times reported French support for Usmanov’s removal to facilitate an Azerbaijani prisoner-release agreement, and Luxembourg’s support for Fridman’s removal because of his $16 billion investment arbitration claim.
- The US Bureau of Industry and Security renewed one-year export-denial orders against Aeroflot, Azur Air and UTair, citing continuing apparent export-control breaches. The US also issued General Licence 131J, allowing negotiations and contingent contracts for Lukoil International’s sale until 22nd October 2026. Completing a transaction still requires separate authorisation from OFAC.
Iran
- The UK published regulations restoring restrictions on energy goods, oil, petrochemicals, precious metals, maritime technology and sectoral software as of 29th September 2026. Financial measures restrict certain investments, lending, banking relationships, insurance and Iranian bonds. The regulations also expand powers over specified ships and prohibit Iranian aircraft from landing, subject to exceptions. Related licensing changes pertaining to the Shah Deniz gas field were scheduled for the same date, with the new licence subject to parliamentary approval. Separately, Russian and Chinese vetoes prevented renewal of the UN Iran Panel of Experts, whose mandate was scheduled to expire on 26th September 2026.
- The US aviation package covered 27 Iranian and eight non-Iranian entities, including companies allegedly assisting Mahan Air, and ECT Aviation Support owner Ibrahim Ali Mohamed Mohamed Mahran. The US suspended three aviation authorisations and its policy for licensing commercial aviation safety exports.
- The US designated Turkey’s Golden Global Yatirim Bankasi Anonim Sirketi and two controlled subsidiaries, alleging that the bank facilitated IRGC-Qods Force transactions and Iranian access to international banking. The US also added already-sanctioned VTB Bank to its Iran list over correspondent banking arrangements, efforts to move frozen Iranian assets and a rouble-rial settlement system. The designation carries secondary-sanctions exposure, meaning the US may also sanction parties materially supporting VTB.
- The US further designated three individuals and two entities in the digital-assets network of already-sanctioned Babak Zanjani, including BitBank and its software developer Pishtaz Simorgh Electronic Trade Company. Another package listed 14 individuals and five entities associated with Kata’ib Hizballah and Lebanese Hizballah for alleged financing, technological assistance and sanctions evasion supporting Iran. Targets included intermediaries transferring Iraqi funds and Iranian oil proceeds to Iran and Hizballah.
Enforcement
- OFSI agreed a £4,732,830.58 settlement with Citibank London Branch for Russia and anti-corruption sanctions breaches. Between February 2022 and July 2025, it processed 970 payments totalling £19.7 million. The case included 328 transactions worth £5.4 million involving entities owned or controlled by Sovcomflot, and 177 fee deductions from frozen accounts worth £135,000. OFSI identified screening failures, unscreened routing lists, incorrect licence application and delayed frozen-asset reporting. It found no intent to breach or circumvent sanctions, but classified the case at its highest severity level.
- Illumina Cambridge Limited paid HM Revenue and Customs a £7,438,840.13 compound settlement for Russia sanctions offences. Between July 2022 and January 2023, the company transferred sanctioned goods between two overseas group companies for export to Russia, breaching restrictions on making controlled goods available for Russian use. Illumina voluntarily disclosed the breaches.
- The US Attorney’s Office for the Southern District of New York filed a civil forfeiture complaint targeting approximately $61 million in cryptocurrency allegedly generated by sanctioned Iranian oil sales. Prosecutors alleged that Chinese companies Blessed Trust and Hexa Whale laundered proceeds through Binance accounts, including conversions involving US cryptocurrency issuers. A wider network allegedly distributed more than $1.5 billion to IRGC-related businesses and cryptocurrency addresses. Separately, the US District Court for the District of Columbia ordered forfeiture of cryptocurrency traced to North Korean information technology worker schemes.
- OFAC reached a $1,427,230 settlement with an unnamed US person over 39 apparent Iran sanctions violations between June 2019 and July 2021. These involved consultancy for an Iranian software company, Iranian dividends received into US accounts, shareholdings and an Iranian property purchase. OFAC treated the conduct as egregious and not voluntarily disclosed, but reduced the penalty for mitigating factors including cessation of the activity and inability to pay a larger amount.
- A court in Florida convicted Russian national and former Aeroflot employee Alexander Mamonov on 12 counts involving unlicensed exports of more than $900,000 in aircraft parts to Russia. He misled suppliers about destinations in the UAE and China.
- UK authorities froze a £53 million London townhouse owned by Zhao Chen, according to reporting by the Organised Crime and Corruption Reporting Project. The freeze concerned her association with UK-sanctioned Wu An Ming, an alias of Hu Xiaowei, whom the organisation reported to be her husband. Hu was designated for alleged involvement with the Prince Group and faces asset freezes in Hong Kong, a money laundering investigation in Singapore and an indictment in Taiwan.
Other Designations, De-Listings, and Regulatory Updates
- The UK designated five Israeli settlers and Hizballah financing organisation Al-Qard Al-Hasan. It announced planned bans on settlement goods and services to settlers, including financing, with legislation expected within six to nine months. Canada and France also announced settlement trade bans. Separately, the US announced a further year of visa restrictions on Palestine Liberation Organisation and Palestinian Authority members.
- The US continued Cuba designations, listing former President Raúl Castro’s grandson Fidel Ernesto Castro Calis and five banking, mining and energy entities, followed by eight entities and three military officials associated with nickel production and weapons development. Elsewhere, it designated Chinese marketplace Xinbi Guarantee and two supporting companies for services to criminal networks and scam centres, and Ecuadorian gang Los Tiguerones as a Specially Designated Global Terrorist and a Foreign Terrorist Organisation for alleged narcotics trafficking and attacks on civilians and law enforcement.
- The US removed all listings under its Ethiopia sanctions programme after the national emergency expired on 18th September 2026. Designations had previously spanned the Eritrean Defence Forces and Eritrea’s ruling People’s Front for Democracy and Justice. Separate export-control amendments removed Ethiopia from the defence-export denial list, allowing licence applications to be considered individually.
- US Venezuela licences expanded to cover coal-related transactions, services and investment negotiations, while another licence postponed authorisation of certain Petróleos de Venezuela (PdVSA) bond transactions until 5th November 2026. The UN renewed Sudan sanctions until November while discussing a wider arms embargo.
- The US State Department revised its Munitions List, easing controls on certain aircraft fitted with defensive equipment and specified uncrewed underwater vehicles. The changes take effect on 13th and 19th October 2026. Servicing the aircraft’s defensive equipment remains controlled.
- The UK announced plans to raise OFSI’s maximum percentage-based penalty from 50% to 100% of the value involved in a breach. The existing ceiling is the greater of £1 million or 50% of that value.
