The UK imposed new designations targeting Russia’s drone supply chains, migrant trafficking networks, crypto-enabled sanctions evasion, and information warfare operations, while both the UK and EU designated individuals and entities linked to the forced deportation, militarisation, and indoctrination of Ukrainian children.  The UK also introduced new Russia trade and transport sanctions covering emerging technologies, Russian-origin uranium, refined oil products processed from Russian crude, LNG maritime services, construction services, and specified ships.

In notable sanctions enforcement,  OFAC reached a $275 million settlement with Adani Enterprises Limited for apparent breaches of the Iranian Transactions and Sanctions Regulations involving Iranian-origin liquefied petroleum gas, while OFSI imposed a £165,000 penalty on Deutsche Bank AG London Branch for Russia sanctions breaches involving payments to Okko LLC.  Elsewhere, the US introduced a new Cuba sanctions framework, while the EU, UN, and UK updated extended regimes covering Syria, Libya, cyber threats, and ISIL/Al Qaida.

Iran

• In parallel with the ongoing war in the Middle East, the US continued its “Economic Fury” campaign against Iran’s oil trade and financial networks. On 5^th May, OFAC and the State Department added six individuals, 21 entities, and one vessel to the Iran sanctions list. The measures principally targeted three Iranian foreign currency exchange houses as well as their front-company networks, which were said to facilitate billions of dollars in transactions annually on behalf of sanctioned Iranian actors, including the Central Bank of Iran and NIOC.

• The US also targeted Iranian-linked activity in Iraq’s oil sector. On 11^th May, the US designated four individuals and four entities, including Iraq’s Deputy Minister of Oil Ali Maarji Al Bahadly, for facilitating the diversion of Iraqi oil products to US-sanctioned Iraqi businessman Salim Ahmed Said and the US-sanctioned terrorist militia Asa’ib Ahl Al-Haq (“AAH”).  Other individuals designated included a leader and economic official of AAH, a former senior official of Kata’ib Sayyid al-Shuhada (“KSS”), and a senior KSS official.

• US measures later in the month targeted IRGC oil sales to China. On 13^th May, the US designated three officials of the IRGC’s Shahid Purja’fari Oil Headquarters for enabling the sale and shipment of Iranian oil.  The US also designated nine shell companies operating across Hong Kong, the UAE, and Oman.  These entities were said to have arranged, purchased, or facilitated IRGC oil shipments, including shipments worth tens of millions of dollars carried by sanctioned tankers.

• On 20^th May, the US added 60 individuals, entities, and vessels to its counterterrorism and Iran sanctions lists, combining measures against Hamas support networks and Iranian sanctions-evasion operations. The Iran-related designations targeted Ebrahimi and Associates Partnership Company, also known as Amin Exchange, together with associated front companies and vessels operating across the UAE, Turkey, and China.  The same package also added eight individuals and one entity for supporting Hamas, including individuals linked to a pro-Hamas flotilla attempting to reach Gaza and coordinators associated with Samidoun.

• At the end of the month, the US designated the Persian Gulf Strait Authority for being linked to the IRGC. The Authority is responsible for collecting tolls on behalf of the IRGC in the Strait of Hormuz, and OFAC issued a related alert on toll payments for passage through the Strait.  Separately, the EU amended its regime targeting Iranian support for Russia’s war in Ukraine, to cover people and entities involved in Iranian actions and policies impeding lawful transit passage and freedom of navigation, in particular in the Strait of Hormuz.

Russia

• The UK imposed a significant package of Russia-related designations on 5^th May, adding 35 individuals and entities under the Russia sanctions regime and the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025. The Russia sanctions designations targeted three groups: individuals and entities linked to Russia’s Alabuga Start programme, through which migrants are recruited to work in drone production facilities; suppliers of drones and drone components within Russia; and entities based in Thailand and China supplying drone components or dual-use goods to Russia.  The irregular migration designations targeted individuals and entities involved in trafficking foreign nationals into Russia and instrumentalising migration to destabilise Ukraine and Europe, marking the first use of the UK’s irregular migration regime for this purpose.

• The UK and EU also imposed sanctions linked to Russia’s deportation and indoctrination of Ukrainian children. The EU added 16 individuals and seven entities for responsibility for the unlawful deportation, forced transfer, and forced assimilation of Ukrainian children to Russia and occupied Ukrainian territories.  The EU stated that Russia has deported or forcibly transferred nearly 20,500 Ukrainian children since the start of its full-scale invasion, and that more than 130 individuals and entities are now sanctioned in connection with the abductions.

• The UK separately added 85 individuals and entities to its Russia sanctions list on 13^th May, covering two groups. 29 targets were linked to Russia’s campaign to deport and militarise Ukrainian children and a further 56 targets were linked to Kremlin information warfare, including 49 individuals working for the Social Design Agency (“SDA”), which the UK said had been tasked and funded by the Russian government to carry out influence operations designed to undermine democracy and weaken support for Ukraine, including planned interference in Armenian elections.

• Licensing and waivers affecting Russia-related trade continued alongside the new restrictions. The UK issued two general trade licences: one authorising certain imports of diesel and jet fuel processed from Russian-origin crude oil, and another authorising the maritime transportation of Russian LNG from the Sakhalin-2 and Yamal LNG terminals to third countries, or between third countries, until 1^st January 2027. The US also issued a general licence authorising the delivery and sale of Russian-origin crude oil and petroleum products already loaded on vessels on or before 17^th April 2026, extending the authorisation until 17^th June 2026.

• The UK further targeted Russian crypto-enabled sanctions evasion.  On 27^th May, the UK designated four individuals and 14 entities linked to the A7 crypto network, used by Russia to evade existing sanctions.  Targets included A7 director Sergey Mendeleev and OJSC Eurasian Savings Bank, a Kyrgyzstan-registered bank, as well as entities involved in Russia’s financial sector and Kyrgyz entities carrying on business of economic significance to the Russian government.

Enforcement

• OFAC announced a $275 million settlement with Adani Enterprises Limited (“AEL”) for over 32 apparent violations of the Iranian Transactions and Sanctions Regulations. Between 2023 and 2025, AEL imported Iranian-origin LPG from a Dubai supplier and sold it to customers in India.  OFAC found that AEL overlooked red flags indicating Iranian origin, including significantly discounted prices, vessel manipulation of Automatic Identification System (“AIS”) data, unexplained AIS dark periods, frequent name and flag changes, and at least one payment being stopped due to sanctions concerns.  AEL did not voluntarily self-disclose the apparent violations and OFAC treated the breaches as egregious, although the penalty was reduced to reflect cooperation and remedial measures.

• In the UK, OFSI imposed a £165,000 penalty on Deutsche Bank AG London Branch for breaches of sanctions on Russia. In 2022, the bank processed two transactions worth over £635,000 on behalf of a non-UK customer to Russian company Okko LLC while Okko was owned by UK-sanctioned JSC New Opportunities. The bank voluntarily disclosed the payments, but OFSI applied a 45% discount rather than the maximum 50% available for prompt and complete voluntary disclosure because the disclosure was not complete.  The case is the second OFSI enforcement action relating to Okko and New Opportunities, following the £390,000 penalty imposed on Apple Distribution International.

Other Designations, De-Listings and Regulatory Updates

• The US continued to impose counterterrorism sanctions across several regimes. Alongside Hamas-related designations, the US added nine Hizballah-linked individuals for obstructing the peace process in Lebanon and impeding Hizballah’s disarmament.  The EU separately agreed to sanction further Israeli settler groups and entities, as well as leading Hamas figures.

• US narcotics sanctions continued to target Sinaloa Cartel-linked networks. The US designated 11 individuals and two entities linked to the cartel’s fentanyl trafficking activities.  Targets included Armando de Jesus Ojeda Aviles, for leading a network involved in laundering proceeds of fentanyl and other narcotics trafficking activities, Jesus Gonzalez Penuelas, for leading an organisation trafficking illicit drugs into the US and laundering cartel funds, and Alfredo Orozco Romero, described as a security adviser and debt collector.  The two entities designated were Gorditas Chiwas and Grupo Especial Mamba Negra.

• The US removed Francesca Albanese, the UN Special Rapporteur on the Occupied Palestinian Territories, from the International Criminal Court sanctions list on 22^nd May following a temporary injunction in LC v Trump and OFAC’s notice that her designation would not be enforced for the duration of the injunction.  One week later, the US added her back to the same list, without indicating whether the designation was made on amended grounds.

• The EU rejected three appeals by members of the Makhlouf family and upheld their EU Syria sanctions listings, finding their evidence of estrangement from the family insufficient. These individuals were two daughters and a widow of Mohammed Makhlouf, a Syrian businessman and uncle of former President Bashar Al Assad.

• The EU and UN issued several regime renewals and guidance updates. The EU extended its cyber sanctions regime until 18^th May 2027 and amended entries relating to cyber threat groups APT10 and Wizard Spider.  The EU also renewed its Syria sanctions regime until 1^st June 2027, while removing seven entities including Syria’s Ministries of Defence and Interior to support strengthened engagement with Syria. Finally, the EU renewed its Russia human rights sanctions regime until 28^th May 2027, under which 72 individuals and one entity are currently listed.

• On 5^th May, President Trump signed a new Executive Order authorising sanctions on persons responsible for repression in Cuba, threats to US national security, serious human rights abuses, corruption, material support to the Cuban government, and activity in key sectors including energy, defence, financial services and security. The order also authorised secondary sanctions on foreign financial institutions that conduct or facilitate significant transactions with designated persons.  Across May, 12 individuals and five entities were designated under this framework, notably including Cuba’s Ministry of the Interior, the Policía Nacional Revolucionaria, the Directorate of Intelligence, and several senior government officials.

The post Sanctions Guide – May 2026 appeared first on Alaco.

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 30^th 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.

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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 2^nd 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 10^th 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 23^rd 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 20^th March 2026. The licence expires on 19^th 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 13^th April 2027.

Russia

• Russia remained the dominant sanctions theme of the month. On 16^th March, the EU renewed its targeted Russia sanctions regime until 15^th 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 12^th March 2026, valid until 11^th April 2026.  Earlier in the month, it had authorised the delivery and sale of Russian-origin crude oil to India until 4^th April 2026 and transactions involving two German Rosneft subsidiaries.  OFAC also extended the operating licence of Serbia’s NIS, a Gazprom Neft subsidiary, until 17^th 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 26^th 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 20^th 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 26^th 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 31^st March 2027. The EU also renewed its sanctions regime targeting the misappropriation of Ukrainian state funds until 7^th 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.

The post Sanctions Guide – March 2026 appeared first on Alaco.

In parallel, Western governments continued tightening sanctions on Russia. The UK introduced its largest sanctions package since the start of Russia’s full-scale invasion of Ukraine, designating nearly 300 entities, individuals, and vessels, including major energy companies Transneft and Rosatom. The EU also outlined plans for a 20th package of sanctions targeting Russian oil, the shadow fleet, banks, and additional export controls, while also designating individuals responsible for serious human rights abuses. Elsewhere, the US, UK, EU, and UN imposed sanctions on individuals linked to corruption, human rights violations, cyber threats, and armed conflicts, including actors connected to Hizballah, Nicaragua’s government, Sudan’s war, and sanctions evasion networks.

Enforcement actions were widespread across multiple jurisdictions. European authorities pursued criminal cases for breaches of Russian sanctions, including arrests for exporting dual-use goods and military-related materials to Russia or Belarus, while France and India seized sanctioned vessels linked to Russia’s shadow fleet and Iranian oil shipments. In the US, regulators issued financial penalties for sanctions and export-control violations and imposed prison sentences for individuals involved in illegal weapons and technology exports to South Sudan, Russia, and China.

Iran

• The US ramped up sanctions against the Iranian regime as pressure increased throughout the month. Designations carried out by OFAC and the Department of State targeted seven officials including Interior Minister Eskander Momeni who oversees Iran’s Law Enforcement Forces (“LEF”), as well as over 45 entities, individuals, and vessels connected to the illicit trade in Iranian petroleum products and Iran’s weapons production.  The US also imposed visa restrictions on Iranian regime officials and telecommunications industry leaders, and sanctioned two UK-registered digital asset exchanges for operating in the Iranian financial sector.

• The EU proscribed the IRGC to its terrorism list on 19th February, joining the US, Canada, and other countries that have already proscribed the group. The UK announced plans to introduce new legislation to add the IRGC to its list of terrorist entities.  Meanwhile, the UK listed Momeni, the LEF, and nine individuals under its Iranian sanctions regime.

• Also during the month, the US issued an Executive Order authorising the Government to impose tariffs on products imported from foreign countries that directly or indirectly purchase goods or services from Iran. The US Financial Crimes Enforcement Network (“FinCEN”) also reportedly proposed a rule to cut a Swiss bank’s access to the US financial system due to alleged financial support for actors connected to Iran and Russia.

Russia

• The UK announced its largest sanctions package against Russia to mark the fourth anniversary of Russia’s full-scale invasion of Ukraine, designating 240 entities, seven individuals, and 50 vessels. Measures targeted multiple sectors of Russia’s economy, most notably energy with the listing of Transneft, responsible for 80% of Russia’s oil networks, and Russian nuclear energy company Rosatom.

• The EU Commission announced the first details of its proposed 20th sanctions package against Russia, which will include further prohibitions on Russian crude oil, Russia’s shadow fleet, its banking sector, and other export restrictions. The EU’s stepwise ban on Russian gas imports also entered into force, prohibiting imports of pipeline gas and LNG directly or indirectly exported from Russia into the EU.  Separately, the EU added eight individuals to its Russian sanctions lists for serious human rights violations.

• The European Commission is reportedly considering anti‑circumvention measures against Kyrgyzstan under its Russian regime to restrict the exports of sanctioned goods and technology to third countries at high risk of sanctions circumvention, including certain machine tools and radio‑electronic equipment that are being diverted from Kyrgyzstan to Russia. The EU has also added Russia to its list of high-risk third countries with anti-money laundering and countering the financing of terrorism deficiencies that pose threats to the EU’s financial system.

Enforcement

• In the EU, enforcement focused on breaches of Russian sanctions. In Germany, prosecutors arrested five people for exporting goods to at least 24 listed arms manufacturers in Russia.  German police also arrested Jörg Dornau, an AfD representative in the Saxony State Parliament, for allegedly declaring Kazakhstan as the destination for a telescopic loader intended for Belarus in August 2022.  In Latvia, an Estonian-Russian dual-national was sentenced to three years in jail for attempting to ship ammunition to Russia, whilst the Latvian State Security Service asked the Prosecution Office to initiate criminal prosecution against a Latvian resident for illegally providing programming services to a company in Russia.  Polish authorities arrested four Belarusian citizens and two Polish citizens for attempting to transport EU-sanctioned dual-use goods to Russia.

• The French Ministry of Justice fined the owners of ‘The Grinch,’ a US and EU-sanctioned vessel identified as being part of Russia’s shadow fleet. The vessel was seized in January 2026 by French authorities whilst travelling from Russia.  In similar news, Indian authorities seized three vessels sanctioned by the US for transporting oil for the National Iranian Oil Company and Iranian military.

• In the US, OFAC announced a $3.77 million settlement with an unnamed US citizen for 20 violations of the former Syria sanctions regime. The US Bureau of Industry and Security (“BIS”) separately reached a $1 million settlement with Teledyne DLIR LLC for 19 breaches of export regulations and a $374,000 settlement agreement with US-based IT Company Vizocom for exporting US technology to China.

• US citizen Peter Ajak was sentenced to 46 months in prison by the US District of Arizona for conspiring to illegally export weapons to South Sudan. His co-defendant Abraham Chol Keech was sentenced to 41 months in December 2025.  The US Eastern District of Virginia sentenced two individuals – Oleg Nayandin (3 years) and Vitaliy Borisenko (1 year) – for illegally exporting US technology to Russia.  Bulgarian citizen Milan Dimitrov was also sentenced in a federal court in Texas to 38 months imprisonment for a scheme to illegally export US-origin sensitive microelectronics to Russia.

• In the UK, the High Court ruled that the decision to proscribe Palestine Action as a terrorist organisation in July 2025 was unlawful because it contravened government policy and breached the fundamental rights of freedom of expression and freedom of assembly. The UK Government has since been granted permission to appeal the judgement, meaning Palestine Action will remain proscribed until the Court of Appeal has heard the government’s case.  Separately, UK citizen Steven Gates was jailed for two years for attempting to export night-vision rifle parts to Hong Kong without a licence.

Other Designations, De-Listings and Regulatory Updates

• The EU removed asset freeze restrictions and travel ban sanctions against Zimbabwe. The arms embargo on Zimbabwe remains in place and has been extended until 20th February 2027.  Separately, the EU amended its terrorism sanctions regime by expanding its listing criteria and introducing travel bans on sanctioned individuals.

• The US Department of State began designated two people, four entities and two vessels for exploiting Lebanon’s financial sector to generate revenue for Hizballah. The US also sanctioned five Nicaraguan government officials for enabling the Murillo-Ortega dictatorship to repress its people, as well as Nicaraguan prison director Roberto Clemente Guevara Gomez for human rights violations against a political prisoner.  Elsewhere, OFAC designated Sergey Zelenyuk and six associated individuals and entities for distributing cyber tools harmful to US security.

• The US issued and amended eight general licenses related to Venezuela’s oil and gas sector. The US additionally extended the rolling 30-day waiver from sanctions for the Serbian Oil Industry, a subsidiary of sanctioned Russian energy major Gazprom Neft.  Throughout the month the State Department also imposed visa restrictions on two officials from Palau and the Marshall Islands for involvement in corruption on behalf of China-based individuals, three Chilean government officials for activities that compromised critical telecommunications infrastructure, and executives and senior officials at two Uzbekistan-based visa facilitation companies that facilitated illegal immigration to the US.

• Targeting Sudan, the UK sanctioned six individuals suspected of committing human rights violations in the war, or fuelling the conflict through the supply of mercenaries and military equipment. OFAC sanctioned three commanders of Sudan’s Rapid Support Forces (“RSF”) for their role in atrocities committed during the 18-month siege and October 2025 capture of El-Fasher, North Darfu.  Later in the month the UN designated four commanders of the RSF for human rights violations.

• This month’s delistings included the removal of Brunei-registered Soltech Industry Co Ltd from the US sanctions lists, as well as the UK’s removal of the former Deputy Chairman of Sovcombank Alexey Panferov from its sanctions list. The EU General Court annulled Maya Tokareva’s September 2025 relisting on the EU Russia list.  Several delisting applications were rejected this month.  The EU rejected the applications of Russian state‑owned credit institution VEB.RF and Russian insurance company AlfaStrakhovanie.  The UK Court of Appeal meanwhile dismissed the delisting appeal of Belarusian property developer Dana Astra.

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The new year in sanctions saw international regulatory bodies focus on two key jurisdictions: Iran and Venezuela. Measures taken in each country follow key geopolitical events, respectively mass anti-government demonstrations and a US-led presidential deposition. US authorities expanded Iranian designations beyond traditional political targets to include senior security figures, IRGC commanders and an extensive shadow banking network, alongside a fresh tranche of vessels linked to Iranian petroleum and petrochemicals exports. The UK and EU have also signalled impending increased measures, with OFSI set to target Iran’s finance, energy, transport and software sectors, while the EU prioritised individuals linked to violent crackdowns on protesters.  

Meanwhile in Venezuela, vessel seizures continued to be a favoured enforcement action, seeing coordinated action from US, UK, and European authorities. The indictment of Nicolas Maduro and senior family members on narcoterrorism charges sat alongside an abrupt shift in US messaging later in the month, as officials also announced a potential pathway to sanctioned oil sales and hinted at near-term sanctions relief. 

Enforcement action remained robust across the US and Europe, with a strong focus on export controls, Russia-related sanctions, and circumvention activity. US courts handed down multiple custodial sentences linked to aerospace and firearms-related export controls breaches and DPRK revenue-generation schemes, while European authorities pursued high-profile seizures of suspected shadow fleet vessels. In the UK, regulators continued to emphasise self-disclosure as a mitigating factor, as illustrated by a reduced fine imposed on Bank of Scotland. Regulatory amendments included the EU’s adoption of new measures to phase out Russian LNG and pipeline gas imports, and an extension of its regimes against Guatemala and Hamas and the Palestinian Islamic Jihad. 

Iran and Venezuela 

• With mass protests and violent punishments in response, a global spotlight on Iran has seen international authorities impose increased measures on the country, targeting both individuals associated with crackdown on protestors and actors supporting strategic sectors. 

• The US added five Iranian government officials to its sanctions list, additionally targeting six people and 12 entities involved in the country’s shadow banking network. Notable designations include the Secretary of the Supreme Council for National Security, Ali Larikani, and four IRGC military commanders. A further nine vessels were added to OFAC’s Iran petroleum and petrochemicals sanctions lists along with the companies that own the vessels, which are registered across India, Oman, the Seychelles, Marshall Islands, UAE, and Liberia. 

• The UK and EU have also confirmed that they will increase sanctions on Iran, with the UK set to target Iran’s finance, energy, transport and software sectors and the EU citing those using violence against peaceful protesters. 

• Venezuela-related sanctions activity also remained a high priority for US authorities throughout January. At the beginning of the month, OFAC sanctioned eight companies and associated ships reported to form part of the country’s shadow fleet transporting sanctioned oil. Throughout the month, five vessels were seized, including the most recently seized vessel the Sagitta, in addition to the two vessels seized in December. The UK Government is meanwhile reported to have identified a legal basis for boarding and detaining UK-sanctioned vessels, having earlier assisted the US in seizing a US-sanctioned oil tanker, the Bella 1. 

• Shortly after, deposed President Nicolas Maduro was indicted on narcoterrorism charges alongside his wife, son, and former Interior Minister. Charges allege that Maduro acted in a way intended to financially benefit five designated foreign terrorist organisations: Fuerzas Armadas Revolucionarias de Colombia (FARC), Ejercito de Liberación Nacional (ELN), the Sinaloa Cartel, the Zetas, and Tren de Aragua (TdA). Maduro has pleaded not guilty to all four charges against him. 

• Finally, in a move perceived unsurprising by political commentators, on 7th January 2026, Trump announced via social media that the US had reached an agreement with Venezuelan interim authorities to sell sanctioned Venezuelan oil. The following week, Treasury Secretary Scott Bessent announced that sanctions against Venezuela could be lifted in as little as a week. 

Other Designations and De-Listings 

• Beyond Venezuela and Iran, January saw designations across several transnational regimes, primarily counterterrorism and counternarcotics.  The US added 7 entities and one individual, a UK national, to its counterterrorism list for their actions in support of Hamas in Gaza. A further 11 people, ten entities, and one vessel were added to the same list for their roles in a Houthi smuggling network said to have transported oil products, procured weapons and dual-use equipment, and provided financial services for the terrorist-designated organisation. Elsewhere in the Middle East, Egyptian, Jordanian, and Lebanese branches of the Muslim Brotherhood were designated foreign terrorist organisations. 

• In other narcotics designations, the US added five individuals and five entities to its transnational list, spanning various members of a trafficking network led by Luis Manuel Picado Grijalba and Jordie Kevin Picado Grijalba, Costa Rican brothers involved in transporting cocaine from Colombia. Visa restrictions were imposed on two members of Haiti’s Transitional Presidential Council for their enabling of Haitian gangs, including those designated as foreign terrorist organisations. 

Enforcement 

• Enforcement action in relation to EU sanctions spanned several European countries in January. Portuguese prosecutors began proceedings this month against Premier League football club Casa Pia and its manager Tiago Lopes. The club is alleged to have received EUR 1.5 million from Russian club FC Akhamat, whose owner was sanctioned by the EU in 2014. This move follows an announcement from FIFA that EU clubs should pay outstanding transfer fees to Russian clubs despite the risk of breaching EU and international sanctions. 

• Italian customs officials seized a vessel carrying 33,000 tonnes of iron reported to be in breach of sanctions on Russia, having turned off its automated tracking system near the Russian port of Novorossiysk. France similarly boarded and seized the Grinch tanker, believed to belong to Russia’s sanctioned shadow fleet. This seizure saw cooperation between the French and British navies. Finally, federal prosecutors in Germany arrested two individuals reported to have transported drones ad medical supplies to the Donbass region of Ukraine in aid of the pro-Russian Donetsk and Luhansk People’s Republic militias. 

• In the UK, Bank of Scotland was fined £160,000 for breaches of Russia sanctions, having been found to have made funds available to a designated person. This fine represents a 50% reduction of the original penalty due to Bank of Scotland’s voluntary self-disclosure of the matter to regulators. Also in the UK, an inquiry into alleged breaches of Sudanese sanctions through the re-exportation of UK-manufactured arms via the UAE found no evidence substantiating allegations. This follows widespread media reporting in October 2025 suggesting that British military equipment was being used by the UAE-backed Rapid Support Forces who are accused of committing a genocide in Sudan. 

• US federal authorities handed down a number of prison sentences to individuals found to have breached OFAC regulations. In Oregon, an Indian businessman was sentenced to 30 months’ imprisonment for export controls breaches, having been found to have conspired to obtain aerospace goods and technology on behalf of Russian parties. Meanwhile in Georgia, another individual was sentenced to 41 months’ imprisonment also for attempts to breach aerospace-related export controls on behalf of a Russian flight school and in New York a Kyrgyz national was sentenced to 39 months for conspiracy to export US-manufactured firearms to Russia.  

• Elsewhere in the US, a New Jersey man pleaded guilty to mail and wire fraud and conspiracy to commit money laundering as part of a scheme to generate revenue for the DPRK’s weapons of mass destruction programmes. A District Court in Columbia enforced three Russian arbitral awards originally issued in favour of TV-Novosti, a Russian state-owned media company now subject to US sanctions, after finding that the awards were validly assigned to a non-sanctioned third party before sanctions were imposed. Following a $7 million enforcement penalty applied by US authorities last month, Gracetown Property Inc has started a claim against OFAC in which the firm argues excessive measures were applied for a negligent administrative oversight, seeking to vacate the fine. 

Other Regulatory Updates  

• The EU extended its sanctions on Guatemala for another year, maintaining restrictions on the eight individuals and one entity included on the list. EU sanctions on Hamas and the Palestinian Islamic Jihad were also extended for another year.  

• Following on from a proposal approved by the Council in December, the EU adopted a regulation to phase out direct and indirect imports of LNG and pipeline gas from Russia. This regulation aims to counter the effects of Russian circumvention of oil sanctions through shadow fleets, with sanctions to date having significantly reduced imports from Russia. 

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Beyond Venezuela, December saw wide-ranging sanctions activity and enforcement. The US, UK, and EU added new listings tied to the Sudan conflict, Russian oil, cyber and information operations, Iran’s shadow fleet and Syrian regime-linked actors, while the EU rejected a series of prominent Russian and Syrian delisting applications, signalling limited scope for relief. Enforcement actions included major settlements and fines for sanctions breaches involving Iran, Russia, North Korea and export controls. Most notable among these was the settlement of a $1.5 billion investor lawsuit against Standard Chartered, linked to alleged Iranian sanctions breaches. Meanwhile, regimes targeting Mali, the Democratic Republic of Congo, and Somalia have been extended, and the scope of an arms embargo on the Central African Republic amended in light of improved security conditions.

Venezuela

• Among the most notable actions taken by the US in December was the seizure of sanctioned vessel the Skipper off the coast of Venezuela, a crude oil tanker transporting petroleum products between Venezuela and Iran. A week later, President Trump announced a blockade on all sanctioned vessels travelling to and from Venezuela

• This was followed by a wave of designations targeting members of President Nicolas Maduro’s family, including his parents, wife, daughter, and three nephews, in addition to designations for Panamanian businessman and Maduro associate Ramon Carretero Napolitano and six shipping companies reported to be transporting sanctioned oil. Members of Carretero’s family were also sanctioned. On the counterterrorism front, the US also designated seven individuals and four entities for their links to Venezuela’s Tren de Agua, including a cell leader and a partner of Tren de Agua’s leader.

• Action against Venezuela was not limited to that taken by the US, as the EU also extended its sanctions regime against Venezuela for another year, maintaining restrictions on the 69 people included on the list.

Designations and De-Listings

• Pressure on Russia continued throughout December, as OFSI sanctioned two individuals and five entities reported to be linked to Russian foreign misinformation campaigns and political interference operations, including political scientist Aleksandr Dugin and blogger Mikhail Zvinchuk. Three entities founded or directed by Zvinchuk were also sanctioned. In addition, the UK designated two entities under its cyber sanctions regime, namely Integrity Technology Group, a covert network of over 260,000 devices that has targeted UK public sector IT systems, and Sichuan Anxun Information Technology Co, which has enabled Chinese access to and interference with UK public and private sector IT systems. Finally, five people and 19 entities linked to Russia’s oil sector were sanctioned, including four major oil companies: PJSC Taftneft, PJSC Russneft, LLC NNK-Oil and LLC Rusneftegaz.

• The EU also targeted 12 people and two entities under its hybrid threats regime, comprising foreign policy analysts, media figures and members of the Russian military intelligence unit all involved in manipulating information entering the EU and/or conducting cyber-attacks against EU infrastructure. A further five people and four entities involved in oil trading activities reported to be circumventing sanctions against Russia were designated along with 41 vessels.

• In Iran, the US designated 3 people, 17 entities and 29 vessels for their Iranian shadow fleet involvement. Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr was also designated for owning and operating many of the management companies for the vessels. While the UK removed the IRGC and two connected individuals from its Syrian sanctions list, these remain designated through sanctions on Iran. Separately, 9 Assad-linked individuals and militias were added to OFSI’s Syrian sanctions list.

• Elsewhere, the US sanctioned two ICC judges from Georgia and Mongolia respectively for their efforts to investigate, arrest, and prosecute Israeli nationals and designated Colombia’s Clan de Golfo as a Foreign Terrorist Organisation. The EU designated former Haitian President Michel Martelly, his former political advisor, and a former senator for their involvement in human rights abuses in the country. In Sudan, the US sanctioned four people and four entities found to be part of a transnational network recruiting Colombian nationals to fight in Sudan’s civil war on behalf of the RSF. The UK similarly sanctioned four RSF commanders, two of whom are also sanctioned by the US and EU respectively.

• December saw a string of unsuccessful de-listing applications in relation to EU sanctions on Russia, including those submitted on behalf of leading Russian business figure Gennady Timchenko and his wife Elena; mining magnate Musa Bazhaev; Sberbank subsidiary SBK Art; Eurochem owner Andrey Melnichenko and his wife Aleksandra; and businessman Igor Rotenberg.  Outside of Russia, the EU rejected Amer Foz’s Syrian delisting application on the grounds that Foz’s links to ISIL trade remain relevant and that his links to a cousin of Bashar Al Assad justify his associations with the Syrian regime.

• OFAC delistings were equally notable; Brazilian Supreme Court judge Alexandre de Moraes, previously judged to have undermined freedom of expression in Brazil, was removed from the Global Magnitsky sanctions list along with his wife and business interests.

Enforcement

• December saw several significant updates in the sanctions enforcement space. Standard Chartered Plc agreed to a settlement of a £1.5 billion lawsuit over allegations of breaches of Iranian sanctions. A group of 216 investors claimed that Standard Chartered had published untrue or misleading statements related to its sanctions compliance. The settlement follows a judgement handed down by the Court of Appeal ruling that Standard Chartered was obliged to disclose certain regulatory documents that the bank argued would leave it liable to regulatory sanctions or criminal proceedings overseas over its duty of confidentiality.

• OFAC published details of an $11.4 million settlement with Chicago private equity firm IPI Partners in light of the firm’s violation of Russian sanctions. These violations included wire transfers with an entity owned by sanctioned businessman and former Russian senator Suleiman Kerimov. A settlement of $3 million was also reached with Exodus Movement for their alleged violation of Iranian sanctions through the provision of digital wallet services to users in the country.

• Keeping with the US, virtual asset trading platform Paxful admitted to processing transactions involving sanctions evasion and agreed to pay a $4 million criminal penalty. The transactions were associated with North Korean cyber-criminal group Lazarus, which has been sanctioned by the US since 2019.

• A $7 million fine was handed down to a New York-based property management firm, Gracetown Inc, for its activities managing properties belonging to Oleg Deripaska, who was sanctioned in 2018. A US-based company also pleaded guilty to AI-related export control breaches, having attempted to export $160 million worth of Nvidia graphic processing units to China and Hong Kong. The company will be issued with a financial penalty while its owner faces ten years’ imprisonment.

• In the UK, HMRC concluded a £620,000 settlement with a UK business found to have exported military goods without a license.

Other Regulatory Updates

• The US granted Hungary an exemption from sanctions on Russian oil and gas following White House negotiations this month. This exemption enables Hungary to import oil and gas via the Druzhba and TurkStream pipelines, which both run through Hungary.  The US also issued a general licence authorising transactions involving three Belarus potash companies after over 100 prisoners were released by President Alexander Lukashenko, including key opposition figures and a Nobel peace prize winner.

• The EU renewed its sanctions regimes targeting Mali, first established in 2017 in line with now-inactive UN sanctions; its global human rights regime, now extended until December 2026; the Democratic Republic of Congo, by which 31 individuals and two entities are currently sanctioned; and sectoral sanctions against Russia for a further six months. The UN has meanwhile extended its Al Shabaab sanctions regime in Somalia for another year.

• In addition, the EU has broadened its Belarus sanctions criteria to include those who engage in foreign information manipulation, target the functioning of democratic institutions, enter an EU member state without authorisation, and interfere with critical infrastructure. These amendments are said to be linked to recent meteorological balloon incursions into Lithuania’s airspace.

• In the UK, sanctions against the Central African Republic were amended to lift the arms embargo in recognition of the country’s progress towards stability in disarming two major armed groups. This applies to the CAR government and not to other armed groups in the Central African Republic, who remain prohibited from accessing weapons and ammunition.

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International authorities coordinated on several notable listings and delistings. The UN, UK, and US jointly removed Syrian President Ahmed Al Sharaa and Interior Minister Anas Hasan Khattab from terrorism sanctions lists, while the EU rejected a delisting request from Samer Al Assad. Meanwhile, the EU sanctioned Rapid Support Force commander Abdelrahim Hamdan Dagalo for violence in Sudan and imposed further penalties on Russian officials linked to human-rights abuses, including the death of Alexei Navalny. Cyber-related actions also expanded, with the US sanctioning North Korea-linked financial and technology entities and, alongside the UK, targeting Russian hosting providers Media Land and Azea Group for supporting cybercrime and threatening Ukrainian security. Additional measures hit Iranian aviation and global oil-shipping networks.

Sanctions enforcement intensified across multiple jurisdictions. OFAC levied a maximum $4.6 million penalty on an individual involved in the sale of a sanctioned Russian national’s property, while UK authorities charged two art-sector firms for breaching Russian sanctions. France extradited a Belarusian national to the US over aircraft-equipment export-control violations, and the US secured a settlement with Eleview International for illicit shipments to Russia. Regulatory updates included the US lifting its arms embargo on Cambodia, the EU expanding dual-use export controls to cover quantum and semiconductor technologies, and both the UK and US issuing general licences related to Lukoil, Rosneft, and Hungary’s Paks II nuclear project.

Counter Terrorism and Organised Crime

• In counter terrorism, November saw continued efforts from the US to target terrorist organisations across the Middle East. OFAC sanctioned three people said to have facilitated financial transfers from Iran to Hezbollah valued in the tens of millions over the course of 2025. Trump additionally issued an Executive Order calling for the Treasury and State Departments to report and designate chapters of the Muslim Brotherhood as foreign terrorist organisations where they are found to support violence and harm US citizens. The US also added 11 individuals and 21 entities to its counterterrorism and non-proliferation sanctions lists due to links to Iran’s ballistic missile and UAV procurement networks, said to be centred around a three-person venture named MVM Partnership, comprising Marco Klinge, Vahid Qayumi, and Majid Dolatkah.

• Outside of the Middle East, the US designated four organisations said to belong to the Antifa movement, including groups based in Germany, Greece, and Italy, the latter being the Informal Anarchist Federation/International Revolutionary Front. These groups have conducted attacks domestically and internationally, as well as threatening violence, bombs, and letter bombs against political and economic institutions. The UK designated Kieran Gallagher and the New Irish Republican Army for counterterrorism sanctions violations. Gallagher is also subject to director disqualification measures.

• The US continues to make organised crime a key focus of its sanctions designations, this month adding seven people and 20 entities to its transnational criminal organisations sanctions list for their reported links to the Hysa Organised Crime Group. The group is reported to operate with the consent of the Sinaloa Cartel and is involved in laundering money through gambling establishments and restaurants. Another high-profile subject of US sanctions this month was Ryan Wedding, a former Canadian Olympic snowboarder turned drug kingpin involved in importing cocaine to the US and Canada and laundering the proceeds via cryptocurrencies. A wife, girlfriend, associate, and lawyer of Wedding were all sanctioned for their involvement in the trafficking network. In Venezuela, the US designated Cartel de los Soles as a Foreign Terrorist Organisation, citing its links to President Nicolas Maduro and two FTO-designated cartels, Tren de Aragua and the Sinaloa Cartel.

Designations and De-Listings

• Taking joint action, the UN, UK, and US notably delisted Syrian President Ahmed Al Sharaa and Interior Minister Anas Hasan Khattab from their respective ISIL and Al Qaida sanctions lists, both of whom had previously been designated in 2013 for their roles in Al Qaida-affiliated Hayat Tahrir Al Shams. The UK additionally delisted Hayat Tahrir Al Shams. Meanwhile, a delisting application by Samer Al Assad was rejected by the EU, failing to argue that membership of the Assad family is a broad and discriminatory criterion.

• The EU sanctioned Abdelrahim Hamdan Dagalo, a commander in Sudan’s Rapid Support Force, in light of his role in sustained violence in El Fasher, Sudan where the RSF is responsible for ethically motivated killings and violations of international human rights. A further ten individuals were sanctioned for violating human rights sanctions in Russia, including prison officials, members of the Russian judiciary, and those associated with the death of Alexei Navalny.

• In the cyber space, the US added two entities and eight individuals to its cyber and North Korea sanctions lists, including Ryujong Credit Bank, Korea Mangyongdae Computer Technology Company, and related banking professionals. The UK and US also took coordinated action in sanctioning Media Land LLC, a Russian hosting web service provider allegedly linked to cybercrime and ransomware operations and Azea Group LLC, a similar provider whose actions threaten Ukrainian national security. A sister company of Media Land and four employees were also sanctioned by the UK while four companies affiliated with Azea Group were sanctioned by the US.

• There were also several notable actions taken against and in favour of airlines this month.  Belarus’ Belavia was delisted by OFAC while several entities and individuals linked to Iran’s Mahan Air were added to US sanctions lists. In shipping, two people, eight entities, and four vessels were sanctioned by the US for their roles in transporting and selling Iranian oil, including companies based in Singapore, the Marshall Islands, the Seychelles, the UAE, and Vietnam.
• The US designated 8 people and 11 entities linked to the Los Chapitos faction of the Sinaloa Cartel under its counter-narcotics programme. In late October the US continued its counter-narcotics sanctions with the designations of Colombian President Gustavo Petro, his family, and the Colombian Interior Minister Armando Benedetti.  The US additionally designated two Haitian individuals under its counter-terrorism sanctions, both of whom were later also designated by the UN.

Enforcement

• OFAC issued a $4.6 million fine in November to an unnamed individual involved in the sale of a property in Atlanta, Georgia belonging to a sanctioned Russian person. Details published by OFAC stated the violations of Russian Harmful Foreign Activities Sanctions to be egregious, and due to the lack of voluntary self-disclosure, the maximum penalty was issued.

• The US Bureau of Industry and Security also released details this month of a settlement with Eleview International, a Virginia-based freight forwarding company that shipped goods subject to export controls to Russia between February 2022 and June 2023. The settlement saw Eleview pay a fine of $125,000 as well as agreeing to export compliance training and a three-year suspension of its ability to apply for export licenses.  Separately, Belarussian national Yana Leonova was extradited from France to the US to face charges for conspiring to violate export controls by procuring avionics and aircraft equipment to be exported to Russia. The case is being investigated by the FBI in Kansas City, Atlanta, and New York.

• In the UK, the London branch of Swiss art gallery Hauser & Wirth and arts logistics company Artay Rauchwerger Solomons were charged with breaching Russian sanctions by enabling the purchase of a work of art by an individual connected to Russia.  While the individual was not himself sanctioned, the sale violated export controls on luxury goods.

Other Regulatory Updates

• The US lifted its arms embargo on Cambodia, first imposed in 2021 due to violations of human rights and Chinese involvement in the country’s military. This lifting comes amidst renewed engagement between Cambodia and the US regarding defence, although defence-related export controls remain in place and exemptions will be considered on a case-by-case basis.

• Amendments to the EU’s dual-use regulation came into force in November, adding new items subject to export controls to include quantum technology, semiconductor manufacturing and testing equipment, advanced computing integrated circuits and electronic circuits, coatings for high temperature applications, and peptide synthesisers. The EU also extended its sanctions regime against Turkey related to unauthorised drilling activity in Cypriot-claimed waters for another year and UN sanctions against Yemen will similarly remain in force until November 2026.

• OFSI issued a general licence, active until February 2026, authorising transactions with two Bulgarian subsidiaries of Lukoil, which was sanctioned in October 2025. Later in the month, this was extended to a further two subsidiaries in Bulgaria. The US issued similar Lukoil and Rosneft-related exemptions. Other US General Licenses issued this month include authorisations for transactions related to the Paks II nuclear plant project in Hungary.

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Iran’s Foreign Ministry has claimed the UN’s snapback sanctions lack a legal basis as the UK designated 43 people and companies to reflect UN regulations.  Meanwhile, the US sanctioned 38 individuals and 73 companies throughout October for procuring arms for Iran, operating in Iran’s petrochemical sector, and supporting the Iranian Revolutionary Guard Corps (“IRGC”).

In the enforcement space, BNP Paribas was ordered to pay $20 million to three Sudanese refugees after a New York jury found it liable for enabling genocide in Sudan.  Separately a New York court allowed terrorism financing claims against the bank brought by 288 victims of terrorist attacks committed in Israel and Iraq between 2006 and 2018.

Russia and Iran

• Key sanctions against Russia in October came in the form of the US and UK’s joint action, designating Lukoil and Rosneft, Russia’s two largest oil producers. This action was part of a wider swathe of sanctions, with the US also designating 34 subsidiaries of the oil majors.  The UK additionally sanctioned five people and 35 companies, also listing 51 Russian vessels as prohibited from accessing UK ports.  Although the US began the month issuing a license postponing sanctions on the Russian-owned Serbian oil refinery operator Serbian Oil Industry (“NIS”), the waiver expired on 9^th October, and US sanctions on NIS entered into force.

• The EU adopted its 19^th Russia sanctions package, which targets Russia’s banking and energy sectors, including a ban on Russian LNG imports and sanctions on Russia’s shadow fleet, as well as sanctions on crypto networks and banks said to be circumventing EU sanctions. The package also included designations related to the forced deportation of Ukrainian children, producers of military and dual-use goods, and the implementation of service authorisations on all work with the Russian government.

• In line with UN snapback sanctions on Iran, the UK updated designated 23 people and 20 entities, and updated its regulations to reflect UN control lists. Designations included Iranian nuclear scientists, senior members of the IRGC, and the Atomic Energy Organisation of Iran.  On 18^th October the Iranian Ministry of Foreign Affairs published a statement claiming that the snapback sanctions lacked legal basis, stating Iran should be removed from the UN’s sanctions lists as a non-nuclear-weapon state.  The UK later sanctioned one Iranian national for allegedly providing economic resources to the IRGC.

• Meanwhile, the US designated 22 entities and 22 people said to be involved in procuring weaponry for the Iranian Ministry of Defence and military, as well as 10 individuals, 49 companies, and 32 ships for operating in Iran’s petrochemical sector, and two companies and six people for supporting the IRGC and two Iran-aligned militia groups in Iraq.

Designations and De-Listings

• The US designated 8 people and 11 entities linked to the Los Chapitos faction of the Sinaloa Cartel under its counter-narcotics programme. In late October the US continued its counter-narcotics sanctions with the designations of Colombian President Gustavo Petro, his family, and the Colombian Interior Minister Armando Benedetti.  The US additionally designated two Haitian individuals under its counter-terrorism sanctions, both of whom were later also designated by the UN.

• In another joint action, the Prince Group, a network that operates illegal scam centres in Southeast Asia, was targeted by the UK and US. The US sanctioned 146 individuals and entities for ties to the Prince Group, whilst the UK sanctioned 12 associated companies and people.  The UK additionally designated 12 people and 1 entity with alleged ties to a Western Balkans people smuggling route and the Kosovo-based organised crime group the Krasniqi network.  Elsewhere, the EU announced its intention to add the DRC-based militant group the Allied Democratic Forces to its ISIL and Al Qaida sanctions on top of its existing listing under DRC sanctions.

• OFAC removed 52 individuals and entities from its Balkans sanctions regime. OFAC also delisted Turkish company Kuzey Star Shipyard, which had been sanctioned in January 2025 for its connection to Russian maritime company Atomflot, as well as the former Paraguayan President Horacio Manuel Cartes Jara, and his five companies, having been designated in February 2023.

• The EU General Court annulled the listings of Russian national Galina Pumpyanskaya, and Belarusian businessman Mikhail Gutseriev. The EU General Court, however, rejected the appeals of Russian nationals Gennady and Elena Timchenko and Moldovan national Maria Albot regarding their designations.  In the case of the Timchenkos, their appeal challenged the legality of sanctions reporting obligations. The same claim has previously been rejected on three occasions when brought by sanctioned businessmen and politicians Mikhail Fridman, Petr Aven and German Khan.

Enforcement

• French bank BNP Paribas has faced significant enforcement action in October 2025. The month began with the US District Court for the Southern District of New York allowing terrorism financing claims based on sanctions breaches against the bank to proceed to trial.  The claim was brought by 288 victims of terrorist attacks committed in Israel and Iraq between 2006 and 2018, who alleged that BNP Paribas provided services to US-sanctioned Iranian oil companies used as fronts for the IRGC.  On 17^th October a New York federal jury found BNP Paribas liable for its role in enabling the genocide committed by former dictator Omar Al Bashir against Black African civilians in Sudan.  The bank has been ordered to pay $20 million to three Sudanese refugees as a result of the decision.

• The US Bureau of Industry and Security (“BIS”) published details of two settlements related to breaches of the Export Administration Regulations in October 2025. Biotechnology company Luminultra Technologies Inc received a civil penalty of $685,000 for exporting controlled items to Iran, and BVI entity Hallewell Ventures Ltd was handed a civil penalty of $374,000 for exporting an aircraft to Russia without a license.

• In the EU, Latvian authorities have charged two people with breaching EU sanctions against Russia for renting out the premises of Moscow House in Riga, which was owned by the Moscow City Property Department. Another Latvian national also pleaded guilty to conspiring to sell aircraft technology to Russia in breach of US export controls, whilst a Spanish national was sentenced to 31 months in prison for conspiring to export US radio technology to Russia via Latvia without a license.  In Finland, the Helsinki District Court dismissed charges against three crew members of a ship said to be part of Russia’s shadow fleet, whilst a student with Russian citizenship received a 14-month suspended sentence after pleading guilty to delivering dual-use items to Russia in breach of EU export control laws.

• The UK Court of Appeal rejected an appeal against the High Court’s decision, which granted Palestine Action permission to challenge its proscription under the Terrorism Act 2000 in July 2025. Later in the month the UK removed the terrorism proscription of Syrian group Hay’at Tahrir al-Sham.

Other Regulatory Updates

• The EU extended several sanctions programmes until October 2026, including sanctions against Russian hybrid threats, chemical weapons, Niger, ISIL/Al Qaida, and Moldova. The UN additionally renewed its Haiti sanctions for another 13 months.

• The UK lifted the arms embargo on Armenia and Azerbaijan that had been in place since 1992. The UK government also announced it will move to a single consolidated list for designations by the treasury and the foreign office. This is set to come into force by the end of January 2026.

• OFAC granted a sanctions licence to the government of Trinidad and Tobago and the National Gas Company of Trinidad and Tobago to enter transactions necessary to negotiations with the Venezuelan Government related to an offshore gas field development project in Venezuela. The BIS renewed its temporary denial of export privileges against Ural Airlines JSC.  The BIS later added 26 companies (16 Chinese, nine Turkish and one Emirati) to the US Entity List, meaning exports are subject to additional licensing requirements.

The post Sanctions Guide – October 2025 appeared first on Alaco.

Designation activity globally remained robust. The UK sanctioned dozens of Russian-linked vessels, entities, and individuals involved in military support and propaganda in occupied Ukraine, while the EU extended Russia-related sanctions through March 2026 and imposed new human rights sanctions on Russian prison officials in Crimea. The US maintained its focus on counter-narcotics and counter-terrorism, sanctioning individuals and entities involved in fentanyl and synthetic opioid trafficking, as well as designating Antifa a terrorist group. Sanctions were also issued against cyber-enabled scam networks in Southeast Asia, including actors tied to the Karen National Army.

In terms of regulatory and enforcement developments, the EU proposed its 19th sanctions package, which included a ban on Russian LNG, and financial restrictions on Russian banks and crypto networks. Separately, the EU and UK approved the imposition of a lowered oil price cap to $47.60, which was also adopted by Australia and Japan, but not the US. Sanctions on Sudan were extended by both the UN and EU, while delistings occurred in Guinea-Bissau and Burundi. Enforcement actions included US fines against Fracht FWO Inc and crypto firm ShapeShift AG for violations of Iran, Syria, and Venezuela sanctions. Several high-profile EU de-listing applications—including those by Alisher Usmanov and Roman Abramovich—were rejected, though the court annulled the listing of a former Ukrainian MP due to outdated evidence.

Middle East

• Sanctions news this month was dominated by the reimposition of UN sanctions on Iran following the conclusion of the snapback mechanism, which had seen sanctions suspended upon the adoption of the JCPOA. This has resulted in the reinstatement of asset freezes on individuals and entities involved in Iran’s nuclear and ballistic missile programmes as well as on banks linked to the IRGC, and bans on Iranian arms exports and the sale of heavy conventional weapons.

• On 2nd September OFAC sanctioned Iraqi-Kittitian businessman Waleed al-Samarra’I and his network of seven shipping companies and nine vessels for smuggling Iranian oil disguised as Iraqi oil. Later in the month, OFAC also designated a further four individuals based in the UAE and 12 entities belonging to Iran’s shadow banking network and proscribed four Iran-backed militias as foreign terrorist organisations.

• Ahead of the UN General Assembly, Senator Ted Cruz introduced a bill to ban sanctioned Iranian officials from entering the US, which would usually be allowed under the US-UN Headquarters Agreement.

• Elsewhere in the Middle East, the US State Department designated three NGOs – Al Haq, Al Mezan Center for Human Rights, and the Palestinian Centre for Human Rights – under its ICC sanctions regime for engaging in ICC’s efforts to detain and prosecute Israeli nationals without Israel’s consent. OFAC also sanctioned 11 people, 21 entities, and 4 ships involved in illicit fundraising, smuggling, and weapons procurement for Yemen’s Houthis. These actions constitute the US’s largest Houthi-related sanctions package to date.

• Finally, in late September, OFAC published a final rule implementing changes to its Syria sanctions regimes. Under this rule, the title of the sanctions was changed to ‘Promoting Accountability for Assad and Regional Stabilisation Sanctions’ (PAARSS).

Designations

• The UK continued to take action against Russia this month, sanctioning 70 vessels, 27 entities, and 3 individuals for their support of the Russian military and involvement in Russia’s oil industry. OFSI also designated eight people and three entities involved in implementing russification policies in occupied territories of Ukraine, including the deportation and indoctrination of Ukrainian children. Further action was taken against six Georgian nationals, entities, and vessels for their links to Russia and involvement in disinformation campaigns.

• The EU meanwhile extended sanctions against Russia until March 2026, maintaining pressure on over 2,500 individuals and entities sanctioned via its regimes. The EU further designated two individuals under its global human rights sanctions regime – the head and deputy-head of the Directorate of the Russian Federal Penal Enforcement Service for Sevastopol & Crimea – for human rights abuses in Crimea.

• Counter-narcotics and counter-terrorism sanctions remain a high priority in the US. OFAC imposed entry bans on two Montenegrin officials said to be involved in corruption that enabled drug trafficking; bans were also imposed on members of their immediate family. Sanctions were also applied on two Indian nationals for fentanyl trafficking, as well as Chinese chemical company Guangzhou Tengyue Chemical Co Ltd and its two representatives, found to be manufacturing and selling synthetic opioids. Other counter-narcotics and counter-terrorism designations made by OFAC included the Los Mayos faction of the Sinaloa Cartel and the leader of Los Rugrats gang in Mexico, and Barrio 18, a gang operating across El Salvador, Guatemala, and Honduras. In notable domestic news, Trump signed an executive order designating Antifa a terrorist organisation for its actions to overthrow the US government.

• The US also took action against scam centres across Southeast Asia this month, sanctioning seven people and 12 entities involved in malicious cyber-enabled activities. These designations included individuals and entities with ties to the sanctioned Karen National Army.

Regulatory Updates

• September saw the arrival of the EU’s proposed 19^th sanctions package, spanning a ban on Russian LNG imports until January 2027, bans on transactions involving Rosneft and Gazpromneft, and sanctions on cryptocurrency networks and Russian banks using alternative payment systems, among other restrictions. The EU also lowered the price cap on Russian crude oil from $60 per barrel to $47.60 in alignment with the UK.  The regulation is due to be reviewed in April 2026. This move was subsequently adopted by other countries including Australia and Japan, although notably not the US.

• The UN renewed its sanctions regime against Sudan for another year, extending targeted measures against individuals and entities undermining peace in Darfur and an arms embargo on non-governmental entities and individuals in Darfur. The EU similarly agreed to extend its Sudan sanctions list until October 2026. Elsewhere in Africa, the EU removed all entries from its Guinea-Bissau and Burundi sanctions lists, although the regimes remain active.

Enforcement

• On 3rd September OFAC announced that Texan freight forwarding company Fracht FWO Inc agreed to pay $1.6 million to settle its liability for violations of sanctions against Venezuela and Iran. The company had contracted an aircraft charter to ship vehicle components between Mexico and Argentina; the chartered aircraft was wholly owned by a designated Venezuelan state-owned airline and previously owned by Mahan Air, an airline also designated for supporting Iran’s Revolutionary Guard Corps, for which the aircraft remained sanctioned.

• OFAC additionally announced a settlement this month with ShapeShift AG, a digital asset exchange that was found to have violated sanctions on Cuba, Iran, Sudan, and Syria. The company was fined $750,000 for not screening sanctioned users or maintaining a sanctions compliance programme, resulting in tens of thousands of violations of sanctions regimes between 2016 and 2018.

• The UK issued a disclosure notice against Vanquis Bank, which was found to have allowed a sanctioned individual access to their bank account for eight days after their designation. OFSI ruled that while a monetary penalty was not necessary, a warning letter would be too lenient.

• In Europe, Luxembourg’s financial services regulator issued a EUR 214,000 fine to digital payment platform Alipay (Europe) SA after an inspection revealed breaches of anti-money laundering and counter-terrorist financing laws. Estonian authorities meanwhile extradited Andrey Shevlyakov to the US to face charges of exporting US-made electronics and technology for the Russian government.

• September saw several notable delisting applications. The EU’s General Court dismissed Alisher Usmanov’s de-listing application, finding him to meet the definition of a leading businessperson operating in Russia through his 49% stake in USM Holding, a major mining and telecoms operator. The EU also rejected delisting applications for former Ukrainian president Viktor Yanukovych and his son Oleksandr for their support of Russian politicians in Crimea and business activities in the Donbas region; Roman Abramovich’s de-listing application was also rejected on the grounds of his continued influence in Russian politics, ties to Putin, and involvement in income generating activities for the Russian government. It also ruled inadmissible an application to annul to the EU’s decision to prohibit Russian-flagged historical vessels from accessing EU ports and locks. The EU General Court nevertheless annulled the September 2024 listing of former pro-Russian Ukrainian MP Vyacheslav Boguslayev for outdated evidence.  Similarly the US removed Iryna Litviniuk from its Global Magnitsky sanctions list and Mosbah Mohamed Wadi from its Libyan sanctions regime.

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UK and US sanctions regimes continued to target Iran and industries of strategic importance to the regime, including technology procurement and oil transportation, with dozens of new designations this month spanning individual actors, entities, and vessels. Notably, registrations for Panamanian vessels sanctioned by OFAC were cancelled by Panama’s Maritime Authority.

On the enforcement and regulatory front, OFAC issued general licenses around this month’s summit in Alaska between Trump and Putin, as well as extending allowances for certain diamond imports from Russia. Also in the US, August saw a series of arrests and convictions related to violations of export controls and sanctions, including weapons exports to North Korea and Russia, technology transfers to China, and narcotics trafficking. The UK issued its first suspended sentence related to counter terrorism sanctions violations.

Counter Narcotics

• The US has continued to take action against narcotics trafficking, implementing President Trump’s directive to completely eliminate cartels and transnational criminal organisations that threaten US nationals. Two Mexican cartels, Carteles Unidos and Los Viagras, and seven affiliated people linked to terrorism, drug trafficking, and extortion in Mexico’s agricultural sector were sanctioned by OFAC. Related to the designations, the US Department of Justice announced the charging of Farias Alvarez, Barragan Chavez, Fernandez Magallon, Orozco Cabadas and Sierra Santana. The charges relate to allegedly decades-long conspiracies to manufacture and distribute controlled substances, including methamphetamine, cocaine, and fentanyl, to be unlawfully imported into the US. In addition, Farias Alvarez, Fernandez Magallon and Barragan Chavez have been charged with firearms charges.

• Separately, four Costa Rican-based nationals and two Costa Rican-based entities were added to the SDN list for their activities in narcotics trafficking, two of whom were arrested in Costa Rica in June and are awaiting extradition to the US.

• OFAC further sanctioned one Mexican individual and 13 Mexican companies linked to timeshare fraud led by Cartel de Jalisco Nueva Generacion, which has been a designated a Foreign Terrorist Organisation since February 2025. Those targeted include Michael Ibarra Diaz Jr, who is alleged to play a role in managing fraudulent timeshares for the CJNG in Puerto Vallarta. This is in addition to designations targeting four high-ranking members of Mexico’s Cartel del Noreste, including its second-in-command Abdon Federico Rodriguez Garcia and rapper Ricardo Hernandez Medrano whose concerts and events are reported to be used to launder money on the cartel’s behalf.

Other Designations

• Iran continues to be targeted by US and UK sanctions. At the beginning of the month, OFAC sanctioned five entities and one individual for their procurement of technology in support of the designated Iran Aircraft Manufacturing Industrial Company. OFAC additionally sanctioned seven Iranian nationals and 11 Iranian entities reported to have facilitated sanctions evasion and political oppression. In the UK, meanwhile, one person and four entities were designated for their involvement in hostile activity by the Iranian government. The Panamanian Maritime Authority cancelled the registrations of 17 vessels sanctioned by the US in July in light of allegations of transporting Iranian oil. At the end of the month, OFAC sanctioned a further eight crude oil tankers, one individual, and 13 entities also involved in the transportation of Iranian oil and petroleum products.

• OFAC, the US Department of State, and the US Department of Justice took coordinated action to sanction and seize the assets of entities and individuals affiliated with cryptocurrency network Garantex and its Kyrgyzstan-based successor Grinex. Registered in Russia and Estonia, Garantex is alleged to have facilitated ransomware actors and cybercriminals by processing over $100 million in transactions linked to illicit activities since 2019. Separately, the US Department of State also revoked visas and imposed visa restrictions on multiple Brazilian government officials and former Pan American Health Organisation officials who are alleged to maintain ties to a Cuban medical worker programme that is reportedly being exploited by the Cuban government. These include officials across Africa, Cuba, and Grenada, many of whom have not been named.

• OFAC additionally sanctioned four ICC judges and prosecutors including former US sanctions ombudsperson Kimberley Prost, who was designated for ruling to authorise the ICC’s investigation into US personnel in Afghanistan. A second ICC judge, Nicolas Yann Guillou, was designated for ruling to authorise the ICC’s issuance of arrest warrants for Israeli Prime Minister Benjamin Netanyahu and former Minister of Defence Yoav Gallant.  Two deputy prosecutors, Nazhat Shameem Khan and Mame Mandiaye Niang, were designated for continuing to support illegitimate ICC actions against Israel.

• With regards to delisting applications, the EU notably rejected the applications of Russian billionaire Gennady Timchenko and his wife Elena. Gennady failed to convince the EU’s General Court that he has distanced himself from Bank Rossiya, while Elena unsuccessfully challenged her association with her husband. The EU also rejected delisting applications for two Tunisian nationals, respectively the brother and daughter of Tunisia’s First Lady, who are alleged to have been involved in or associated with the misappropriation of public funds. Alexander Pumpyansky, whose father is an influential businessman operating in Russia, was also denied interim relief from EU sanctions; his delisting application will nonetheless continue.

• The UK followed in the footsteps of the EU in annulling the listing of DRC official Alex Kande Mupompa, who was first designated in 2020 for alleged violations of human rights. Mupompa was delisted by the EU in July in light of a change in regime in the DRC, Mupompa’s lack of executive power in government, and his distancing from the former president.

Regulatory Updates

• Prior to the August 15^th meeting between Putin and Trump in Alaska, OFAC issued a general licence authorising transactions necessary for the summit that would otherwise have been prohibited, active between 13^th and 20^th Another Russia-related general licence was implemented to authorise transactions related to imports of certain diamonds and a licence authorising imports of certain non-industrial diamonds to the US from Russia was extended.

• The US further enacted new Export Control legislation requiring the US Bureau of Industry and Security to report to Congress annually on licensing, to include details such as the name of the entity submitting the application, where the item is being exported, the decision with respect to the license application or authorization, and information on related enforcement activities to ensure compliance with US export controls.

• Finally, continuing its commitment to winding down Syrian sanctions, OFAC published a final rule revoking Syrian sanctions, although sanctions on members of the former Assad regime remain in force.

Enforcement

• In Florida, arms dealer Maxim Larin was arrested for allegedly exporting weapons parts and accessories to Kazakhstan in breach of export controls. In Texas, an active-duty soldier was arrested on charges of attempted transmission of national defence information and attempted export of controlled technical data, in exchange for which the officer attempted to obtain Russian citizenship.  Two Chinese nationals were also arrested in Los Angeles due to allegations they knowingly exported microchips to China to be used in AI applications in breach of export controls.

• In California, a District Court sentenced Chinese national Wen Sheunghua to eight years’ imprisonment for illegally exporting firearms, ammunition, and other military-grade items to North Korea, for which he was paid USD 2 million by the North Korean government. The same district court also sentenced music executive José Ángel Del Villar to four years’ imprisonment for conspiring to violate counter narcotics sanctions regulations; Del Villar and his company were fined USD 2 million and USD 1.8 million respectively.

• Meanwhile in New Jersey, US-Russian dual national Vadim Yermolenko was sentenced for unlawfully purchasing and exporting electronic components to Russia for the development or nuclear and military applications. The Department of Justice additionally seized USD 2.8 million in cryptocurrency, USD 700,000 in cash, and a luxury vehicle, all of which belong to Ianis Aleksandrovich Antropenko, who was charged in Texas for conspiring to commit computer fraud and money laundering.

• In relation to global human rights and anti-corruption sanctions, OFAC indicted Haitian national Jimmy Cherizier, also known as Barbecue, and US national Bazile Richardson, also known as Fred Lion and Leo Danger, with leading a conspiracy to transfer funds from the US to Cherizier to fund his gang activities in Haiti. Richardson was arrested in Texas in July 2025 while Cherizier remains a fugitive believed to be in Haiti.

• In its first sentence for counter terrorism sanctions, the UK issued a suspended sentence to UK charity director Aozma Sultana, who was convicted for breaching sanctions in June 2025 as a result of financially supporting Gaza Now, a news agency accused of promoting Hamas and the Palestinian Islamic Jihad.

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