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. 

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

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.

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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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Beyond Russia, the US again imposed extensive sanctions on Iran’s petroleum and terrorism financing networks, including entities in the UAE, Hong Kong, and Turkey. The UK designated multiple terrorist groups, including Palestine Action, and proscribed other extremist organisations.  Enforcement was a central theme internationally, with the US Justice Department pursuing multiple settlements for sanctions violations involving Cuba, Iran, and North Korea—several of which saw reduced penalties due to self-disclosure. Regulatory updates also emerged across the UK, EU, and UN, with the UK sanctioning a host of individuals pursuant to its new irregular migration regime. The EU and UN respectively extended regimes against Lebanon and the Democratic Republic of Congo.

Finally, delisting efforts made several headlines as applications by notable figures such as Eugene Shvidler failed to be overturned. One widow of Assad regime associate Mohamed Makhlouf was accepted, while another former wife of the same individual was rejected, having failed to provide sufficient evidence as to a lack of circumvention risk.

Russia

• At the beginning of the month, the EU extended its sanctions in view of the Russian Federation’s actions destabilising the situation in Ukraine until the end of January 2026. Hungary and Slovakia initially voted against the EU’s 18^th Russian sanctions package, which was passed later in the month and included measures to lower the oil price cap from $60 to $47.60 per barrel, to sanction an additional 105 vessels belonging to Russia’s shadow fleet, to ban transactions involving a further 22 Russian banks, to prohibit transactions related to Nord Stream 1 and 2, and to apply export restrictions and bans worth an estimated $2.5 billion.

• The EU further designated five Russian judges pursuant to its Russia human rights sanctions list as a result of their repression of civil society and democratic opposition in Russia, as well as being involved in the prosecution of Alexei Gorinov, who was sentenced to over 6 years in prison for disseminating ‘false information’ about the Russian armed forces. On its hybrid threats list, an additional nine individuals and six entities were sanctioned, including a pro-Russian Australian blogger implicated in spreading disinformation ahead of the 2024 US elections and directors of a Russian state-owned broadcaster of pro-Russian media in parts of Eastern Ukraine. The EU did, however, lift sanctions on three liquified natural gas tanker ships after receiving firm commitments that they would no longer transport Russian fuel, while the UK designated a further 135 ships related to Russia’s energy and oil sectors.

• In its largest compound settlement agreement related to the UK’s Russian sanctions, an unnamed business that exported goods to Russia in breach of sanctions paid over £1 million to HMRC in May 2025, as announced this month. The UK also charged British-Russian software developer Mikhail Vlasov with eight counts of violating UK sanctions by sending Bitcoin worth £4,000 to paramilitary groups in Ukraine.

• Associates of OFAC-sanctioned Russian banker Andrey Kostin meanwhile avoided trial in the US following allegations they helped the baker maintain a ski chalet in Aspen, Colorado. The individuals in question agreed to a deferred prosecution arrangement and prosecutors have suspended their investigation.

Other Designations

• The UK notably proscribed Palestine Action under the Terrorism Act 2000 this month, alongside Maniacs Murder Cult and the Russian Imperial Movement, making it a criminal offence to belong to or express support for these groups. Palestine Action applied for judicial review of the decision but was refused interim relief. The US meanwhile sanctioned the UN Palestine Special Rapporteur Francesca Albanese for directly engaging with the ICC in efforts to investigate, arrest, detain or prosecute US and Israeli nationals. Meanwhile growing pressure to apply sanctions on Israel continues to have a divided response: OFAC-sanctioned Albanese called this month for sanctions on Israel due to human rights abuses while the EU has faced accusations from human rights organisations of failing to confront Israel in an unlawful betrayal of Palestinians.

• The US designated four individuals and four entities for supporting cybercrime activity. These include Aeza Group, a bulletproof hosting services provider headquartered in Russia. The group sells digital services to facilitate ransomware attacks, personal information theft, and drug trafficking. Later in the month, an additional two entities and four individuals were designated, including a DPRK-based hacker who facilitated a scheme by which DPRK IT workers accessed US employment with fake identification. A Russian national who facilitated revenue generating activities for the DPRK by hiring North Korean IT workers was also sanctioned.

• With regards to Iran, the US continued to target Iran’s shadow fleet and terrorism financing network, sanctioning eight individuals and 21 entities, recognised as Iranian petroleum transporters or Hizballah financiers. Additionally, 12 oil tankers were identified as blocked property as a result of being owned or controlled by sanctioned individuals. Later in the month, a further 22 entities across the UAE, Hong Kong, and Turkey were sanctioned for facilitating Iranian petroleum sales and acting as front companies for financial transfers benefiting the IRGC.

• On the sectoral front, two individuals and one entity were added to the UK’s Chemical Weapons sanctions list for their membership of the Radiological, Chemical and Biological Defence Troops of the Russian Ministry of Defence and their supply of chemical grenades to the Russian military respectively. In the EU, eight individuals and one entity were added to the global human rights sanctions list for committing serious human rights violations and abuses on behalf of the Iranian state bodies outside of Iran. Six members of Venezuela’s Tren de Aragua gang were designated pursuant to OFAC’s transnational criminal organisations and terrorist financing regimes. Venezuela’s Cartel de los Soles was also designated for its support to Tren de Aragua; the organisation is understood to be headed by Venezuelan President Nicolas Maduro.

• This month saw a number of noteworthy delisting applications. Belarusian chemicals company Grodno Azot had applied to overturn its December 2021 listing by the EU as part of its Belarusian sanctions programme. The decision was affirmed in February 2023 and a subsequent appeal rejected this month, due to findings that the company’s dividends are a source of substantial income for the Lukashenko regime. Elsewhere, the 2023 and 2024 listing of Hala Almaghout, widow of Mohammed Makhlouf, the uncle of former president Bashar Al Assad, was annulled in light of evidence that she was a victim of intimidation and persecution by the former Syrian regime and the Makhlouf family. She remains sanctioned due to being relisted in the period between her hearing and the handing down of the judgement. Delisting applications for three further members of the Makhlouf family, including a different widow of Mohammed Makhlouf, were rejected. In the UK, Abramovich associate Eugene Shvidler failed to overturn sanctions against him after his listing was upheld by the Supreme Court.

Regulation Amendments

• The US continued its easing of measures against Syria, revoking most sanctions regimes but retaining specific measures against members of the former Assad regime, mirroring actions taken by the EU. Notable entities no longer subject to restrictions include the National Defence Forces, the 1^st and 4^th Divisions of the Syrian Arab Army, and Syria’s state-run oil company, Sytrol.

• The UN Security Council voted to extend its sanctions regime against the Democratic Republic of Congo for a year, continuing its arms embargo as well as asset freezes and travel bans in response to hostilities in North and South Kivu. The UN further amended its Haiti sanctions regime to create a new designation criterion for people and entities engaging in destabilising activities through the illicit exploitation or trade of natural resources. The arms embargo for Haiti was further expanded to prohibit all armaments as well as technical and financial support for military activities. These amendments have also been adopted by the UK, where the arms embargo on Azerbaijan and Armenia was also amended.

• The UK introduced a new regime targeting irregular migration, announced back in January, shortly followed by its first designations: 20 individuals and five entities found to be involved in people smuggling networks in Turkey, Iraq, across the Balkans among others. Two general license for this regime were issued, permitting a person to make funds available so UK designated persons can meet their basic needs, and permitting FCA officers to carry out duties otherwise permitted by sanctions.

• The UK also effected measures to allow Treasury debts to be settled, provided payments to UN-designated persons satisfy sovereign debt obligations and the person making the payment has reasonable cause to suspect the obligation arose before the designated person was sanctioned. These measures apply to UK sanctions on the Central African Republic, Haiti, Libya, South Sudan, and Yemen.

• EU sanctions against Lebanon were renewed until July 2026, enabling the designations of individuals and entities who persistently hamper the formation of government in Lebanon, commit serious financial misconduct in relation to public funds, and obstruct or undermine critical economic or public sector reforms in the country. There remain, however, no designations within this list.

Enforcement

• The US was particularly active in the enforcement space this month, with several notable settlements below the maximum penalty owing to steps taken by companies to self-disclose violations. For example, OFAC announced a $608,825 settlement with Delaware-registered global logistics company Key Holding after its Colombian subsidiary facilitated 36 freight shipments to Cuba in violation of US sanctions between 2022 and 2023. The company could have faced a maximum penalty of $4 million had it not self-reported its sanctions violations. A similar reduced penalty was applied to Harman International Industries Inc for its 11 violations of sanctions on Iran. In this instance, only $1.45 million of a maximum $4 million penalty was handed down, in light of self-disclosure and other mitigating factors.  Finally, Interactive Brokers avoided the most substantial fine of the trio, totalling $60 million, instead agreeing an $11.8 million settlement in light of improvements to its compliance framework, voluntary disclosure, and the limited economic benefits to sanctioned persons who accessed its systems. In contrast, the US’ Bureau of Industry and Security agreed a $4.25 million settlement with Alpha and Omega Semiconductor Inc over 15 export controls violations, for which the maximum fine was $5.6 million.

• This month also saw the conviction and arrest respectively of two individuals over sanctions violations. Chicago’s District Court convicted Ahsraf Al Safoo, leader of Khattab Media Foundation, of conspiring to provide material support to Islamic State by sharing IS propaganda online. At his sentencing in October he will face a maximum penalty of 130 years in prison.  Meanwhile, the CEO of an Iranian engineering company, Bahram Ostovari, was arrested on charges of violating sanctions on Iran, allegedly using two Emirati front companies to export goods; Ostovari will face a maximum of 20 years in prison if convicted.

• Also in the US, the Justice Department announced enforcement action against illicit revenue generation schemes designed by the Democratic People’s Republic of Korea to evade sanctions in 16 US states. These actions targeted North Korean individuals who obtained US employment using stolen or fake IDs to steal export-controlled US military technology and virtual currency.

• In France, the Central Bank’s Supervision and Resolution Authority fined Banque Delubac et Cie EUR 600,000 for sanctions compliance failures, including its failure to implement internal systems to apply EU asset freeze sanctions.

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In a rare move the US condemned the UK, along with four other countries, for the designations of the Israeli Finance Minister and National Security Minister for the abuse of Palestinian human rights.  The US Government asked the UK to reverse the sanctions, whilst Israel has said it will take steps against the UK and the other countries involved.

Regarding Russia, the EU has extended its regime against Russia and further updates are expected this week on the EU’s 18^th Russia sanctions package after Hungary and Slovakia voted against the proposal in late June.  The UK has continued designations, whilst there was a lack of US activity against Russia this month.

Enforcement actions continued at pace in the US, with notable cases involving sanctions evasion through cryptocurrency, arms exports, and illicit trade with China, DPRK, Iran, Venezuela and Russia.  In the UK an art dealer was sent to prison for a series of sales to a sanctioned Hizballah financier.

Middle East

• The US has revoked six Executive Orders enforcing sanctions on Syria, whilst ensuring the continuation of sanctions against Bashar Al Assad, his associates, and other destabilising regional actors. Six members of the US House of Representatives also introduced a bill to repeal permanently The Ceasar Syria Civilian Protection Act which imposed US sanctions on Syria, rather than relying on rolling waivers.  The EU also designated five Syrian nationals for their alleged involvement in the Assad regime and human rights abuses.

• US President Donald Trump has said he would consider lifting sanctions on Iran “if they can be peaceful,” despite having previously said he would not lift sanctions following a ceasefire between Israel and Iran.

• In a joint action with Australia, Canada, New Zealand, and Norway, the UK has sanctioned Israeli Finance Minister Bezalel Smotrich and National Security Minister Itamar Ben-Gvir for inciting “extremist violence and serious abuses of Palestinian human rights.” The US Department of State condemned the sanctions and has asked for them to be reversed.  In response, Smotrich cancelled a waiver allowing Israeli banks to provide services to Palestinian financial institutions, and has stated that the Israeli Parliament is working towards “a package of steps” against the countries that have imposed sanctions.

• The US Department of State sanctioned four ICC judges for authorising investigations against US personnel in Afghanistan and for authorising arrest warrants against Israeli politicians Benjamin Netanyahu and Yoav Gallant. The ICC issued a statement criticising the designations for undermining the independence of the judicial body.  The European Commission is reportedly discussing further sanctions on West Bank settlers and Hamas supporters.

• OFAC also designated 10 people and 27 entities on its Iran list, all of which comprise a network tied to the Zarringhalam brothers, three Iranians who have laundered billions of dollars via Iranian exchange houses and foreign front companies as part of Iran’s shadow banking network. OFAC also sanctioned one person and eight entities and identified one vessel as blocked property for involvement in the procurement and transshipment of sensitive machinery for Iran’s defence industry.  Elsewhere, OFAC sanctioned four people and 12 entities, and identified two vessels as blocked property, for their alleged involvement in importing oil and “other illicit goods” in support of the Houthis, as well as a Ugandan national due to his alleged funding and recruiting for ISIL.  OFAC also designated five people and six charities who are alleged to have financially supported Hamas and the Popular Front for the Liberation of Palestine.

Other Designations

• Donald Trump signed a proclamation, in which the US Government has fully restricted entry for nationals from 12 countries, including Afghanistan, Myanmar, and Iran, and partially restricted entry from nationals from seven countries, including Cuba, Turkmenistan, and Venezuela. The US Department of State also imposed visa restrictions on several Central American government officials and their family members for their nexus to the Cuban regime’s forced labour scheme, whilst three US senators have also introduced a bill to apply US sanctions on government officials in El Salvador who engage in human rights violations and to hold El Salvador accountable for “its collusion with the Trump Administration to imprison people without due process.”

• Throughout the month OFAC continued its designations of South American cartels under its counter narcotics and counter terrorism regimes. Designations included six individuals for trafficking cocaine from South America to the US, Europe and Caribbean; three people and ten entities associated with Los Chapitos, a faction of the sanctioned Sinaloa Cartel, for controlling laboratories linked to counterfeit pills containing fentanyl; five leaders of the Jalisco Nueva Generacion Cartel for allegedly participating in gang-related financial crime, violence, and narcotics production and trafficking; and the leader of Tren de Aragua, a US-designated foreign terrorist organisation and transnational criminal organisation alleged to be involved in the narcotics trade and human trafficking, among other things.  The US has also imposed visa restrictions on family members and associates of individuals sanctioned for narcotics trafficking.

• Throughout the month, the EU designated three people and one entity on its Guatemala sanctions programme. Under the EU’s Russia hybrid threats sanctions regime, the European Council also sanctioned Nathalie Yamb, a Swiss-Cameroonian dual national and social media influencer, for her outspoken support for Russia and ties with an organisation linked to Russian private military activity in Africa.

• The UK designated four individuals and six entities on its Russia sanctions list, also specifying 20 vessels under its Russia Regulations which are prohibited from accessing UK ports.

Regulation Amendments

• The EU extended its sanctions regimes against Crimea and Sevastopol, and Russia, and amended its Common Customs Tariff so Belarussian and Russian agricultural imports to the EU no longer benefit from import duty exemptions. The EU also announced the details of its 18^th Russian sanctions package to further target Russia’s energy reserves and infrastructure, its banking sector, its shadow fleet, and to lower the crude oil price cap from $60 to $45.  The package includes a prohibition on EU operators from transactions concerning the Nord Stream pipelines, as well as the designations of several Russian and foreign companies said to support Russia’s military and industrial complex.  The package requires unanimous support by EU Member States before it can be adopted and has met opposition from Hungary and Slovakia who reportedly voted to block it.  The next vote is scheduled in early June.

• UK press reported that the UK National Crime Agency has identified individuals to be sanctioned under a new “illegal migration” sanctions regime. Legislation for the regime is due to be passed by parliament later in the year. The UK also introduced legislation to protect employees who disclose potential violations to the Government.  OFSI has extended two General Licences permitting certain activities, including the maritime transfer of Russian oil, related to the Sakhalin-2 Project, an oil and gas development in Russia which supplies roughly 9% of Japan’s LNG imports.

• The UN Security Council voted to extend its South Sudan and Democratic Republic of Congo regime for a year, as well as its arms embargo on Libya for six months.

Enforcement

• Chinese national Cui Guanghai, UK national John Miller and an unnamed US resident were charged with violations of the US Arms Export Control Act. The defendants, who are currently in Serbia, are alleged to have, among other things, procured US defence items for export to China and attempted to prevent an individual from criticising the Chinese government.  Another Chinese national, Shenghua Wen, pleaded guilty to criminal charges of exporting firearms, ammunition, and other military items to DPRK by concealing them inside shipping containers departing from California, in return for approximately $2 million sent by DPRK government officials.  The US Department of Justice (“DoJ”) separately announced enforcement action against DPRK illicit revenue generation schemes designed to evade sanctions in 16 US states, targeting North Korean individuals who obtained US employment using stolen or fake IDs to steal export-controlled US military technology and virtual currency.

• The DoJ is reportedly investigating Indian publicly-listed trading house Adani Enterprises Limited for alleged sanctions breaches related to the import of petrochemicals to India from Iran. Adani Enterprises has denied knowledge of the investigation and any engagement in sanctions evasion.  Also in relation to Iranian sanctions, the US Court of Appeals upheld the conviction of an individual for sending construction equipment to Iran without a licence, and OFAC imposed a $3.9 million fine on petroleum catalyst product supplier Unicat Catalyst Technologies LLC as part of a settlement agreement over the company’s violations of US sanctions on Iran and Venezuela.

• A criminal complaint has been lodged in the US against two individuals who allegedly conspired to sell chemical catalysts and industrial equipment to Venezuelan state-owned steel and petrochemical companies. They face 20 years’ imprisonment if found guilty.

• Regarding Russia, the assets of sanctioned Russian oligarch Suleiman Kerimov were a focus in June. OFAC issued a penalty notice for almost $216 million against venture capital firm GVA Capital Ltd for managing Kerimov’s investments after his designation and failing to comply with an OFAC subpoena.  A New York court also refused to stay the forfeiture of Kerimov’s seized Amadea yacht; Eduard Khudaintatov argued that he was the true owner of the yacht, although the court found that he had not provided sufficient evidence that he was not a proxy owner.  Separately, the DoJ unsealed a 22-count indictment of Iurii Gugnin, a New York resident and Russian citizen, with various offenses related to using his cryptocurrency company Evita to funnel over $500 million of overseas payments to aid Russian banks and help Russian end-users to acquire sensitive US technology while hiding the source and purpose of the transactions.

• In the UK, the UK Crown Prosecution Service sentenced art dealer Oghenochuko Ojiri to two years and six months in prison for failing to report sales to Nazem Ahmad, an alleged financier of Hizballah, who has been sanctioned by the US since 2019 and the UK since 2023. Separately, British aviation expert David Greenhalgh and Greek financier Christos Farmakis have pleaded not guilty to 17 charges under the UK Export Control Act, which included involvement in the supply and delivery of weapons and defence equipment to several countries, including Sudan, South Sudan, Iran, Libya and Syria.  The Court of Arbitration for Sport has held that UK sanctions make it temporarily unlawful for West Ham United Football Club to pay a transfer fee owed to Russian football club CSKA under a transfer agreement.

• In the EU, the EU General Court rejected the delisting applications of Alfa Bank JSC and its major shareholder German Khan, but annulled the March 2024 listing of Vyacheslav Aleksandrovich Boguslayev. An Estonian journalist, Svetlana Burceva, was convicted of sanctions violations and treason, having allegedly worked for the Russian media conglomerate Russia Today.  She was sentenced to six years’ imprisonment in total, two of which were attributed to sanctions violations.

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