Sanctions activity in February focused heavily on Iran and Russia. As tensions in the Middle East grew ahead of the US-Israeli strikes on Iran on 28th February, the US increased pressure on Iran throughout the month through sanctions targeting senior officials, including Interior Minister Eskander Momeni (“Momeni”), as well as individuals and entities involved in Iran’s petroleum trade and weapons programmes. Meanwhile, the EU formally listed the Iranian Revolutionary Guard Corps (“IRGC”) as a terrorist organisation, with the UK signalling it will introduce similar legislation whilst imposing sanctions on Momeni and other Iranian actors.
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.
