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.
