Sanctions Guide – July 2026

The EU’s 21st package of sanctions against Russia is the headline for sanctions activity in July.  Among other measures, the package introduced 218 listings and expanded restrictions across Russia’s financial services, crypto-assets, energy, military-industrial and trade sectors.  The EU and UK also coordinated measures against Russian cyber and hybrid operations and imposed sanctions linked to surveillance technology, Ukrainian detainees and the poisonings of Alexei Navalny and Dawn Sturgess.

 

Iran was focus for the US.  Following attacks on US ships in the Strait of Hormuz, the US revoked its general licence, which had temporarily authorised Iranian oil transactions.  Subsequent designations targeted Iranian oil, shipping, finance and procurement networks.  The UK also designated the Islamic Revolutionary Guard Corps (“IRGC”) and the Islamic Movement of Companions of the Right, the first groups named under its new foreign state-threat framework.

 

The UK’s HM Revenue & Customs reached a £6.4 million settlement with Airbus’ UK subsidiary, whilst the UK National Crime Agency applied for the forfeiture of $357,000 held by a sanctioned Russian individual.  In the US a US-Iranian national was convicted for breaching Iranian sanctions.  Wider developments included measures against Sudan’s conflict-gold economy, a proposed EU migrant-smuggling sanctions regime, the beginning of the US process to remove Syria’s state-sponsor-of-terrorism designation, and the removal of 84 outdated entries from OFAC’s sanctions list.

 

Russia

 

• The EU adopted its 21st Russia sanctions package on 24^th July, introducing 218 additional listings and measures across the energy, financial services, military-industrial and trade sectors.  The package froze assets belonging to 94 financial institutions, prohibited transactions with 33 additional Russian credit and financial institutions and 11 crypto-related platforms, and listed 41 shadow-fleet vessels.  It also targeted the A7 payments network, listed 56 military-industrial targets, tightened dual-use export restrictions on 51 entities, expanded trade controls and paused automatic adjustment of the oil price-cap mechanism until 15^th July 2027.

 

• The UK and EU imposed a coordinated cyber sanctions package on 13^th July.  The UK listed 24 people and entities, targeting Main Intelligence Directorate (“GRU”) Unit 29155, senior GRU figures, operators of the Lumma Stealer malware, members of Cyber Army of Russia Reborn and personnel associated with media company Rybar LLC.  The EU listed nine people and four entities.  The UK and EU member states also attributed an attack on Poland’s energy grid to the Russian Federal Security Service’s Centre 16.

 

• Human-rights and chemical-weapons measures remained prominent.  The EU listed six people connected to the poisoning and death of Navalny, while the UK listed seven people and two research institutes linked to the poisonings of Navalny and Sturgess.  Further EU measures targeted Russian surveillance technology companies, executives, prison personnel and detention facilities accused of involvement in abuses against Ukrainian prisoners of war and civilians.  The EU also designated one person and five ABS Electro Group entities involved in producing components used in Russian drones and guided bomb kits.

 

• The UK removed sanctions targeting the Azerbaijan state-owned vessel MT Zangazur, following in line with the EU which de-listed the tanker in April 2026.  The vessel had previously been identified as part of Russia’s shadow fleet.  The US removed four Indian companies previously listed for sanctions evasion and exports to the Russian military.  Neither authority provided reasons for the delistings.

 

Iran

 

• On 9^th July, following strikes on US ships in the Strait of Hormuz, the US revoked General Licence X, which had temporarily authorised oil transactions.  Replacement General Licence X1 authorised wind-down transactions until 17^th July and required payments to blocked persons to be placed in blocked US accounts.  On 16^th July the US designated over 50 people, entities and vessels connected to Mohammad Hossein Shamkhani’s shipping network, described by OFAC as a major force behind Iranian oil exports.  Twenty vessels were also blocked.  OFAC stated that more than 200 targets connected to the network have now been sanctioned.

 

• Financial and evasion networks were also targeted.  The US designated eight people and six entities, including financier Ali Ansari, Smart Global Ltd and three Iranian exchange houses, for moving foreign currency for sanctioned banks and supporting senior officials.  The EU later listed Ansari for transferring proceeds from Iranian oil sales through foreign banking channels.  The US separately listed four people and nine entities connected to Babak Zanjani’s network, which allegedly used financial services, gold, digital assets and transport projects to move funds and conceal ownership.

 

• The US designated 10 entities and eight tankers involved in Iranian petroleum activity and the alleged monetisation of passage through the Strait of Hormuz.  Targets included Persian Gulf Marine Insurance Company, HormuzSafe Marine Services Authority, tanker operators and vessels transporting Iranian crude oil and petroleum products to China.  Procurement and counterterrorism measures included four people and three entities involved in an IRGC weapons-procurement network spanning Iran, Nigeria, Italy and Russia.  The US also listed one person and five entities connected to Mahan Air, including representatives in China, India and Russia and an IRGC-affiliated front company alleged to have solicited locations of US and Israeli equipment for military targeting.

 

• The UK designated the Islamic Movement of Companions of the Right (IMCR) under its Iran regime for involvement in hostile activity by the Iranian government.  After enacting the National Security (State Threats) Act 2026, the UK made the IRGC, the IMCR and Russia’s GRU Volunteer Corps its first foreign state-threat designations.  The EU listed five Iranian judges for proceedings against religious minorities and political dissidents, and an IRGC-linked hacker associated with the Ashiyane cyber group.

 

Enforcement

• HMRC concluded a £6.4 million compound settlement with Airbus Operations Ltd for offences under the Export Control Order 2008.  Over a sustained period before 2008, Airbus reportedly failed to maintain accurate records and registers for controlled-technology transfers under .

 

• The UK National Crime Agency applied to Westminster Magistrates’ Court for permanent civil forfeiture of $357,000 held by sanctioned Russian national Sergei Sergeevich Tregub.  The application concerns funds suspected of being proceeds of crime or intended for unlawful conduct and a trial is expected in March 2027.

 

• A federal jury in Boston convicted dual US-Iranian national Mahdi Mohammad Sadeghi of illegally exporting sophisticated electronic components to Iran.  Prosecutors said he routed US-origin accelerometers, gyroscopes and inertial measurement units through a Swiss front company to an Iranian entity connected to navigation systems used by the IRGC’s drone programme.  Sentencing is scheduled for October 2026.

 

• The US Court of Appeals for the District of Columbia Circuit upheld OFAC’s designation of precious-metal traders Axel and Fritz Diegelmann for operating in Russia’s metals and mining sector.  The court held that trading refined precious metals could constitute procuring geological materials and rejected their challenge to the supporting evidence.

 

Other Designations, De-Listings, and Regulatory Updates

 

• The EU introduced sectoral sanctions on Sudanese-origin gold, mining equipment and related technical, brokering and financial assistance, stating that gold revenue sustains the conflict.  The UK separately designated four people and seven entities involved in gold, procurement and financial networks supporting the Rapid Support Forces or Sudanese Armed Forces, including actors trading through Dubai and Hong Kong.  In the wider continent, the UN added six people and two entities to its Democratic Republic of Congo sanctions list, including the Congo River Alliance, Twirwaneho and associated armed-group leaders.  The UK meanwhile added the UN-designated tanker Avax to its Libya specified-ships list over alleged illicit petroleum exports.

 

• US measures against Latin American organised crime expanded significantly.  The US designated Ecuador’s Chone Killers, Mexico’s Juárez Cartel and Los Viagras as terrorist organisations, listed two people and four entities connected to Brazil’s Primeiro Comando da Capital, and designated more than 50 people and entities linked to Cartel de Jalisco Nueva Generación, including alleged new leader Juan Carlos Gonzalez.  Elsewhere in Latin America, the US targeted Cuba, first listing its Ministry of Tourism and nine other state-linked entities, and following with nine entities and two people involved in energy, financial services, overseas medical missions and the Grupo de Administración Empresarial SA network.

 

• The US listed a UK-based leader of the Egyptian Muslim Brotherhood and three people and three entities accused of supporting Hamas. The EU designated seven people and three entities connected to Prince Holding Group and South-East Asian scam centres for alleged trafficking, torture and other abuses.  The US separately listed the 1VPNS network and two operators for providing services and tools to ransomware actors.  The United Nations added six people and two entities to its Democratic Republic of Congo sanctions list, including the Congo River Alliance, Twirwaneho and associated armed-group leaders.

 

• The European Commission proposed a sanctions regime targeting migrant smuggling, human trafficking and serious organised crime.  The proposal would impose asset freezes and travel bans but requires unanimous Council approval.  The US separately began the process of rescinding Syria’s designation as a state sponsor of terrorism.  It also allowed the expiration of Executive Order 13936 relating to Hong Kong, while transferring persons sanctioned under continuing legislation to OFAC’s Non-SDN Menu-Based Sanctions List.  Separately, OFAC removed 84 outdated people and entities from its Specially Designated Nationals list and corrected 18 duplicate entries.