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Last Week's Major Developments in Sanctions - April 13, 2026, to April 17, 2026

  • Apr 21
  • 6 min read
You can now listen to the audio version of our weekly sanctions updates here.

Monday, April 13

  • BIS reached an Administrative Enforcement Settlement with Coastal PVA Technology, Inc. The company exported semiconductor-related brushes to Chinese Entity List companies (SMIC Beijing and SMIC North) on 18 occasions without the required BIS license, due to inadequate export compliance controls. The company settled with BIS, admitting the violations and agreeing to a $1.7 million civil penalty. However, the payment of the fine was fully suspended subject to compliance with the terms of the settlement agreement along with mandatory compliance training and an internal audit. (Here)


Tuesday, April 14

  • OFSI issued General License INT/2026/9491628 under regulation 20 of the Global Human Rights Sanctions Regulations 2020. This General License allows for insolvency-related payments and activities connected with the Prince Group and their Subsidiaries. (Here)

  • OFAC imposed sanctions on three individuals and three entities (all in Mexico) under Executive Order 14059 of December 15, 2021 for their involvement in global illicit drug trade. (Here, the Department of Treasury press release, and the Department of the State’s press release) Concurrently, OFAC issued Counter Terrorism General License 35, "Authorizing the Wind Down of Transactions Involving Entities Blocked on April 14, 2026." (Here)

  • OFAC also issued Russia-related General License 128C, "Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia," which supersedes GL 128B, continuing to authorize transactions related to Lukoil retail service stations outside Russia. The key change is an extension of the authorization period from April 29, 2026 to 12:01 AM EDT on October 29, 2026. (Here) OFAC amended one Russia-related Frequently Asked Question to reflect the amended licenses (FAQ 1225). Concurrently, OFAC issued Russia-related General License 130A, "Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria which extends earlier authorizations relating to transactions involving specified Lukoil entities incorporated in Bulgaria and entities in which they hold, directly or indirectly, a 50% or greater interest. GL 130A extends the expiration of the authorization from April 29, 2026 to 12:01 AM EDT on October 29, 2026. (Here)

  • OFAC issued Venezuela General License 56, "Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela," (Here) and Venezuela General License 57, "Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals." (Here) OFAC also issued one Venezuela-related Frequently Asked Question, (FAQ 1248).

  • OFAC has released a Quarterly Report of Licensing Activities pursuant to Section 906(b) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by OFAC under Section 906(a)(1) of the TSRA from October through December 2025. (Here)


Wednesday, April 15

  • OFSI published its Strategy 2026-2029 setting out OFSI’s core objective in ensuring efficiency of UK sanctions. The Strategy reflects the growing use of sanctions amid geopolitical instability, aligned with challenges and opportunities OFSI expects over the next three years. (Here)

    • What the strategy covers: Primary goal is ensuring sanctions are effective, resilient, and impactful, built around the “Promote, Enable, Respond, Change (PERC)” framework covering guidance, licensing, enforcement, partnerships, and long-term system change.

    • What is new/renewed in this Strategy: Stronger data- and intelligence-led approach, expanded use of AI and digital tools, deeper public-private and international coordination, clearer guidance and expectations for industry, and a focus on faster, more predictable licensing and enforcement outcomes.

    • What has changed in this Strategy: Shift toward proactive, risk-based enforcement and intelligence-driven actions, more structured and measurable delivery via KPIs, expanded counter-terrorism role, streamlined systems (e.g., unified sanctions lists, new settlement scheme), and a broader mandate addressing emerging risks like crypto and sanctions circumvention.

  • OFAC imposed blocking sanctions against three individuals (two in the United Arab Emirates, one in London), 17 entities and nine vessels under ​​Executive Order 13902 of January 10, 2020 pertaining to Iran and Global Terrorism Sanctions Regulations. The sanctions were imposed for their links to an Iranian oil shipping network led by Mohammad Hossein Shamkhani, targeting efforts to evade sanctions and generate revenue for the Iranian regime. It also designated a separate network involving an Iranian-Hizballah financier facilitating oil-for-gold transactions with Venezuela to fund terrorist activities. (Here, the Department of Treasury press release, the Department of State press release)

  • The Justice Department today announced the sentencings of two U.S. nationals, Kejia Wang, 42, and Zhenxing Wang, 39, for their roles in facilitating North Korean remote information technology workers posing as U.S. residents to obtain work at more than 100 U.S. companies. The multi-year scheme used the stolen identities of at least 80 U.S. persons and generated more than $5 million in illicit revenue for the government of the Democratic People’s Republic of Korea. (Here)

  • An Armenian national pleaded guilty in a federal court in Austin to participating in a criminal conspiracy to export goods from the United States to the Russian Federation through the Republic of Armenia without the requisite license or authorization from the U.S. government. From February 2022 until at least August 2024, Kamo Kirakosyan knowingly and willfully combined, conspired, and agreed with others to export and reexport goods subject to the Export Administration Regulations without having first obtained the required licenses from BIS. The exported goods included items that could be used for semiconductor manufacturing. (Here)


Thursday, April 16

  • FinCEN amended its June 2025 order which imposed special measures against CIBanco S.A., Institución de Banca Multiple (CIBanco), as a financial institution that is of primary money laundering concern in connection with illicit opioid trafficking by authorizing certain transmittals of funds to facilitate payments necessary for the Government of Mexico to liquidate CIBanco. (Here) This is a testament to the potency of FinCEN’s special measures: the bank that was targeted by FinCEN is now going through liquidation.

  • FinCEN issued its Year in Review highlighting some key accomplishments including approximately $10 billion saved through deregulatory actions, over 90 percent of surveyed partners reporting the value of Bank Secrecy Act data, and nearly 600 stakeholder engagement and training events. FinCEN also continues to drive impact through efforts that have helped return nearly $1 billion to fraud victims since 2015. (Here)

  • OFSI amended General License INT/2025/7628424 to expand its scope and operational flexibility. The definition of “IT Providers” was broadened, and new permissions were introduced allowing third parties to make payments on behalf of designated persons , with reimbursement permitted from UK accounts, as well as enabling currency conversions and related fund transfers. Reporting requirements were updated to reflect these changes, particularly to capture payments made via intermediaries. The licence has also been extended by six months and will now expire on 22 October 2026. (Here)

  • OFAC imposed blocking sanctions against seven individuals and seven entities (all in Nicaragua) under Executive Order 13851 of November 27, 2018 for their links to Nicaragua’s gold sector and government for generating revenue, confiscating U.S.-owned assets, and supporting the regime, resulting in asset freezes and transaction prohibitions. (Here, the Department of State press release, the Department of Treasury press release). In connection thereto, OFAC issued Nicaragua-related General License 5, authorizing the wind down of transactions involving Exportadora de Metales Sociedad Anonima. (Here)


Friday, April 17

  • The UK Export Control Joint Unit issued Notice to Exporters 2026/12 implementing a change in the office responsible for licensing sanctioned goods and associated ancillary services for export (where these are not otherwise subject to export controls) to the Office of Trade Sanctions Implementation (OTSI) effective Monday April 27. Thereafter, the ECJU will continue to be responsible for licensing all goods and associated ancillary services which are subject to export controls (including where the destination is sanctioned). (Here)

  • OFAC imposed blocking sanctions against seven individuals in Iraq under the Global Terrorism Sanctions Regulations. (Here, the Department of Treasury Press Release, the Department of State Press Release)

  • OFAC imposed blocking sanctions against three individuals and two entities (all in Colombia) for recruiting and deploying former Colombian military personnel to fight for the Rapid Support Forces in Sudan, under Executive Order 14098 of May 4, 2023 pertaining to Sudan. (Here, the Department of Treasury Press Release, the Department of State Press Release)

  • In an attempt to keep the energy price low by increasing the global supply, OFAC issued Russia-related General License 134B authorizing the delivery and sale of crude oil and petroleum products of Russian Federation Origin (ordinarily blocked under various sanctions regulations) between April 17, 2026 to May 17, 2026. (Here)

  • The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued updated interagency guidance and this bulletin to clarify model risk management principles, to set forth a risk-based approach to model risk management, and to rescind prior model risk management guidance and other issuances. It appears that the new guidance gives larger, more sophisticated institutions room to move towards a more “risk-based approach” that is right for them. (Here)


Recommendation of the Week

  • A French court sentenced the former CEO Bruno Lafont of the cement company, who had paid facilitation payments to ISIS in Syria in order to continue Lafarge’s business in a territory controlled by ISIS, was sentenced to six years in prison. Others in the company were also sentenced to jail. The company itself was fined €1.125 million. It is important to note that Lafarge had pleaded guilty in the United States in 2022 and paid $778 Million in fines. (Check here - In French)

  • Our founder, Amir Fadavi, will speak at S&P Global's 2026 New York Trade Finance Compliance Annual Meeting. You can register to attend in person for free here.

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