Last Week's Major Developments in Sanctions - April 20, 2026, to April 24, 2026
- May 1
- 6 min read
You can now listen to the audio version of our weekly sanctions updates here.
Monday, April 20
The UK government is making several amendments to various sanctions-related regulations to improve the clarity, consistency and strength of the UK's sanctions regulations. Specifically, the new amendments, which will come into force on May 13, will impact 36 of the UKs sanctions regimes. (The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026)
Tuesday, April 21
The EU Council adopted Council Decision (CFSP) 2026/897:
Extending EU restrictive measures in respect of the Republic of Moldova (Council Decision (CFSP) 2023/891 of 28 April 2023 concerning restrictive measures in view of actions destabilising the Republic of Moldova), until 29 April 2027; and,
Amending the entries for seven persons included in the list of natural and legal persons, entities and bodies subject to restrictive measures. EU restrictive measures, which include asset freeze, prohibition on making funds available to those listed (directly or indirectly), and a travel ban, currently apply to a total of 23 individuals and 5 entities. (Here and press release)
The EU Council adopted Council Decision (CFSP) 2026/884, amending its Russia sanctions framework to add two entities to the sanctions list for spreading disinformation and supporting Russian influence operations. (Here, and press release)
OFAC designated eight individuals, four entities, and two aircrafts, based in Iran, Turkey and United Arab Emirates, for their involvement in procuring or transporting weapons or weapons components on behalf of the Iranian regime under various Iran related authorities. (Here, U.S. Department of Treasury Press Release, and U.S. Department of State Press Release)
Wednesday, April 22
In a major update from the U.K., OTSI published its first guidance for businesses to help them understand ‘Sanctions End-Use Controls’ and how to ensure compliance. In short, Sanctions End-Use Controls are designed to prevent sanctioned goods and related technology from reaching sanctioned jurisdictions and end users. As a result, when U.K. exporters have been “informed” by the U.K. Government that their goods are at the risk of being diverted to a sanctioned destination, there is a requirement to obtain a license. (Here)
Thursday, April 23
The 20th package of EU sanctions against Russia was finally adopted. (Press release) Hungary and Slovakia had withheld their support for the package which was supposed to be adopted in February. The 20th package consists of two decisions:
Council Decision (CFSP) 2026/504:
Added a new designation ground to designate persons who own, control, manage or operate shadow fleet transporting Russian oil, or that otherwise provide material, technical or financial support to the operations of such vessels;
Introduced new derogations; and,
Designated 37 individuals and 80 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.
Council Decision (CFSP) 2026/508:
Added 60 entities to the list of legal persons or entities in Annex IV to Decision 2014/512/CFSP, which support Russia’s military and industrial complex in its war of aggression against Ukraine. Addition to this list means tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defense and security sector;
Introduced additional export and import restrictors;
Extended the list of goods and technology subject to the prohibition on transit via the territory of Russia;
Expand the existing broadcasting prohibition to also restrict broadcasting and the facilitation of broadcasting in the Union of content of entities which mirror the content of other entities that are already subject to the prohibition;
Introduced a prohibition on providing liquified natural gas terminal services to Russian entities or to entities owned or controlled by Russian nationals or operators;
Added Yelo Bank (Azerbaijan) to the list of entities in Annex XVIII which includes entities or bodies established outside Russia that use the System for Transfer of Financial Messages (‘SPFS’) of the Central Bank of Russia or equivalent specialized financial messaging services set up by the Central Bank of Russia or the Russian State, or any systems of the Central Bank of Russia and any systems provided by any other Russian entity that include a financial messaging functionality, including the Fast Payment System (SBP) and Mir.
Prohibited engaging, directly or indirectly, in any transaction involving central bank digital currencies such as the digital rouble or providing support to the development of such projects;
Added RUBx, and Digital rouble to list of crypto-assets the use of which is prohibited in transactions, as those crypto assets are determined to pose a risk of circumventing the the EU sanctions, effective May 24, 2026;
Introduced a broad ban on engaging with any crypto-asset service provider that is established in Russia, and making use of any platform that is established in Russia, which facilitates the transfer and exchange of crypto-assets;
Added 20 financial institutions to the list of legal persons, entities or bodies subject to a transaction ban;
Added requirement for specific due diligence and a mandatory clause in tanker vessel sales agreements in accordance with which the vessels cannot be sold on or transferred to any natural or legal person, entity or body in Russia, or for use in Russia in order to ensure that vessels sold by Union operators do not join or support the shadow fleet;
Identified the Kyrgyz Republic as a jurisdiction where the risk of circumvention is systematic and persistent, with authorities failing to prevent the sale, supply, transfer, or export to Russia of goods and technology as listed in Annex XIV to Decision 2014/512/CFSP, exported from the Union;
Added two ports and locks in Russia, and one port and lock in in Indonesia to the relevant Annex to Decision 2014/512/CFSP, that are used for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices;
Added 45 vessels to list of named shadow fleet; and
Added Joint Development Bank (Laos), Keremet bank (Kyrgyzstan), OJSC Capital Bank of Central Asia (Kyrgyzstan), Arneis, Asia Import Group, GPAgent, Platejka to the list of financial institutions and entities with which it is prohibited to directly or indirectly engage in any transaction.
The EU also adopted Council Decision (CFSP) 2026/512 to expand restrictive measures against Belarus in response to its continued support for Russia’s war in Ukraine. The measures
Broaden export and import bans,
Impose a prohibition on engaging in any transaction involving a Belarusian Central Bank digital currency or providing any support to the development of such a project,
Prohibit transactions with any crypto-asset service providers established in Belarus or with any decentralized platforms established in Belarus that enable the exchange or transfer of crypto-assets
Introduce new restrictions on services such as technology and tourism, and strengthen anti-circumvention controls, including transit bans.
In line with an earlier announcement, the UK government updated the remit of OTSI's responsibilities in issuing licenses. In this guidance the UK government explains the responsibilities of OTSI, ECJU, and Import Controls and Sanctions team. Concurrently, OTSI updated its guidance on how OTSI assesses license applications to reflect the new changes. (Here) OTSI also updated the following guidance documents to reflect its new responsibilities: Apply for a license to carry out sanctioned trade through OTSI, and Trading under sanctions with Russia. Furthermore, OFSI amended its guidance documents for the Afghanistan, Democratic Republic of Congo, Haiti, Central African Republic, DPRK, and Russia sanctions regimes to clarify which UK Department for Business and Trade teams now lead on the sanctions office, sanctions licensing and trade licensing. The Russia sanctions guidance update also include new reference to the Sanctions End-Use Controls.
OFAC designated nine individuals (six in Mexico, one in Guatemala and one in India) and 14 entities (ten in Mexico, two in Guatemala, two in India and one in the U.S.) that were allegedly part of the Sinaloa Cartel’s global supply chain under E.O. 14059 pertaining to Global Illicit Drug Trade and Global Terrorism Sanctions Regulations. (Here, U.S. Department of Treasury Press Release, and U.S. Department of State Press Release).
OFAC designated five individuals and 24 entities (all in Cambodia) linked to cyber-enabled fraud operations in Cambodia under the Cyber-related sanctions Regime, targeting networks responsible for scams defrauding U.S. victims and generating illicit revenue streams. (Here, U.S. Department of Treasury Press Release, U.S. Department of State Press Release). Concurrently, OFAC issued Cyber-related General License 2, authorizing certain transactions involving Anco Water Supply Co. Ltd. to ensure continuity of essential drinking water services despite sanctions restrictions. (Here)
Friday, April 24
OFAC designated 20 entities and 19 vessels under Iran’s Sanctions programRegime under E.O. 13902, targeting a global network that has been allegedly involved in sustaining Iran’s oil trade. (Here, U.S. Department of Treasury Press Release, U.S. Department of State Press Release) Among the designated parties was the second largest China-based independent refinery, Hengli Petrochemical (Dalian) Refinery Co., Ltd., which allegedly continued to purchase Iranian oil. OFAC issued Iran-related General License V, "Authorizing the Wind Down of Transactions Involving Hengli Petrochemical (Dalian) Refinery Co., Ltd." (Here)
A Chinese national was arrested at JFK Airport and charged for allegedly photographing sensitive military aircraft at Offutt Air Force Base in Nebraska without authorization. He had previously been confronted by the FBI and later apprehended while attempting to travel, with authorities citing national security concerns. The case remains under investigation, with potential for more serious charges beyond the current offence carrying up to one year imprisonment. (Here)
OFSI issued the General Licence INT/2026/9512597. The General Licence pertains to legal Services which took take effect following the expiry of Legal Services General Licence INT/2025/7323088 on 28 April 2026. This General Licence permits a UK legal firm or UK counsel who has provided legal advice to a person designated under the UK Autonomous Sanctions Regimes to receive payment from that designated person without an OFSI specific license, provided that the terms of the General Licence are met. Concurrently, FAQ 170 was withdrawn and FAQ 184 was added following the new General Licence. Furthermoer, FAQ 50 and FAQ 57 were amended. (Here)
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