Last Week's Major Developments in Sanctions - April 27, 2026, to May 24, 2026
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You can now listen to the audio version of our weekly sanctions updates here.
Monday, April 27
The EU Council extended its Myanmar restrictive measures for another 12 months, until 30 April 2027, citing ongoing human rights violations and actions undermining democracy. The measures currently apply to 105 individuals and 22 entities. (Here, and Press Release)
Tuesday, April 28
OFAC imposed blocking sanctions against 17 individuals (16 in Iran, one in UAE) and 18 entities (seven in Iran, none in Hong Kong, three in the U.K.) under its Iran sanctions program to disrupt Iran’s shadow banking network and targeted both domestic financial operators and offshore front companies. (Here, U.S. Department of Treasury Press Release, U.S. Department of State Press Release)
OFAC also issued an alert warning financial institutions of sanctions risks linked to China-based “teapot” oil refineries, which purchase and refine the majority of Iranian crude oil—accounting for roughly 90% of Iran’s oil exports. (Here, U.S. Department of Treasury Press Release) Many have asked what does this mean in practice. Here's our founder's take on this:
The alert in relevant part reads that "U.S. and foreign financial institutions should carefully review any transactions involving China-based teapot refineries." Accordingly, the following steps could help FIs:
Identifying the exposure to those in the oil and gas sector (refineries, traders, logistic companies, insurance providers, port operators, etc.) in Shandong Province of China whether through clients or clients' counterparties;
If any exposure is found then the FI should consider recertification of clients with exposure and notify them about the heightened risk of Iranian oil and ask them to acknowledge that they are not using their FI for such transactions;
In parallel, identifying bank partners in China and having a conversation with them about how they ensure that they are not routing such transactions through their FI and documenting that.
In the same vein, OFAC issued Iran-related FAQ 1249 clarifying that “toll” payments for safe passage through the Strait of Hormuz are not authorized for U.S. persons. (Here)
The UN Security Council Committee established pursuant to Resolution 1591 (2005) concerning Sudan designated four entries for engaging in actions or policies that threaten the peace, security, or stability of Darfur, a region in Western Sudan. (Here)
Wednesday, April 29
OFAC issued Russia-related General License 131E, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities." (Here) The new license simply extends the validity of GL 131D by one month (to May 30, 2026) with no change to scope or permissions. OFAC also amended Russia-related FAQs 1224 and 1225 to reflect the new timeline.
Thursday, April 30
The U.K. Export Control Joint Unit (ECJU) published the “Strategic export controls: licensing statistics, 2025” covering export licensing decisions made by the U.K. government between January 1 and December 31, 2025. (Here) Additionally, ECJU published the quarterly breakdown of the statistics for the period between October 1 and December 31, 2025. (Here)
OFAC imposed blocking sanctions against former Democratic Republic of Congo's President, Joseph Kabila, under the U.S. sanctions program against DRC for providing financial and material support to designated armed groups M23 and AFC, which have fueled violent conflict, civilian deaths, and mass displacement in eastern DRC. (Here, U.S. Department of Treasury Press Release, U.S. Department of State Press Release)
Friday, May 1
Following last week’s updates on the role of OTSI in issuing licenses, the U.K. government continued to update its statutory guidance documents for Iraq, Iran, Zimbabwe, Yemen, Venezuela, Syria, Sudan, South Sudan, Belarus, Counter-terrorism international sanctions, Myanmar, Somalia, Russia, Libya, ISIL and Al-qaeda. The updates are to reflect changes to the licensing responsibilities within the U.K. Department of Business and Trade’s (DBT) licensing teams, and to clarify which DBT teams now lead on trade sanctions licensing.
Following the issuance of FAQ 1249 on April 28, OFAC issued an Iran-related alert on Sanctions Risks of Iranian Demands for Strait of Hormuz Passage. (Here) OFAC also issued FAQ 1250 to clarify that all Iranian financial institutions including digital asset exchanges are blocked pursuant to E.O. 13599 regardless of whether it is listed on the SDN list.
The U.S. government imposed blocking sanctions against six individuals, 21 entities, and a vessel under its Iran program for facilitating Iran oil trade. (Here, the Department of the Treasury's press release, the Department of State's press release, and the Department of State's fact sheet) Concurrently, OFAC issued Iran-related General License W authorizing the wind down of transactions involving Qingdao Haiye Oil Terminal Co., Ltd., or any entity in which it owns, directly or indirectly, a 50 percent or greater interest till May 31, 2026. Qingdao, among other entries, was blocked on May 1, 2026. (Here)
To finish off the week, the U.S. President signed a new Executive Order, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy." (Here) Among other things, the new Executive Order:
Provided nine new designation grounds, notably any foreign person that operates in or have operated in energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy.
Provided authority to the Secretary of the Treasury to impose on a foreign financial institution correspondent banking ban or blocking sanctions upon determining that the foreign financial institution has conducted or facilitated any significant transaction or transactions for or on behalf of any person whose property or interests in property are blocked pursuant to this order. (This as a classic "secondary sanctions" against FIs that was not previously a feature in the Cuba sanctions program of the United States.)
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