Last Week's Major Developments in Sanctions - August 24 to August 28, 2026

Monday, August 24

• The European Commission updated its Russia sanctions FAQs across three areas: the Infrastructure Transaction Ban (Article 5ae, Reg. 833/2014), the Oil Price Cap (Article 3n, Reg. 833/2014), and the LNG Import Ban (Article 3ra, Reg. 833/2014) all reflecting changes introduced by Regulation (EU) 2026/1848 of 23 July 2026. (Here)

• The U.S. Departments of State and Treasury jointly launched "Operation Economic Outcast," an unprecedented whole-of-government sanctions campaign against Iran. The State Department imposed blocking sanctions on 13 individuals (eight in Iran, three in India, one in Türkiye, and one in Singapore) and 13 entities (three in Iran, four in India, four in Türkiye, and two in Hong Kong) under E.O.s 13846 and 13949 for military procurement and petroleum/petrochemical trading activity. The State Department also imposed blocking sanctions on one vessel flagged in Barbados. The sanctions target seven senior IRGC, Artesh, and MODAFL officials held responsible for directing conventional weapons, missile, and UAV strikes against U.S. forces and partners during Operation Epic Fury, alongside two Iran-based entities that supplied targeting imagery and battle-damage intelligence. The remaining sanctions target form a petroleum/petrochemical trading network of Indian, Turkish, Hong Kong, and Iranian companies and principals who imported or brokered Iranian-origin crude and petrochemical products, including a customs broker and a Hong Kong-based tanker manager.

  Alongside the State Department, OFAC imposed blocking sanctions on 37 entities (15 in Hong Kong, seven in UAE, five in China, three in Singapore, two in Iran, one in Malaysia, one in Switzerland, one in France, one in the Marshall Islands, and one in the UK), and 15 individuals (six in Iran, four in China, two in Greece, two in UAE, one in Singapore) plus five vessels (two flagged in Gambia, one flagged in Botswana, one flagged in Cameroon, one flagged in Vanuatu) under its Counter-proliferation, Cyber and Counterterrorism sanctions programs (E.O.s 13382, 13694 as amended, 13902, and 13224) for conduct spanning three networks: a Hong Kong/China front-company system procuring dual-use nuclear- and missile-relevant technology for MODAFL's Malek Ashtar University; an Iranian Ministry of Intelligence and Security-directed cyber group blamed for compromising U.S. critical infrastructure (coordinated with an FBI indictment unsealed August 18); and UAE, Singapore, and Hong Kong-based shipping brokers, bunkering firms, and vessel owners moving Iranian crude oil and LPG to East Asian markets. The Department of the Treasury paired the designations with a sectoral determination under E.O. 13902, extending sanctions exposure to any person operating in Iran's aviation, digital asset, gold, shipping, or technology sectors, and an updated OFAC alert warning that paying "tolls" to the Iran-linked Persian Gulf Strait Authority, Persian Gulf Marine Insurance Company, or HormuzSafe for Strait of Hormuz passage carries sanctions risk regardless of payment form. In a related but separate action, OFAC indefinitely suspended five general licenses under the Iranian Transactions and Sanctions Regulations, replacing them with General License BB, a wind-down-only authorization through September 8, 2026, while separately issuing General License AA to authorize wind-down transactions involving La Nivernaise de Raffinage SAS through October 23, 2026. (Here)

• In a major development, the U.S. State Department rescinded Syria's designation as a State Sponsor of Terrorism (SST), a status Syria had held since 1979. Accordingly, Syria is no longer subject to prohibitions under the Terrorism List Governments Sanctions Regulations, 31 CFR part 596 (TLGSR), or 22 USC 7205(a)(1). Concurrently, the State Department revoked Hay'at Tahrir al-Sham's (HTS, formerly al-Nusrah Front) designation as a Specially Designated Global Terrorist (SDGT), and OFAC removed HTS from the SDN List. OFAC also updated FAQ 1220, FAQ 1221, and FAQ 1222, and removed FAQ 1223. Additionally, the U.S. Departments of Commerce, State and Treasury have issued an updated Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria. Alongside these reliefs, OFAC updated the SDN listings for two individuals who are designated for financial and logistical support to al-Qa'ida leadership and for organizing weapons training and assassination cells in Syria. (Here)

  
  

Tuesday, August 25

• BIS settled an enforcement action against Container Manufacturing Ltd. (CML), an Ohio-based aluminum can-end tooling manufacturer, resolving ten violations of the Export Administration Regulations arising from unlicensed exports of EAR99 spare parts (HTS codes 8466.94, 8462.29, and 4016.93, valued at $264,721) to a Russian end user between March 2023 and March 2025, in violation of the license requirement under 15 C.F.R. § 746.8(a)(5) for items listed on Supplement No. 4 to Part 746 (Russian/Belarusian Industry Sector Sanctions List). Under the settlement, CML admitted the conduct and agreed to pay a $1,000,000 civil penalty within 30 days, with continued export privileges conditioned on timely payment, in light of CML's full cooperation and remedial measures including enhanced screening, transaction-review, and training controls. (Here)

  
  

Wednesday, August 26

• The U.S. Department of State, in partnership with the Department of the Treasury announced the designation of Autistici/Inventati as a Specially Designated Global Terrorist pursuant to Executive Order 13224. The press release states that Autistici/Inventati (the A/I Collective) is an Italy-based extremist group that builds and operates the digital infrastructure for violent Antifa cells and other far-left militants across the world. A/I’s cadre of radical hackers and tech developers provide a full spectrum of services to Marxist, anarchist, and other left-wing extremist groups in the United States, Europe, and elsewhere. (Here) In my humble opinion, this designation will be challenged on the basis of the IEEPA exemption for information materials.

• OFAC imposed blocking sanctions on two individuals (both in Palestine) and three entities (one each in UK, Brazil and Italy) under its counter terrorism sanctions program targeting infrastructure and front-organization support for violent far-left extremism. OFAC concurrently issued General License 36, authorizing wind-down transactions involving Autistici Inventati (and majority-owned entities) through September 25, 2026, with payments to blocked persons required to route through blocked accounts. (Here)

• OFAC issued General License 104B, extending through September 1, 2027 the authorization for U.S. persons to import certain non-Russian-origin diamonds that had been prohibited under the February 8, 2024 determination pursuant to E.O. 14068, superseding General License 104A which was due to expire September 1, 2026. (Here)

  
  

Thursday, August 27

• OFAC issued amendments to eight Venezuela-related General Licenses under 31 CFR part 591. The key change across all of them is the removal of the requirement that contracts with the Government of Venezuela, PdVSA, Minerven, or CONATEL/CANTV be construed and interpreted in accordance with U.S. state law, leaving only the requirement that dispute resolution proceedings occur in the United States, United Kingdom, France, or Singapore. All other conditions, exclusions, and reporting obligations under each license are unchanged. The licenses are:

  • General License 46D, authorizing established U.S. entities to import Venezuelan-origin oil and petrochemical products, superseding General License 46C.

  • General License 47B, authorizing the export and sale of U.S.-origin diluents to Venezuela, superseding General License 47A.

  • General License 48C, authorizing the supply of U.S. goods, technology, software, or services for Venezuelan oil, gas, and electricity sector operations, superseding General License 48B.

  • General License 50C, authorizing oil and gas sector operations in Venezuela of BP, Chevron, Eni, Établissements Maurel & Prom, Repsol, and Shell, superseding General License 50B.

  • General License 51C, authorizing established U.S. entities to trade Venezuelan-origin minerals, including gold, via Minerven, superseding General License 51B.

  • General License 52B, authorizing established U.S. entity transactions with PdVSA under E.O. 13884 and E.O. 13850, along with related Government of Venezuela activity, superseding General License 52A.

  • General License 54B, authorizing the supply of U.S. goods, technology, software, or services for Venezuelan minerals and gold operations, superseding General License 54A.

  • General License 61A, authorizing the supply of U.S. goods, technology, software, or services for Venezuelan telecommunications installation, maintenance, and support, superseding General License 61.

  Additionally, OFAC issued two new Venezuela-related Frequently Asked Questions (FAQs 1267 and 1268), amended two Venezuela-related Frequently Asked Questions (FAQs 1233 and 1244), and archived FAQ 1260. (Here)

• The U.K. OTSI issued its Annual Review 2025-2026 covering the office's inaugural full year of civil enforcement, licensing, and compliance measures. Highlights:

  • Enforcement: 178 suspected breach reports received (mostly Russia-related), 104 cases closed, no civil monetary penalties issued yet, several investigations at an advanced stage.

  • Licensing: 51 applications processed (mostly Russia-regime services), 17 granted, average 96 working days to close.

  • New powers: Sanctions End-Use Controls launched April 2026 to catch risk or third-country diversion; licensing remit expanded to cover goods (not just services) from 27 April 2026.

  • Engagement: 60+ stakeholder engagements, 169 queries handled, updated guidance on Russian evasion/circumvention.

  • Forward-looking: supported the latest Russia sanctions package (LNG, oil imports, shadow fleet) and flagged digital/CMS development as a 2026-27 priority. (Here)

• The U.K. ECJU published its quarterly licensing commentary on August 27, 2026, covering the period January–March 2026. Some brief highlights include: 1. ECJU made 2,705 licensing decisions on standard individual export licences (SIELs) in Q1, an 11% increase from the prior quarter, with 96% issued and 4% refused; 2. the refusal rate remained above the long-run average, continuing a trend since Q3 2022 partly attributed to enhanced military end-use controls covering China since May 2022. 3. The total value of SIELs issued rose to £3.53 billion, up from £3.04 billion in Q4 2025, though ECJU cautions that self-declared licence values can overstate actual export activity. (Here)

Friday, August 28

• OFAC imposed blocking sanctions on one individual (in UAE) and one entity (in Hong Kong) under its Iran and Counterterrorism sanctions programs for facilitating Iranian sanctions evasion and shadow banking. The designations target the general manager of Bank Melli's Dubai branch for acting on behalf of Bank Melli which has moved billions through IRGC-Qods Force-controlled accounts, and Kameng Trading Limited pursuant to E.O. 13902 for operating in Iran's financial sector by helping sanctioned exchange house Pedram Pirouzan (Opal Exchange) launder funds.

• Delivering on the Economic Outcast campaign, FinCEN issued a notice of proposed rulemaking under Section 311 of the USA PATRIOT Act to cut Banque Misr UAE off from U.S. correspondent banking after finding that the bank processed roughly $1.8 billion for 103 companies tied to Iranian shadow banking networks, including apparent fronts for Iran's Ministry of Defense and the IRGC. (Here)

• A federal jury in the Southern District of Florida convicted a Russian national residing in South Florida and former Aeroflot employee, on all 12 counts related to a scheme to illegally export nearly $1 million in U.S. aircraft parts to Russia and state-owned carrier PJSC Aeroflot, following the U.S. Department of Commerce's post-2022 export restrictions on Russia and a temporary denial order barring Aeroflot from receiving U.S.-origin goods; charges included conspiracy to violate the Export Control Reform Act, illegal export of ECRA-controlled items, conspiracy to commit smuggling and smuggling of goods, submission of false or misleading export information, and conspiracy to commit money laundering, with Mamonov and co-conspirator Ignat Vakorin (a Russian national who remains a fugitive) accused of misleading U.S. suppliers by falsely declaring the UAE and China as end destinations. Sentencing before U.S. District Judge Kathleen M. Williams is scheduled for November 20. (Here)