Last Week's Major Developments in Sanctions - August 3 to August 7, 2026

Monday, August 3

• The U.K.'s OTSI and Department for Business & Trade published guidance clarifying banknote export prohibitions under the Belarus and Russia (Sanctions) (EU Exit) Regulations 2019, confirming that exporting, supplying, or making available banknotes (including GBP, EUR, and six other currencies) to persons connected with Belarus or Russia, or for use there, remains prohibited, including transport by post or on one's person. A personal use exception permits up to £10,000 per journey for a traveler's essential needs (accommodation, food, medical care, transport), but does not apply above that threshold, for commercial purposes, or for provisioning family or friends resident in either country; regulated entities remain subject to existing due diligence and mandatory reporting standards. (Here)

• FinCEN assessed a $125 million civil money penalty against UBS Financial Services Inc. (UBSFS) for willful violations of the Bank Secrecy Act. This is the largest penalty ever imposed on a broker-dealer for BSA violations. This is FinCEN's second enforcement action against UBSFS, following a 2018 Consent Order ($14.5 million penalty) for failing to monitor foreign currency wires. Despite assurances it would remediate, UBSFS continued to fail to monitor over 50,000 foreign currency wires worth more than $10 billion, and did not disclose these failures until FinCEN's own investigation uncovered them. FinCEN also found UBSFS failed to perform adequate customer due diligence on high-risk clients tied to Russia and Latin America resulting in hundreds of unreported suspicious transactions. UBSFS admitted willfully violating the BSA and must complete a third-party lookback and independent AML program review, with up to $15 million in review costs waivable upon satisfactory remediation. The review will specifically assess UBSFS's handling of illicit finance risk tied to the Southwest border/narcotics trafficking, Iran, Russia, and Venezuela. (Here)

• OFAC issued Venezuela General License No. 5Y authorizing transactions related to the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5% Bond that would otherwise be prohibited under E.O. 13835 (as amended by E.O. 13857) and the Venezuela Sanctions Regulations (31 CFR Part 591). GL 5Y replaces and supersedes GL 5X (dated 18 June 2026) in its entirety, effective 3 August 2026. The only substantive change is the effective date threshold, pushed from August 4, 2026 (under GL 5X) to September 17, 2026 (under GL 5Y). (Here)

Tuesday, August 4

• There were no major developments on this day.

Wednesday, August 5

• OFAC removed Fly Baghdad from its SDN list. Fly Baghdad was designated under the U.S. counterterrorism sanctions program on January 22, 2024, due to alleged support of the operations of the IRGC-QF and its proxies by delivering materiel and personnel throughout the region. (Here)

Thursday, August 6

• OFSI published an amended Russian Oil Exempt Projects General Licence INT/2025/5635700. The General Licence was amended to include the Kurdistan Export Pipeline until 14 October 2027. (Here)

• The UK imposed asset freezing sanctions on one individual, 12 entities and six vessels under its Russia (Sanctions) (EU Exit) Regulations 2019. The designations target six Russian banks supporting the country's war economy, six shadow fleet tankers carrying Russian-origin oil and LNG to third countries, a UK-sanctioned shipping company that facilitated a tanker's transfer into Russian ownership, three companies making available goods or technology relevant to Ukraine's destabilization, an entity supporting the Russian energy sector, and one individual sanctioned for ownership of a company in Russia's chemical sector. The package brings the UK's total Russia-regime designations to over 3,400 individuals, entities, and ships, with more than 500 added this year alone. (Here)

• OFAC issued FAQ 1264 pertaining to sanctions exposure for procurement of food and medical supplies to Cuba for a non-US person under EO 14404. (Here)

• The U.S. Department of State imposed blocking sanctions on 6 individuals (4 based in Cuba, 1 in Russia, 1 in China) and 5 entities (all based in Cuba) under its CUBA-EO14404 sanctions program for facilitating the Cuban regime's procurement of military equipment from abroad on behalf of the Ministry of the Revolutionary Armed Forces (MINFAR) and security forces. The designated entities are state-owned enterprises operating in machinery/equipment trade, defense, and vehicle maintenance sectors, targeted for their role as key nodes in Havana's arms-import and foreign military cooperation network, with the individuals abroad reflecting the regime's overseas procurement presence. (Here)

Friday, August 7

• The EU Council adopted Decision (CFSP) 2026/1939 imposing asset freezing sanctions on five individuals all senior executives of Russian defence and military-technology companies. All five are designated for materially supporting Russia's military-industrial complex through the development, production, or supply of military technology used in the war against Ukraine. The listings target directors of companies involved in producing precision electromechanical components for the Iskander-M ballistic missile, communication systems and navigation receivers used in "Orlan-10" and "Tachion" UAVs, drone software and hardware with government contracts, space/military radar systems supplied to the Russian Ministry of Defence (under Roscosmos), and the RS-28 "Sarmat" ballistic missile. (Here)

• FinCEN renewed its Geographic Targeting Order (GTO) targeting government benefits fraud in Minnesota, effective August 11, 2026 through February 6, 2027. The GTO requires banks and money transmitters in Hennepin and Ramsey Counties to report enhanced information on covered funds transfers of $3,000 or more sent to beneficiaries, recipients, or financial institutions located outside the United States. Treasury cited extensive schemes diverting state and federal benefits intended for people who are unhoused, food insecure, disabled, or otherwise eligible for government assistance, with a portion of proceeds laundered overseas, potentially costing Minnesota billions of dollars. (Here)

• OFAC imposed blocking sanctions on five individuals (four in Iran and one with presence in Iran and the UAE) and 13 entities (one in Iran, six in the UAE, three in Hong Kong/China, one in Singapore, one in Poland, and one in Georgia) under its Iran and counterterrorism sanctions programs for operating and facilitating digital asset exchanges and a multi-jurisdictional network of front companies that laundered funds for the IRGC and enabled Iranian sanctions evasion through cryptocurrency. The action targets unlicensed or lightly regulated crypto exchange platforms and their supporting corporate infrastructure, spanning trading companies, digital-currency exchanges, and an online gambling network, which are used to obscure fund origins and move illicit proceeds through the international financial system on behalf of the Iranian government. Additionally, OFAC issued an amended related FAQ 1257. (Here)

Recommendation of the Week

• We started to publish our weekly updates on Substack too. You can follow our Substack here: https://substack.com/@sanctionsexpert

• Our founder, Amir Fadvi, created a new AI Skill that can generate sanctions updates from reliable vetted sources in your AI platform of choie. You can find the skill in GitHub. All you need to do is to download it and add it to your AI platform (or simply ask your Claude, Chat GPT, Gemini, Grok, Perplexity, DeepSeek, or etc.).

• Read this piece from Sanctrust, our founder AI-native financial crime focused firm, about the New Russia sanctions bill that just passed the Senate. (The Russia Sanctions Bill: What You Need to Know)