Last Week's Major Developments in Sanctions - August 31 to September 4, 2026

Monday, August 31

• There was no major development on this day.

  
  

Tuesday, September 1

• There was no major development on this day.

  
  

Wednesday, September 2

• OFAC issued a reminder to file the Annual Report of Blocked Property (ARBP) as of June 30, 2026 no later than September 30, 2026. OFAC notes that failure to file the ARBP by September 30 may lead to an enforcement referral. (Here)

• OFAC amended three Venezuela-related general licenses under 31 CFR Part 591, effective September 2, 2026, extending their scope from Venezuela's minerals sector to its "coal or minerals sectors" and adding Carbones del Zulia S.A. ("Carbozulia") alongside CVG Compania General de Mineria de Venezuela CA ("Minerven") as a named entity, while leaving all other conditions unchanged.

  • General License 55 was replaced by 55A (originally issued March 27, 2026), continuing to authorize the negotiation of and entry into contingent contracts for new investment in Venezuela's minerals sector.

  • General License 54B was replaced by 54C (originally issued August 27, 2026), continuing to authorize the supply of goods, technology, software, and services for minerals operations, subject to a requirement that dispute resolution occur in the United States, United Kingdom, France, or Singapore, that payments to blocked persons be made into the Foreign Government Deposit Funds, and that transactions be reported within ten days of the first transaction and every 90 days thereafter.

  • General License 51C was replaced by 51D (originally issued August 27, 2026), continuing to authorize established U.S. entities to export, sell, purchase, store, or transport Venezuelan-origin minerals, including gold, subject to the same dispute-resolution and payment conditions along with due diligence reporting on supply-chain every 30 days. (Here)

• FinCEN, together with the Federal Reserve, FDIC, NCUA, and OCC, issued a joint statement clarifying that SAR confidentiality requirements under the BSA do not bar banks and credit unions from communicating with customers about potentially fraudulent or suspicious activity (including check fraud) or account closures, so long as the communication does not reveal the existence of a SAR itself. The agencies confirmed that discussing the underlying facts, transactions, and documents on which a SAR is based such as transaction dates, amounts, parties, source-of-funds inquiries, fraud-typology warnings, or notice of account restrictions/closures remains permissible even if a customer could reasonably infer a SAR was filed. (Here)

• FinCEN reissued its Geographic Targeting Order (GTO) for money services businesses along the southwest border, requiring MSBs to file Currency Transaction Reports for cash transactions between $1,000 and $10,000 in designated ZIP codes across Bernalillo, Doña Ana, and San Juan counties (New Mexico) and Cameron, El Paso, Hidalgo, Maverick, and Webb counties (Texas), aimed at combating money laundering by Mexico-based cartels and other criminal actors. The order is effective for 180 days from September 3, 2026, and FinCEN separately issued associated FAQs on September 2, 2026. (Here)

• DOJ announced the sentencing of an Armenian national to 26 months in federal prison for conspiring to export U.S.-origin goods including items usable in semiconductor manufacturing to Russia via Armenia without the required BIS licenses under the Export Administration Regulations, in violation of sanctions and export restrictions imposed after Russia's 2022 invasion of Ukraine. The defendant acted as a straw purchaser for a Russian co-conspirator company that was later added to OFAC's SDN List in February 2023, and instructed the co-conspirator on opening an Armenian bank account for sanctions-evasion purposes while misrepresenting end-user information to U.S. suppliers. The individual was extradited from Germany in August 2025 and pleaded guilty in April 2026. The case was investigated by the FBI San Antonio Counterintelligence Task Force with BIS and DOJ's Office of International Affairs, which secured the extradition. (Here)

• OFSI imposed a £4,732,830.58 monetary penalty on Citibank, N.A., London Branch (CBNA London) for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019 and the Global Anti-Corruption Sanctions Regulations 2021. The case involved 970 transactions worth approximately £19.7 million processed between 2022 and 2025. OFSI announced that the majority of the breaches occurred between February and November 2022 following Russia's invasion of Ukraine and arose across the bank's operations, including payment processing, correspondent banking and account restrictions. CBNA London voluntarily disclosed the majority of the breaches, co-operated with OFSI's investigation and undertook remediation. OFSI applied a 20% voluntary disclosure and co-operation discount and a 20% settlement discount, resulting in the final penalty of £4,732,830.58. (Here)

  
  

Thursday, September 3

• The U.S. Department of State imposed blocking sanctions on one individual (in Cuba) and five entities (in Cuba) under its Cuba sanctions program (E.O. 14404) targeting repression by the Castro regime, exploitation of Cuba's financial, energy, and metals/mining sectors, and support to state-owned oil and nickel enterprises. The designations target the grandson of Raúl Castro, designated as an adult family member of previously-designated Alejandro Castro Espín, Banco Exterior de Cuba (a state-owned bank for corporate/foreign-trade finance), Comercial CUPET S.A. and Empresa Importadora de Abastecimiento para el Petróleo/ABAPET (both linked to state oil monopoly CUPET), and Nicarotec and CEXNI (nickel/mining-sector support and import enterprises). OFAC concurrently issued Cuba General License 4A authorizing transactions for third-country diplomatic and consular missions in Cuba. (Here)

• FinCEN published a Financial Trend Analysis and Alert (FIN-2026-Alert005) flagging nearly $13 billion in suspected digital asset investment scam activity analyzing 33,904 BSA reports filed between September 2023 and December 2025 totaling approximately $12.7 billion, with MSBs (55%) and depository institutions (41%) accounting for the vast majority of filings. The alert attributes these "pig butchering"/romance-baiting schemes primarily to Southeast Asia-based transnational criminal organizations operating industrial-scale, often forced-labor scam compounds in Cambodia, Burma, and Laos, which rely on Telegram-based "guarantee marketplaces" and Chinese money laundering networks to move proceeds through stablecoin and shell-company infrastructure before integration into the formal financial system. FinCEN is requesting that related SARs reference the key term "FIN-2026-SCAMCENTERS" and has laid out 16 red-flag indicators spanning victim payments, guarantee-marketplace exposure, and on-chain laundering techniques, while reiterating support for Section 314(b) information sharing and its Rapid Response Program for cross-border fund recovery. (Here)

Friday, September 4

• OFAC imposed blocking sanctions on three entities (in Turkey) under its Iran sanctions program (E.O. 13902), as part of Operation Economic Outcast, targeting Iran's financial sector and providing correspondent banking access that enabled the Iranian government and the IRGC-Qods Force to move funds internationally. The designations target Golden Global Yatirim Bankasi Anonim Sirketi (Golden Global Bank) for knowingly facilitating significant financial-sector transactions for Iran and for enabling transfers tied to the Sıtkı Ayan network, along with its two subsidiaries, Golden Global Varlik Kiralama Anonim Sirketi and Golden Global Portfoy Yonetimi Anonim Sirketi. OFAC concurrently issued Iran General License CC, authorizing wind-down of transactions involving persons blocked in this action. (Here)