Last Week's Major Developments in Sanctions - February 16, 2026, to February 20, 2026

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You can now listen to the audio version of our weekly sanctions updates here.

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Monday, February 16

• The UK's government is seeking input regarding the ownership and control test under the UK's sanctions regulations across implementation, cost of compliance and how control appears in practice. (Here) This is a great opportunity for everyone, especially compliance professionals to share their view about the challenges associated with determining ownership under the UK sanctions. As a reminder, unlike the United States where ownership matters, the UK sanctions requires UK persons to freeze assets of entities controlled by a designated person even if such entities are not listed on a sanctions list.

Tuesday, February 17

• The EU Council amended Decision 2011/101/CFSP concerning restrictive measures in view of the situation in Zimbabwe by changing the title to "Council Decision 2011/101/CFSP of 15 February 2011 concerning an arms embargo in view of the situation in Zimbabwe," and removing the ground for imposing travel restrictions, as well as asset-freezing obligations. The new decision is valid through February 20, 2027. (Here, and press release)

Wednesday, February 18

• DoJ announced the sentencing of a Bulgarian national to 38 months time served for conspiracy to violate the International Emergency Economic Powers Act. In August 2014, the defendant began working at Multi Technology Integration Group EOOD (MTIG), a Bulgarian company created to enable two Russian companies to acquire U.S.-origin radiation-hardened and high-temperature electronic circuits from a company based in Austin. Earlier in 2014, following Russia’s invasion of Crimea, the U.S. imposed export controls that made it illegal to export those goods directly to Russia without a license from the Department of Commerce, Bureau of Industry and Security. In January 2015, MTIG received a controlled item from a U.S. supplier in Austin. Approximately one month later, MTIG entered into a written contract to deliver the parts to a Russian engineering company. Over the next three months, the Russian company transferred more than $1 million split into three separate payments to MTIG. MTIG thereafter shipped the parts to Russia, in violation of the Export Administration Regulations and the International Emergency Economic Powers Act. (Here)

• OFAC issued two new Venezuela-related Frequently Asked Questions (FAQs 1236 and 1237) clarifying some of its recently issued General Licenses related to Venezuela.

• OFAC, also, issued General License 50A, replacing General License 50. The new General License includes Établissements Maurel & Prom SA as an entity that is authorized to engaged in the activities described in the license.

  
  

Thursday, February 19

• The EU Council designated the Islamic Revolutionary Guard Corps as a terrorist organization. (Here, and press release)

• A UK person was sentenced to 2 year and 1 month in prison for attempting to export military‑grade night vision rifle sights to Hong Kong without the required licence. (Here)

• OFAC imposed blocking sanctions against 5 individuals and 19 entities under OFAC's illicit drugs and counter-terrorism sanctions programs for being part of a a timeshare fraud network that stole money from American citizens for the benefit of the Cártel de Jalisco Nueva Generación. (Here, the Department of the Treasury's press release, and the Department of State's press release) Concurrently, OFAC issued General License 34 authorizing the wind down of transactions involving Kovay Gardens, an entity designated on this day. (Here)

• OFAC also imposed blocking sanctions against three commanders of Sudan's Rapid Support Forces for their role in RSF’s 18-month siege of and eventual capture of El-Fasher.  (Here, the Department of the Treasury's press release, and the Department of State's press release)

Friday, February 20

• There was no major development on this day.