Last Week's Major Developments in Sanctions - February 23, 2026, to February 27, 2026
- Mar 4
- 5 min read
You can now listen to the audio version of our weekly sanctions updates here.
Monday, February 23
On the anniversary of Russia's invasion of Ukraine, the EU's effort to introduce its 21st sanctions package against Russia fell short. However, the EU Council extended some of its sanctions against Russia that were set to expire on February 24, 2026, for another year until February 24, 2027. (Here) Furthermore, the EU Council imposed asset freezing sanctions against eight individuals responsible for serious human rights violations, the repression of civil society, and democratic opposition, and for undermining democracy and the rule of law in Russia. (Here, and press release)
OFSI amended General License INT/2024/4761108 was updated to:
Amend the definition of “Person”.
Include the definition of “Individual”, “Entity”, “UK Bank Account”, “Non-UK Bank Account” and “UK DP”.
Include a new separate permission that allows an Entity to make use of the retail banking services of a designated Credit or Financial Institution to make or receive a payment of for the personal use of an individual, provided the account at the final institution in the chain of payments to which the payment is processed is a UK Bank Account or a Non-UK Bank Account.
For the avoidance of doubt, the intended payments under this new permission remain exclusively for personal purposes and do not include payments for business or commercial activities. Possible examples of permitted payments include, but are not limited to, payments from or to entities for tuition fees, accommodation costs, pension, or living expenses.
No payment is permitted under this General License if the payment relates to the provision of goods or services for commercial purposes.
Increase the cumulative limit of permitted payments from £50,000 to £55,000.
Extend the expiry date of the license to 23:59 on February 23, 2028.
The reporting requirements have been amended.
Tuesday, February 24
Australia imposed asset freezing sanctions against four individuals and 115 Entities. Australia also imposed sanctions against 61 vessels directing them to (a) leave Australia, including by a particular route; or (b) not enter a particular port or place, or any port or place, in Australia. (Here)
In of its largest actions since the start of the war, OFSI imposed asset freezing sanctions against 7 individuals, and 240 entities. OFSI also listed 50 vessels under the Russia sanctions regime. (Here, and press release) OFSI issued new or amended General Licenses INT/2025/5635700 (to include any entity owned or controlled, directly or indirectly, by PJSC Transneft, following their designation by the UK), INT/2026/8893924 ( to wind down certain transactions involving Maritime Mutual Re-Insurance), and INT/2026/8889196 (to wind down certain transactions involving PJSC Transneft). (Here)
OFAC imposed blocking sanctions against four individuals and three entities for their role in acquisition and distribution of cyber tools harmful to U.S. national security. All individuals and entities that were targeted were designated under the United State's Cyber sanctions program. Furthermore, one individual and two entities were designated pursuant to Protecting American Intellectual Property Act of 2022 (PAIPA). PAIPA requires the U.S. President to imposes sanctions on certain foreign individuals and entities involved in the theft of trade secrets belonging to a U.S. individual or entity. For entities designated under PAIPA, the president shall choose five measures out of a menue of 12 sanctions measures provided under law. Of note is that while blocking sanctions were imposed on the two entities that were designated under PAIPA, the additional prohibitions goes beyond and restrict certain transactions involving those entities even such involvement is below 50%. (Here, the Department of the Treasury's press release, the Department of State's press release and fact sheet)
The UN Security Council added the names of four individuals to the list of its sanctions targets under the UN's sanctions regime related to Sudan. As a result, assets and economic interests of those individuals should be frozen by member states. (Here)
Wednesday, February 25
OFAC designated four individuals, 16 entities, and 12 vessels that were allegedly enabled illicit Iranian petroleum sales and Iran’s ballistic missile and advanced conventional weapons. (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFSI extended General License INT/2025/8031092, which authorizes the continuation of business operations with Lukoil International Entities, until to August 25, 2026. (Here) OFSI amended FAQ 174 accordingly.
OFAC published FAQ 1238 which discusses whether OFAC would authorize the resale of Venezuelan origin oil to Cuba. (Here)
OFAC announced that a natural U.S. person has agreed to pay $3,777,000 to settle their potential civil liability for 20 apparent violations of OFAC sanctions on Syria. The person in question, provided managerial services to Syria in their role as an officer and board member for four Syrian real estate companies in support of several luxury real estate projects. (Here) This is the tenth OFAC enforcement action against individuals in the past ten years.
BIS reached an administrative enforcement settlement with Vizicom ICT for exporting EAR-Controlled technology to the PRC without appropriate lincese. (Here)
Thursday, February 26
The EU Councils extended its Belarus sanctions regime for another year. That sanctions regime is now valid through 28 February 2027.
The EU Councils updated its counter-terrorism sanctions regime by introducing the possibility to impose travel ban against the leading members of designated terrorist groups and entities, and to designated persons associated with such groups. (Here, press release)
FinCEN proposed a rule that would sever MBaer Merchant Bank AG (MBaer’s) access to the U.S. financial system as a result of its financial support to illicit actors linked to Russia and Iran. If finalized, the proposed rule would prohibit covered U.S. financial institutions from opening or maintaining a correspondent account for, or on behalf of, MBaer. (Here)
OFAC imposed blocking sanctions against five individuals under the United State's Nicaragua sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFAC issued General License No. 131C to replace General License No. 131B. The new General License extended the expiration date of the authorized transactions from February 28 to April 1, 2026. (Here)
BIS issued a fine for $1 million against Teledyne FLIR for unlicensed China-related thermal camera exports and "de minimis" miscalculations. (Here)
Friday, February 27
The U.S. Secretary of State designated Iran as a State Sponsor of Wrongful Detention. This action is taken pursuant to Executive Order 14348, Protecting U.S. Nationals from Wrongful Detention Abroad,and Countering Wrongful Detention Act of 2025. This designateion paves the way for additional measures, including a potential geographic travel restriction on the use of U.S. passports to, through, or from Iran. (Here)
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