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Last Week's Major Developments in Sanctions - January 12, 2026, to January 16, 2026

  • Writer: Amir Fadavi
    Amir Fadavi
  • a few seconds ago
  • 3 min read
You can now listen to the audio version of our weekly sanctions updates here.

Monday, January 12

  • The Multilateral Sanctions Monitoring Team, a mechanism established to monitor and report violations and evasions of United Nations sanctions on North Korea launched in 2024 after Russia vetoed the renewal of the UN 1718 Committee Panel of Experts mandate, presented its report on the Democratic People's Republic of Korea's violation and evasion of UN sanctions through cyber and information technology worker activities. (Here) The United State's Department of State issued a fact sheet about the recent report. (Here)

  • The EU Council extended its Guatemala sanctions program until January 13, 2027. (Here)


Tuesday, January 13

  • OFAC and State Department imposed blocking sanctions against Lebanese, Jordanian, and Egyptian chapters of the Muslim Brotherhood, as well as the Secretary General of the Lebanese Muslim Brotherhood under the United States' counter-terrorism sanctions program. (Here, the Department of the Treasury's press release, the Department of State's press release, and the Department of State's fact sheet)

  • BIS issued a final rule (effective upon Federal Register publication) changing its license review policy for exports of certain advanced computing semiconductors to China and Macau from a presumption of denial to case-by-case review, if stringent conditions are met. BIS will now consider license applications for Nvidia H200, AMD MI325X, and “similar chips” on a case-by-case basis (rather than generally denying them). (Here)


Wednesday, January 14

  • Yet again OFAC extended the authorization for certain transactions related to the negotiation for the sale of Lukoil International GmbH and related maintenance activities by issuing General License 131B under its Russian Harmful Foreign Activities Sanctions Regulations. (Here) Note that this General License does not allow the sale of the assets. Any sale transaction remains subject to individual Treasury approval. Following the prior disqualification of Gunvor and Xtellus Partners, the U.S. Treasury continues to rigorously vet bidder credentials, funding sources, and potential sanctions evasion risks.


Thursday, January 15

  • OFSI and the EU Commission decided to lower the crude Oil Price Cap from $47.60 to $44.10 per barrel starting January 31, 2026. (The UK's updated guidance, and the EU Commission's Implementing Regulations) The United States has not joined the decision to lower the price cap.

  • OFAC imposed blocking sanctions against 11 individuals and 13 entities for being involved in cracking on protests in Iran or moving funds for the Islamic Republic of Iran. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • A citizen of India was sentenced to 30 months in federal prison and 36 months of supervised release for conspiring with others to export controlled aviation components and a navigation and flight control system to end users in Russia, in violation of the Export Control Reform Act. (Here)

     

Friday, January 16

  • The EU Council renewed its sanctions regime against those who support, facilitate or enable violent actions by Hamas and the Palestinian Islamic Jihad until 20 January 2027. (Decision, and press release)

  • OFAC imposed blocking sanctions against 11 individuals, ten entities, and a vessel under its counter-terrorism sanctions program for transferring oil products, procuring weapons and dual-use equipment, and providing financial services for Iran-backed terrorist organization Ansarallah. (Here, the Department of the Treasury's press release, and the Department of State's press release)


Recommendations of the Week

  • Head to SanctionsExpert.com and try the beta version of Sanctions Connoisseur, our new sanctions AI assistant. (I would love to hear your feedback. Share your thoughts with me at info@sanctionsexpert.com)

  • Last week BIS imposed a civil penalty of USD 1.5 million on Exyte Management GmbH to resolve 13 alleged EAR violations arising from unlicensed in‑country transfers of EAR99 items in China to Entity List customer SMIC Beijing between March 2021 and March 2022. Check out this client alert from Arnold & Porter to find out more.

  • If you have seen anything noteworthy that want me to share with the community, please email it to info@sanctionsexpert.com

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