Last Week's Major Developments in Sanctions - July 20 to July 24, 2026

Monday, July 20

• The EU Council adopted Council Decision (CFSP) 2026/1767 amending Decision (CFSP) 2021/1277 concerning restrictive measures in view of the situation in Lebanon. The amendment extends for another year through 31 July 2027, following a Council review that determined the existing restrictive measures should be renewed. There is no other substantive change. (Here)

Tuesday, July 21

• FinCEN Director Andrea Gacki testified before the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions on July 21, 2026, outlining FinCEN's fraud enforcement and BSA modernization priorities. On fraud, Gacki highlighted the Rapid Response Program's interdiction of nearly $2 billion in stolen proceeds for 5,790 victims since 2015, FinCEN's October 2025 severance of the Huione Group (linked to at least $4 billion in laundered proceeds) from the U.S. financial system followed by June 2026 action against successor entities, and ongoing work under the White House Task Force to Eliminate Fraud targeting healthcare and benefit-program fraud by organized crime and transnational criminal organizations. On regulatory modernization, Gacki cited October 2025 SAR FAQs aimed at focusing filings on high-value information, an April 2026 proposed rule overhauling AML/CFT program requirements to emphasize effectiveness over technical compliance (including an expanded FinCEN supervisory role), and two proposed rules implementing AML and customer identification requirements for permitted payment stablecoin issuers under the GENIUS Act. Gackli also noted FinCEN's whistleblower program remains in a triage phase pending finalization of the April 2026 proposed rule governing award eligibility and confidentiality. (Here)

• OFSI published FAQs 197-202 on Basic Needs Allowance (BNA) licences, which permit designated persons to access a capped monthly sum from frozen funds for essential living expenses. FAQs 197-202 cover the purpose and scope of BNA licences, permitted expenditure, reporting requirements, treatment of monthly underspend, and how costs falling outside the BNA may be licensed separately. (Here)

Wednesday, July 22

• FinCEN extended the comment period for its June 25, 2026 NPRM proposing to amend the definition of Huione Group to include H-Pay Service PLC and add a "successor entity" definition, following a six-day portal outage (June 25–30) that prevented electronic comment submission. Comments are now due by August 2, 2026, submitted via regulations.gov or mail to FinCEN (P.O. Box 39, Vienna, VA 22183; Docket No. FINCEN-2026-0166). (Here)

Thursday, July 23

• The EU Council adopted Council Decision (CFSP) 2026/1847 concerning restrictive measures in view of the situation in Belarus and Belarus's involvement in Russia's aggression against Ukraine. The decision expands the list of items that could contribute to Belarus's military and technological enhancement and introduces further import restrictions on goods that allow Belarus to diversify revenue sources, including copper, nickel, lead, and precious-metals ores, unwrought zinc, certain inorganic chemicals, tall oil, glassware, and car parts. It also extends the existing prohibition on Belarusian nationals owning, controlling, or holding governing-body posts at EU-incorporated entities to cover all crypto-asset service providers (not just wallet/custody services) as of 25 August 2026, while amending derogations to ensure continued provision of goods and services needed to uphold civilian internet infrastructure in Belarus. (Here)

• OFAC issued three Cuba General Licenses. General License 2 authorizes the wind-down of transactions involving CEIBA Investments Limited (or entities in which it holds a 50%+ interest) through August 22, 2026, provided payments to blocked persons are routed into a blocked, interest-bearing U.S. account. General License 3, covering the same wind-down window, authorizes divestment of CEIBA-issued debt or equity to non-U.S. persons, settlement of pre-existing trades in that debt/equity, and unwinding of related derivative contracts, while excluding new U.S. purchases or sales to other blocked persons. General License 4 authorizes transactions ordinarily incident to the official business of third-country diplomatic and consular missions in Cuba, including personal-expenditure processing for mission staff and their families, but excludes transfers to blocked persons beyond taxes, fees, and permit-related payments, and does not unblock any previously blocked property. (Here)

• The State Department imposed blocking sanctions on nine entities and two individuals under Executive Order 14404, targeting three tracks: Cuba's energy sector (a state oil R&D arm and two fuel importers), a GAESA sanctions-evasion scheme in which the regime restructured ownership of the Port of Mariel's container terminal through shell entities to shield it from U.S. sanctions, and Cuba's forced-labor overseas medical missions program reaching the Cuban Health Minister and the state bodies that export and staff the missions. (Here)

• OFAC imposed blocking sanctions on 4 individuals (one Palestinian national and two Iraqi nationals based in Türkiye, and one Austrian national based in the United Kingdom) and 3 entities (one each in Turkey, Gaza, and Indonesia) under its counter-terrorism sanctions program (E.O. 13224, as amended) for providing financial and material support to Hamas and its parent organization, the Egyptian Muslim Brotherhood (EMB). The designations target EMB Secretary General for his fundraising support to Hamas-linked institutions; two sham charities created by Hamas to divert donor funds to its military wing; and Turkey-based underground money exchange El-Kahira for General Trading, along with its owner and two shareholders, which moved hundreds of thousands of dollars for Hamas and provided banking services to organized crime networks including Sweden's Foxtrot Network. (Here)

• OFAC imposed blocking sanctions on 39 individuals (38 Mexican nationals and one dual Mexican-U.S. national) and 16 entities (all in Mexico) under its counter-narcotics and counter-terrorism sanctions programs (E.O. 14059 and E.O. 13224, as amended) for their roles in the leadership, family-based asset-shielding networks, fentanyl and cocaine trafficking, fuel theft, and professional money-laundering operations of the terrorist group Cartel de Jalisco Nueva Generación (CJNG). The designations target new CJNG leader Juan Carlos Gonzalez ("Pelon"), who assumed control following the February 2026 death of his stepfather and CJNG founder Rubén Oseguera Cervantes ("El Mencho"); the family-based networks of senior members Audias Flores Silva ("Jardinero") and Gerardo Botello Rozalez ("El Cachas"); a Zapopan/Guadalajara-based professional bulk-cash money-laundering cell; and a fentanyl-diversion and fuel-theft ring. Treasury described this as the largest action it has ever taken against CJNG, bringing its total CJNG-linked designations since 2015 to over 250. (Here)

• The EU Council adopted the 21st sanctions package against Russia through two CFSP instruments. Through Council Decision (CFSP) 2026/1845, the EU Council imposed asset freezing sanctions on 48 individuals and 168 entities targeting the military-industrial supply chain behind Russian UAV production, senior Central Bank officials tied to integrating occupied Ukrainian territory, and cultural and sporting figures who have publicly supported the war. Most of the 168 entities are banks, designated as a source of revenue for the Russian state, with the remainder spanning gold and precious-metals miners, oil and gas producers, defense manufacturers, shipping companies, and IT/hosting infrastructure used for propaganda. Council Decision (CFSP) 2026/1849 added 51 entities to the export-control list for supporting Russia's military-industrial complex, and expanded controlled goods to include specialty metal powders, aerospace films and tapes, and UAV/missile components, alongside new import restrictions on Russian metals and chemicals. It added 33 credit or financial institutions and 14 crypto-asset providers to transaction-ban lists, and introduced a new mechanism to ban crypto transactions with providers based in third countries that fail to prevent sanctions circumvention. On energy, it paused the automatic oil price-cap adjustment until 15 July 2027, banned transactions with refineries processing Russian crude, added 41 vessels to the shadow-fleet list, and created a temporary, capped exemption for LNG transfers to third countries under existing long-term contracts. (Here)

Friday, July 24

• OFSI has published new guidance on how to verify whether communications claiming to be from OFSI are genuine. The guidance provides information to help individuals verify communications claiming to be from OFSI, including signs that a communication may not be genuine. (Here)

• The UN Security Council Libya Sanctions Committee adds the vessel AVAX (IMO 9058713) to its Sanctions list for attempting to illicitly export petroleum from Libya under Resolution 2146 (2014), as amended and extended. The designation imposes measures prohibiting the vessel from loading, transporting or discharging Libyan petroleum, entering ports, receiving bunkering or vessel services, and engaging in financial transactions related to Libyan petroleum. (Here)

• Following the UN designation, the UK updated the UK Sanctions list to add vessel AVAX under the Libya (Sanctions) (EU Exit) Regulations 2020. The measures prohibit the vessel from accessing UK ports and maritime services and reinforce compliance obligations for financial institutions and maritime stakeholders. (Here)

• FinCEN issued Alert FIN-2026-Alert004 in consultation with U.S. Department of Education’s (ED) Office of Inspector General (ED-OIG) and the Federal Bureau of Investigation (FBI), urging financial institutions to detect, prevent, and report suspicious activity connected to fraud schemes targeting the Department of Education's Federal Student Aid (FSA) programs. FSA disburses more than $120 billion annually to roughly 13 million students, and fraud rings exploit the process using stolen or synthetic identities to create "ghost students" (impersonated identity theft victims, sometimes with AI-generated coursework or paid accomplices) and "straw students" (complicit individuals who provide their PII for a fee), including cases with insider assistance from corrupt school staff. Proceeds are frequently laundered through money mules, shell companies, and fraudulent accounts, with criminal brokers increasingly using a "one-to-one" model to open multiple accounts and layer funds through digital assets before conversion to foreign currency. Key takeaways for financial institutions: 1. Red flags (9 identified): refunds to accounts with no enrollment history or connection to the named recipient; rapid transfers via P2P/wire to purchase digital assets or move funds internationally; multiple unrelated students' refunds landing in one account; newly opened accounts funded solely by student aid refunds; multiple accounts accessed from the same out-of-state/international IP or device; and multiple accounts opened in a short window each receiving a single refund ("one-to-one" pattern). 2. SAR filing instructions: reference key term "FIN-2026-FSAFRAUD" in SAR field 2 and the narrative; check SAR field 34(z) (Fraud – Other) and include "Federal Student Aid Fraud" in the text box; also complete fields 36 (Money Laundering) and 38 (Other Suspicious Activities) where applicable. 3. Broader reminders: standard BSA obligations apply (CTR, Form 8300, FBAR, CMIR, RMSB, DOEP), along with due diligence requirements under Section 312 and correspondent account/PEP screening; institutions are encouraged to use Section 314(b) safe harbor to share information on suspected fraud rings across institutions, including cross-border. (Here)

• OFAC adopted a final rule, effective upon publication in the Federal Register on July 27, 2026, updating website and contact information across nearly 40 parts of 31 CFR chapter V and Appendix A, replacing outdated URLs (e.g., www.treasury.gov/ofac) with the current https://ofac.treasury.gov domain. Substantively, the rule amends Part 546 (Sudan Stabilization Sanctions Regulations) to convert the legal services general license's reporting requirement into a ten-year recordkeeping requirement, corrects an erroneous cross-reference in Part 526 (removing "part 501 of" from a citation to Appendix A), and fixes typographical errors in Parts 553 and 598. Additionally, OFAC is amending one CFR part to update general licenses authorizing payments for legal services from funds originating outside the United States to replace the reporting requirement in the general license with a recordkeeping requirement and correcting typographical errors in two CFR parts. OFAC is also updating a part of 31 CFR chapter V to correct an erroneous cross-reference. (Here)

• OFAC updated Venezuela-related FAQ 1239 pertaining to account information to make authorized payments to the Foreign Government Deposit Funds deposit account. (Here)

• OFAC issued Russia-related General License 131H replacing and superseding General License 131G (dated June 25, 2026) in its entirety. The license continues to authorize transactions ordinarily incident and necessary to negotiating and entering into contingent contracts for the sale of Lukoil International GmbH ("LIG") and its majority-owned entities, as well as transactions necessary to the maintenance or wind-down of LIG Entities' operations, subject to the same restrictions on unblocking property, RuHSR-prohibited transactions, and fund transfers to Russia. The key-change is that 131H extends the authorization deadline from July 25, 2026 (under 131G) to August 22, 2026: a 28-day extension, with no other substantive changes to the license's terms. Additionally, OFAC updated associated FAQs 1224 and 1225. (Here)

• OFAC imposed blocking sanctions on four individuals (two in Iran, one in Tajikistan, and one in Netherlands) and nine entities (six in Iran, two in UAE, and one in Turkey) under its Iran sanctions program for supporting Babak Zanjani's broader Iranian sanctions evasion network, which spans financial services, gold and precious gem production, digital asset trading, and transportation infrastructure used to obscure ownership and launder revenue through Iran and offshore. The action targets Zanjani's Iran-based "Dot One" conglomerate alongside supporting entities for his UK-registered digital asset exchanges Zedcex and Zedxion, including Istanbul-based Zedpay (and its chairperson, Mehdi Rezazadeh, an Iranian national), Dubai-based Zedx DMCC, and Dubai-based BZ Diamond DMCC; Zanjani's significant other, was designated for registering websites for his companies. (Here)

• The EU Council adopted Council Implementing Decision (CFSP) 2026/1850 implementing Decision 2011/235/CFSP imposing asset freezing sanctions on six individuals under the the EU's Iran human rights sanctions list. Five of the six are judges of Iranian Revolutionary and criminal courts designated for presiding over trials of political dissidents, religious minorities, and women's rights activists (including Nobel laureate Narges Mohammadi) marked by serious due-process violations, on charges including those tied to the 2022 "Woman, Life, Freedom" protests, and for imposing death sentences, long prison terms, and flogging. The sixth individual is designated as founder and deputy leader of the "Ashiyane" cyber group, which cooperates with the EU-listed Cyber Police (FATA) and the IRGC in cyberattacks supporting the regime's crackdown on opposition figures. (Here)