Last Week's Major Developments in Sanctions - July 27 to July 31, 2026

Monday, July 27

• UK's ECJU published Notice to Exporters 2026/16 confirming that two UK exporters paid compound settlements of £216,530.30 and £20,889.15 in June 2026 for unlicensed exports of military-listed goods in breach of the Export Control Order 2008 and the Customs and Excise Management Act 1979. For context, compound settlements are offered by HMRC in lieu of prosecution where an exporter has voluntarily self-reported a breach and the violation was inadvertent or resulted from weak internal controls; HMRC does not normally offer settlements where the breach was intentional. (Here)

• OFAC took the second major action under Treasury's sanctions modernization initiative announced by Secretary Bessent in May, removing 84 individuals and entities from the SDN List and improving identifying information for 22 list entries. The action targets outdated entries no longer aligned with U.S. national security or foreign policy priorities, including deceased individuals, defunct entities, and decades-old designations lacking sufficient screening data, following interagency review to confirm removal would not harm foreign policy or national security interests.

  • Key takeaways from this action:

  • Removals: 84 individuals/entities delisted, focused on stale, low-value entries (deceased persons, defunct entities, 20+ year-old designations).

  • Data quality fixes: 22 entries updated with more robust identifiers (DOB, POB, ID numbers, nationality, gender) rather than removed, where retention was still warranted but screening was hampered by thin data.

  • Duplicate resolution: 18 sets of duplicate entries resolved (same person/property listed more than once). (Here)

• In a notable development, FinCEN issued a Statement of Enforcement Policy, developed in consultation with the IRS and the federal banking Agencies, committing to not tak supervisory or enforcement action against U.S. financial institutions for BSA violations arising from authorized financial services provided to persons or entities in Venezuela, in support of economic recovery and earthquake relief efforts under OFAC's GL 60 and GL 57. The commitment runs from July 27, 2026, through January 29, 2027, and is available to institutions that remain in current BSA compliance, have not faced a BSA-related enforcement action in the prior 24 months, and stay compliant with applicable OFAC sanctions, covering non-willful violations only. (Here)

• BIS announced that, effective November 20, 2026, export controls on certain silencers, mufflers, and sound suppressors will move from the State Department's U.S. Munitions List to BIS's Export Administration Regulations, aligning them with existing firearms export controls. Suppressors will be added to the Commerce Control List, with licensing required for certain exports, reexports, and in-country transfers to foreign persons (including related software and technology), and firearms license exceptions will extend to suppressors as well. (Here)

• The EU Council adopted Council Decision (CFSP) 2026/1837 concerning restrictive measures in view of Iran's military support to Russia's war of aggression against Ukraine and to armed groups in the Middle East and Red Sea region. Following its review, the Council renewed the underlying measures until 27 July 2027 and removed four individuals from the Annex I designated persons list. (Here)

Tuesday, July 28

• There were no major developments on this day.

Wednesday, July 29

• The UN Security Council unanimously adopted resolution 2827 (2026) extending for one year the sanctions regime targeting non-State armed groups and individuals in the Central African Republic, originally established under resolution 2127 (2013). The measures, including an arms embargo, travel ban, and asset freezes, are extended until 31 July 2027, while the mandate of the Panel of Experts supporting the 2745 Sanctions Committee is extended until 31 August 2027, with updated Panel reporting deadlines of 31 January 2027 (midterm) and 15 June 2027 (final). France and China both welcomed the resolution while noting continued fragility in border regions, and the Central African Republic's representative urged strict compliance with the sanctions regime, emphasizing scrutiny of the broader financing networks sustaining armed groups rather than the groups alone. (Here)

• OFAC imposed blocking sanctions on nine entities (two in Iran, five in Hong Kong, two in Marshall Islands) and eight vessels (three flagged in Barbados, two in Vanuatu, one in Marshall Islands, one in Mozambique, and one unknown-flagged) under its Iran (E.O. 13902) sanctions program. The action targets an IRGC-backed maritime insurance extortion scheme that forces commercial vessels to purchase mandatory "insurance" to transit the Strait of Hormuz—coverage nominally protecting against risks such as seizure that are overwhelmingly created by Iran itself, with one designated insurer accepting payment in digital assets to evade sanctions—as well as shadow fleet actors responsible for transporting Iranian crude oil and petroleum products to China and the UAE, which have collectively moved hundreds of thousands to millions of barrels of Iranian crude oil and petroleum products since as early as 2022. (Here)

Thursday, July 30

• The French Government imposed asset freezing sanctions on Russian journalist, Ksenia Borchik Fedorova, under its autonomous counter-terrorism sanctions regime. (Here)

• UK's ECJU published Notice to Exporters 2026/17 naming Airbus Operations Limited as having paid a compound settlement of £6,409,388 for offences under the Export Control Order 2008. Over a sustained period before November 2022, Airbus breached multiple recordkeeping and register-keeping requirements under Article 29(2)(a-g), 29(3), and 29(2)(i) tied to three of its Open General Export Licences (OGELs), as well as one condition failure under a Standard Individual Export Licence (SIEL) which are offences contrary to Articles 38(1)(a) and (b) of the Order. The case arose from a voluntary disclosure by Airbus, which fully cooperated with HMRC's investigation and implemented remediation measures. HMRC used the case to underscore the importance of strong internal controls for businesses transferring controlled technology under licensing regimes. (Here)

• The EU Council adopted Decision (CFSP) 2026/1885 imposing asset freezing sanctions on one person and one entity targeting an Iranian businessman and former owner of Bank Ayandeh and the Iran Mall, designated for using a network of companies and foreign banking channels to move funds abroad, including proceeds from Iranian oil sales, and for acquiring EU and UK real estate on behalf of persons connected to the Iranian leadership, including Supreme Leader Mojtaba Khamenei; and the MAPNA Group, an entity owned or controlled by the EU-listed Ministry of Energy of Iran, designated for its role in gas and oil field exploration alongside the Ministry of Petroleum and National Iranian Oil Company, channeling oil revenue support to the IRGC and the Organisation of Defensive Innovation and Research (SPND), and for providing support to Iran's proliferation-sensitive nuclear activities. (Here)

• The EU Council adopted Decision (CFSP) 2026/1882 setting out the results of its periodic review of the EU terrorist list under Decision (CFSP) 2026/455. Having verified that competent authorities' decisions regarding all listed persons, groups, and entities remain valid, the Council concluded that the restrictive measures should continue to apply and retained the full existing list unchanged: 13 natural persons (including designees linked to Iran's IRGC-Qods Force and MOIS, Hizballah, and Hamas-linked networks) and 23 groups/entities (including Hamas, Hizballah Military Wing, PKK, PIJ, PFLP, IRGC, LTTE, and others). (Here)

• The EU Council adopted Decision (CFSP) 2026/1896 on 30 July 2026, amending Decision (CFSP) 2020/1999, imposing asset freezing sanctions on seven individuals and three entities under the EU Global Human Rights Sanctions Regime for serious human rights violations tied to scam centre operations in Southeast Asia, including trafficking in human beings, torture, and other cruel, inhuman, and degrading treatment. The listings target two Cambodia-based conglomerates along with their respective chairmen, as well as a Myanmar/Burmese armed group controlling territory around Myawaddy on the Thailand border and five of its leadership figures, for providing protection to scam compounds and enabling trafficking, forced criminality, and violence against victims who attempted to escape or refused to cooperate. (Here)

• OFAC imposed blocking sanctions on one individual ( in China) and five entities (one in Russia, one in Iran, and two in China, and one in India) under it counter-terrorism sanctions program for supporting Mahan Air's global sales network and the IRGC's military targeting operations. The action targets general sales agents that provided sales, logistics, and travel coordination services enabling Mahan Air's role in transporting IRGC-Qods Force personnel and facilitating Iran's procurement and transport of unmanned aerial vehicle systems and weapons, as well as an IRGC-affiliated front company that used a website to solicit the locations of American and Israeli equipment and received strike requests for U.S. targets in the Middle East. (Here)

Friday, July 31

• The United States arrested and charged Mohammad Yousef Hasna, the global director of a an international charity registered in the United Kingdom which the United States government alleges to be a sham charity organization. He allegedly coordinated directly with Hamas's senior leadership regarding the delivery of fudns and supplies to Gaza. Hasna is charged with conspiring to provide material support to Hamas, conspiring to finance terrorism, and financing terrorism, each of which carries a maximum penalty of 20 years in prison. (Here)

• In a non-sanctions development, the United States dded 43 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. The goods mined, produced, or manufactured wholly or in part by an entity on the UFLPA Entity List are subject to rebuttable presumption of the use of forced labor and are prohibited from U.S. importation under 19 U.S.C. § 1307. (Here)

• The EU Council adopted Decision (CFSP) 2026/1892 concerning restrictive measures related to Iran's military support to Russia's war against Ukraine and to armed groups in the Middle East and Red Sea region. The amendment inserts new paragraphs 2a and 2b into Article 1, permitting competent authorities to authorize the sale, supply, transfer, transit, or export of restricted goods and technology (or related technical/financial assistance) for non-military use and non-military end-users where necessary for medical or pharmaceutical purposes; humanitarian purposes, health emergencies, or disaster response; or official purposes of EU and Member State diplomatic representations in Iran, including for visa application processing. (Here)

• The EU Council adopted Decision (CFSP) 2026/1866 to introduce derogations allowing the supply of certain goods and software to EU and Member State diplomatic representations in Iran, including delegations, embassies, and missions, specifically to support functions such as visa application processing. The amendment revises Article 3(1) to permit the Sanctions Committee to authorize, on a case-by-case basis, the supply of dual-use goods and technology (as listed in Annex I to Regulation (EU) No 267/2012) or related technical/financial assistance where such items clearly would not contribute to Iran's proliferation-sensitive nuclear activities or missile delivery systems, subject to end-user guarantees and Iranian non-use commitments. A new paragraph 3 is added granting Member State competent authorities similar case-by-case exemption authority for Article 1(1)(e) measures, with a requirement to notify other Member States and the Commission within four weeks of any exemption granted. (Here)

• The United States, Japan, South Korea, Australia, Canada, France, Germany, Italy, the Netherlands, New Zealand, and the United Kingdom issued a joint alert regarding the risks associated with North Korea IT workers. It published the modus operandi used by North Korean IT workers to help companies detect them. It also shared points that companies and hiring agencies should consider regarding this risk. (Here)