Last Week's Major Developments in Sanctions - July 6 to July 10, 2026

Monday, July 6

• The UK Government imposed asset freezing sanctions against seven individuals and two entities, all based in Russia, targeting directors, deputy directors, and senior scientific staff of SC Signal and the State Research Institute of Military Medicine (GNIII VM), both linked to the previously-designated (October 2020) State Research Institute of Organic Chemistry and Technology (GosNIIOKhT), in connection with Russia's undeclared chemical weapons program and the research, development, and production of Novichok nerve agents and the toxin Epibatidine used in the poisonings of Alexei Navalny and Dawn Sturgess. (Here)

  
  

Tuesday, July 7

• OFAC issued General License X1, revoking General License X which was issued on June 21, 2026, to authorize Iranian-origin crude oil, petrochemical, and petroleum product transactions through August 21, 2026. GL X1 authorizes the wind-down of activities authorized under GL X through 12:01 a.m. EDT, July 17, 2026, provided any payment to a blocked person goes into a blocked, interest-bearing U.S. account. (Here)

Wednesday, July 8

• OFAC's General License No. 13R replaces and supersedes General License No. 13Q (dated April 8, 2026), extending the authorization for certain administrative transactions otherwise prohibited by Directive 4 under E.O. 14024 which are payment of taxes, fees, or import duties, and purchase or receipt of permits, licenses, registrations, certifications, or tax refunds ordinarily incident and necessary to day-to-day operations in Russia, from the prior expiry of July 9, 2026 out to 12:01 a.m. EDT, October 9, 2026. The substantive terms and carve-outs are otherwise unchanged: it still doesn't authorize debits to U.S. financial institution accounts held by the Central Bank of Russia, the National Wealth Fund, or the Ministry of Finance, nor any other RuHSR-prohibited transactions involving blocked persons. OFAC also amended two associated, Russia-related Frequently Asked Questions, FAQs 999 and 1118. (Here)

• The U.S. President informed Congress of his administration’s intent to rescind Syria’s designation as a State Sponsor of Terrorism , following a 45-day pre-notification period. This is yet another historic step by President Trump to give the Syrian people a chance at greatness. That means starting August 22, 2026, #Syria can move removed from Country Group E under the EAR, which in turn would relax the restrictions on #export of controlled items to Syria. Also, a reminder that most of the #sanctions against Syria were lifted last year. (Here)

• The European Commission and the High Representative of the Union for Foreign Affairs and Security Policy proposed a new EU sanctions regime targeting migrant smuggling, human trafficking, and other serious forms of organised crime, including trafficking in firearms and illicit drugs and related money laundering; the proposal follows President von der Leyen's 2025 State of the Union announcement and is designed to disrupt smugglers' business models, restrict their movement, and cut off their profits, with the measures now heading to the Council for adoption by Member State unanimity. The proposed regime would target: - illicit activities originating outside the Union which, by reason of their widespread, systematic or organised nature, pose a serious threat to the Union's values, to the security of the Union and its Member States, or to international security; - conduct related to migrant smuggling, trafficking in human beings, trafficking and other activities linked to illicit drugs, illicit manufacture and trafficking of firearms and money laundering; - identified individuals and entities involved in these activities, including those who lead, direct or support them by introducing and establishing a clear framework for restrictive measures. (Here)

Thursday, July 9

• There were no major developments on this day.

Friday, July 10

• In a final rule, BIS amends the EAR to provide enhanced favorable treatment for the United Arab Emirates (UAE). Specifically, BIS is removing the UAE from Country Groups D:3 and D:4 and adding the UAE to Country Group A:5. More license exceptions will now be available, including Strategic Trade Authorization (STA) for the UAE Government and approved commercial entities in the UAE. STA will authorize the export, reexport, or transfer (in-country) of military items; certain commercial satellites and spacecraft; and dual-use items useful in, inter alia, oil and gas production, desalination, and civil nuclear power generation. The UAE Government and approved commercial entities will also have license-free access to advanced computing items, consistent with the May 2025 U.S.-UAE Artificial Intelligence Cooperation framework, without compromising U.S. digital infrastructure buildout. (Here)

• OFAC issued DRC-related General License No. 2 under the Democratic Republic of the Congo Sanctions Regulations (31 CFR part 547), authorizing transactions related to agricultural commodities, medicine, medical devices, and related replacement parts, components, and software updates to the DRC or Rwanda (including to third-country persons purchasing specifically for provision to those destinations), as well as transactions related to the prevention, diagnosis, or treatment of disease or medical conditions and the conduct of clinical trials and other medical research in the DRC or Rwanda. (Here)

• OFAC issued General License Y authorizing transactions related to the wind down of any transaction involving Smart Global Limited, or any entity in which Smart Global Limited owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. EDT on August 9, 2026. (Here)

• OFAC imposed blocking sanctions on eight individuals (seven in Iran and one in the United Arab Emirates) and six entities (three in Iran, one in Hong Kong, one in the UAE, and one in Saint Kitts and Nevis) under its Iran sanctions and counterterrorism programs for facilitating illicit financial flows benefiting Iran's Supreme Leader and sanctioned Iranian banks. The designations target a key financier for the Iranian Supreme Leader's office who has institutionalized large-scale embezzlement within the Iranian government and accumulated a global portfolio of real estate and commercial holdings across multiple jurisdictions on behalf of the Supreme Leader and elites, along with the controlling partners and operators of three major Iranian currency exchange houses that collectively move billions of dollars annually on behalf of sanctioned Iranian banks using layers of shell companies and front operations to obscure illicit financial activity. (Here)

Recommendation of the Week

• Last week there were reports that a bipartisan group of senators reached an agreement with President Donald Trump’s administration to move forward on "Sanctioning Russia Act of 2025." (Here) The bill, which was sponsored by recently deceased Republican senator from South Carolina, Lindsey Graham, requires the President to take certain actions (if the President makes such a determination) including:

  • The President must impose visa- and property-blocking sanctions on specified persons such as the Russian president, certain Russian military commanders, and any foreign person that knowingly provides defense items to the Russian armed forces;

  • The President must increase the rate of duty on all goods and services imported from Russia into the United States to at least 500% relative to the value of such goods and services;

  • The President must increase the rate of duty on all goods and services imported into the United States from countries that knowingly engage in the exchange of Russian-origin uranium and petroleum products to at least 500% relative to the value of such goods and services;

  • The Department of the Treasury must impose property-blocking sanctions on any financial institution organized under Russian law and owned wholly or partly by Russia, and any financial institution that engages in transactions with those entities; and

  • The Department of Commerce must prohibit the export, reexport, or in-country transfer to or in Russia of any U.S.-produced energy or energy product.

  Considering the sudden death of senator Graham, the faith of this bill will remain to be seen.