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Last Week's Major Developments in Sanctions - June 1 to June 4, 2026

  • Jun 10
  • 4 min read
You can now listen to the audio version of our weekly sanctions updates here.

Monday, June 1

  • Over the weekend on May 31, 2026, France imposed asset-freezing sanctions against one individual under France's autonomous counter-terrorims sanctions regime. (Here)

  • FTI Consulting, a Washington D.C.-based global advisory firm, settled with OFAC for $1,050,000 for apparent violations of the Ukraine-/Russia-Related Sanctions Regulations (URSR) under Directive 1 of E.O. 13662. The apparent violations highlighted by OFAC in the Enforcement Release are summarised as: between April 2019 and May 2021, FTI provided expert economic consulting services in support of VTB Bank OAO, a Russian state-owned bank on OFAC's SSI list, in Singapore litigation, routing invoices through a law firm intermediary in an attempt to avoid direct dealings. Directive 1 prohibits U.S. persons from dealing in new debt of more than 14 days maturity with SSI-listed entities, and several of FTI's invoices went unpaid for 90 to 198+ days, far exceeding that limit. OFAC found the indirect structure did not shield FTI from liability. Aggravating the case, FTI's own compliance team had flagged VTB-related risks at the outset, yet the firm continued issuing invoices even as they went unpaid and even joined calls with VTB to chase payment. (Here)

  • OFAC released an updated introductory guide covering the fundamentals of how U.S. sanctions work, who must comply, and what happens when they don't. It's a useful reference document for compliance teams, particularly those onboarding new staff or building out sanctions frameworks. (Here)

  • Australia imposed blocking sanctions against two individuals and four entities (farms) extremist West-bank settlers autonomous sanctions program. (Here) 


Tuesday, June 2 

  • OFAC imposed blocking sanctions against four entities and four individuals (all in Iran) under its Iran and Counterterrorism sanctions programs for operating Iranian digital asset exchanges that have processed billions of dollars in transactions linked to the IRGC, facilitated sanctions evasion, and helped the government of Iran transfer wealth out of the country. The action targeted Nobitex, Iran's largest crypto exchange, which processed over 50% of all Iranian digital asset inflows in 2025, along with Wallex, Bitpin, and Ramzinex, as well as Nobitex's chairman, co-founders, and current CEO. OFAC also issued a new FAQ 1257 addressing sanctions risks associated with Iranian digital asset exchanges. (Here, the Department of the Treasury's press release, the Department of State's press release, and FAQ 1257)

  • OFAC imposed blocking sanctions on two individuals (both in Rwanda) under its Democratic Republic of Congo sanctions program for serving as commanders of the FDLR and Rwanda-backed M23 rebel groups, both of which have violently occupied territory in eastern DRC and committed widespread human rights abuses including killings, sexual violence, and forced child recruitment. (Here, the Department of the Treasury's press release and the Department of State's press release)


Wednesday, June 3

  • A dual U.S.-Iranian national and CEO of a Tehran-based technology company, was arrested on charges of violating U.S. sanctions by acquiring sophisticated U.S.-origin networking, security, and encryption equipment for Iranian customers including Iran's nuclear and military establishments. From 2011 to 2024, they moved more than $15 million from Iran into his U.S. bank accounts, falsely reporting the funds to the IRS as a foreign inheritance. If convicted, they face up to 20 years in prison. (Here)


Thursday, June 4

  • The U.S. Department of State imposed blocking sanctions on five individuals (all in Cuba, except one in Spain) and five entities (all in Cuba) under its Cuba sanctions program for sustaining the Cuban regime's subversive operations and anti-American activities. Sanctioned individuals include Cuban President Miguel Díaz-Canel and his wife and stepson, former Cuban intelligence chief Alejandro Castro Espín (son of Raúl Castro) and his son, as well as key regime institutions, a travel agency and a gold mining joint venture. OFAC also issued a new FAQ 1258 (Here, the Department of State's press release, and FAQ 1258)


Friday, June 5 

  • OFAC imposed blocking sanctions on four individuals (two in UAE, two in Iran), 12 entities (four in UAE, one in China, one in Iran, five in Marshall Islands, one in Liberia), and six vessels (four flagged in Panama, one flagged in Palau, one flagged in St. Kitts and Nevis) under the Iran sanctions program, targeting two networks. The first is an LPG smuggling network that used UAE front companies to export Iranian-origin LPG to South and East Asia disguised as Omani LPG. The second is Iranian exchange house Mehrdad Geramian Nik and Partners Company, which moved hundreds of millions of dollars on behalf of sanctioned Iranian banks using overseas shell companies. (Here, the Department of the Treasury's press release and the Department of State's press release)

  • FinCEN issued a Joint Advisory on Non-Work Authorized Populations and Their Employers and Risks to the Integrity of the U.S. Financial System urging vigilance against fraud schemes involving the unlawful employment of undocumented workers. Key takeaways for financial institutions are: 

    • The Advisory identifies two primary typologies: identity theft by workers using fraudulently obtained Social Security numbers and other stolen PII to gain employment and access financial services; and payroll fraud schemes where complicit employers use labor brokers operating shell companies, often unregistered money services businesses, to pay workers off the books via cash couriers, checks, or P2P platforms while evading federal and state payroll taxes and workers' compensation obligations.

    • Financial institutions reported over $2.5 billion in suspicious activity tied to such schemes in 2025. 

    • The Advisory also flags enhanced due diligence considerations around Individual Taxpayer Identification Numbers (ITINs), noting that their use in lieu of a Social Security number when opening accounts or applying for credit may be a relevant risk factor. 

    • The Advisory includes 18 red flag indicators and requests that institutions reference the key term "FINANCIALINTEGRITY-2026-A002" in SAR field 2 when filing related suspicious activity reports. (Here, the Department of the Treasury’s press release)


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