Last Week's Major Developments in Sanctions - June 15 to June 19, 2026
- Jun 24
- 8 min read
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Monday, June 15
The EU Council adopted a comprehensive sanctions package consisting of 34 individuals and 47 entities in response to Russia's war of aggression against Ukraine, hybrid threats, and systematic human rights violations. The measures target Russia's military-industrial complex, its shadow fleet ecosystem used to circumvent energy sanctions, state propaganda networks, and those responsible for the poisoning and death of Alexei Navalny. (Here) Three Council decisions form the backbone of this sanctions wave:
Council Decision (CFSP) 2026/1363 imposes asset freezing sanctions on 15 individuals and 1 entity for involvement in the persecution, poisoning, and death of Alexei Navalny, including FSB operatives, judges, prosecutors, medical personnel, and law enforcement officials who obstructed investigations or facilitated his repression, as well as IPJSC NTK, a facial recognition technology company used to monitor and detain opposition activists and journalists in Moscow.
Council Decision (CFSP) 2026/1351 imposes asset freezing sanctions on 10 individuals and the Presidential Foundation for Cultural Initiatives for Russia's destabilizing hybrid activities, targeting prominent propagandists and media figures, including journalists, bloggers, Orthodox clergy, and TV personalities responsible for spreading disinformation aimed at justifying Russia's aggression and dehumanizing Ukrainians.
Council Decision (CFSP) 2026/1364 imposes asset freezing sanctions on 9 persons and 45 entities supporting Russia's military-industrial complex and enabling energy revenue flows, including drone manufacturers (LLC Rustakt, LLC ASFPV, LLC IONOS), aerospace and defense contractors, Chinese suppliers, and 24 shipping companies operating vessels in Russia's shadow fleet engaged in irregular oil transport practices.
The EU Council adopted Decision (CFSP) 2026/1334, amending the existing restrictive measures concerning the situation in Libya. This update incorporates amendments mandated by United Nations Security Council (UNSC) Resolution 2819 (2026), which specifically updates listing criteria for travel restrictions and asset freezes. Additionally, the decision modifies the scope of measures affecting the Libyan Investment Authority and introduces specific provisions allowing competent national authorities to authorize the transfer of frozen assets between custodial banks to facilitate changes in global custodian roles, provided the assets remain frozen and their value is maintained. (Here)
The EU Council adopted Council Decision (CFSP) 2026/1357 imposing asset freezing sanctions against six individuals responsible for destabilising the Republic of Moldova, bringing total EU sanctions under this regime to 29 individuals and 5 entities. The sanctioned individuals coordinated Russian-funded operations aimed at disrupting Moldova's September 2025 parliamentary elections through vote-buying schemes, disinformation campaigns, and voter influence operations linked to EU-listed figures Ilan Shor and the Russia-based organisation Evrazia. (Here)
To support the diversification of supply chains for Union operators, the EU Council adopted Decision (CFSP) 2026/1333, which amends the restrictive measures related to actions undermining the territorial integrity, sovereignty, and independence of Ukraine. This decision introduces temporary derogations from asset freeze prohibitions for a specific entity (listed as entry number 692), allowing for the orderly wind-down of existing contracts and agreements concluded before April 23, 2026, provided these actions are completed by December 31, 2026. Furthermore, it permits the purchase of critical components from this entity to enable a transition toward alternative supply sources, with such payments required to be completed by March 16, 2027. (Here)
EU Commission amended one FAQ on import ban on refined products obtained from Russian crude oil concerning sanctions adopted following Russia’s military aggression against Ukraine under its Russia sanctions program. (Here)
Tuesday, June 16
The EU Council adopted Decision (CFSP) 2026/1360, which extends the existing restrictive measures originally imposed in response to the illegal annexation of Crimea and Sevastopol. Concluding that the circumstances necessitating these measures remain unchanged—as the affected regions continue to violate fundamental rules of international law, including the prohibition on the use of force—the Council has renewed the sanctions until June 23, 2027. (Here)
Wednesday, June 17
The EU Council adopted Decision (CFSP) 2026/1360, which extends the existing restrictive measures originally imposed in response to the illegal annexation of Crimea and Sevastopol. Concluding that the circumstances necessitating these measures remain unchanged—as the affected regions continue to violate fundamental rules of international law, including the prohibition on the use of force—the Council has renewed the sanctions until June 23, 2027. (Here)
OFSI imposed a £1,000,920.59 penalty on Sabre Global Technologies Limited (SGTL) for breaching Russia sanctions regulations. SGTL violated regulations 13, 14, and 19 of the Russia (Sanctions) (EU Exit) Regulations 2019 by continuing to provide Global Distribution System services to designated entity Ural Airlines after its May 2022 designation, invoicing for these services, and actively exploring alternative payment routes (including requesting test payments to non-UK accounts) to circumvent sanctions blocks, conduct assessed as "most serious." The total breach value reached £2,634,001.54, and the baseline penalty of £1,251,150.73 was reduced by 20% to reflect SGTL's voluntary disclosure and settlement cooperation. OFSI's compliance guidance for firms emphasizes four critical lessons: (1) firms must not manipulate payment pathways or stage payments through third countries; (2) digital and intangible services, including software and data tools, qualify as "economic resources" subject to sanctions; (3) organizations must maintain robust, UK-tailored sanctions policies with competent senior oversight and functional screening systems; and (4) suspected breaches must be reported to OFSI promptly and comprehensively, with early disclosure encouraged even if details remain incomplete. (Here)
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) announced a settlement requiring Robert Bosch GmbH to pay a $36,184,680 penalty for export control violations. Between September 2020 and September 2024, Bosch exported roughly $72.3 million worth of MEMS sensor products and automotive software to Huawei and its affiliates without the necessary BIS authorization, violating the Foreign Direct Product Rule under the Export Administration Regulations. Because the company filed a Voluntary Self-Disclosure and cooperated with investigators, BIS suspended approximately $3.6 million of the penalty as credit toward Bosch's separate profit disgorgement agreement with the Department of Justice. Simultaneously, the Department of Justice's National Security Division announced its first-ever declination of prosecution under the Corporate Enforcement Policy regarding the same conduct. Because Bosch voluntarily self-disclosed these Foreign Direct Product Rule violations, fully cooperated, and overhauled its compliance program, it successfully avoided criminal charges. As part of the resolution, Bosch agreed to disgorge $11.4 million in illicit profits to the DOJ, a portion of which BIS will credit toward its separate civil penalty. (Here)
A U.S. federal judge in Manhattan officially dismissed the nine-year criminal indictment against Türkiye’s state-owned lender, Halkbank. This resolution follows the bank's successful completion of a 90-day compliance review period mandated by a March 2026 deferred prosecution agreement (DPA), during which an independent audit by Ernst & Young confirmed no evidence of non-compliance. By concluding the case without any admission of criminal wrongdoing or the imposition of judicial fines, the settlement removes a major diplomatic friction point, marking a significant normalization step in U.S.-Türkiye bilateral relations. Key Takeaways: Permanent Closure: The dismissal order signed by U.S. District Judge Richard Berman formally ends the 2019 criminal proceedings regarding alleged sanctions evasion. Verified Compliance: The bank passed a rigorous, court-mandated independent audit, confirming the effectiveness of its current sanctions and anti-money laundering (AML) controls. No Financial Penalties: The agreement, which required no admission of guilt, concludes without judicial fines, though it mandates that the bank continue to strictly adhere to anti-Iran transaction prohibitions and cooperate with ongoing compliance monitoring. Diplomatic Thaw: The resolution of this long-standing legal battle is widely regarded as a pivotal development in easing tensions between Washington and Ankara. (Here)
Thursday, June 18
OFAC issued the following Venezuela-related General Licenses: 1. General License No. 5X superseding GL 5W. The key change is the effective date for authorized transactions in the Petróleos de Venezuela 2020 8.5% Bond has been extended from June 19, 2026 to August 4, 2026—a six-week extension of the prior authorization window. 2. General License No. 24A replacing GL 24 (dated August 5, 2019). The license continues to authorize telecommunications and mail transactions with the Government of Venezuela, maintaining the seven-year-old authorization framework with updated administrative language. 3. General License No. 59 authorizing supply of maintenance, repair, and technical services for Conviasa (Venezuelan airline) aircraft. The license includes strict carve-outs: prohibits commercially unreasonable payment terms, debt swaps, gold payments, Venezuelan digital currency (including the petro), and any involvement with Russia, Iran, North Korea, Cuba, or Chinese entities. OFAC also amended FAQ 595. (Here)
OFAC imposed blocking sanctions on three individuals (two in Lebanon and one in Iraq/Lebanon) and five entities (two in Lebanon, one in Syria, one in Iraq, and one in Oman) under its Counter terrorism sanctions program for supporting Hizballah's financial network and undermining Lebanese state authority. The designations target Lebanese political officials, along with members of a business network controlled by U.S.-designated Alaa Hassan Hamieh, including companies operating front operations in multiple countries to generate revenue for the Hizballah network. (Here)
FinCEN, together with the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and National Credit Union Administration, have jointly proposed a rule to implement the GENIUS Act's directives treating permitted payment stablecoin issuers as financial institutions under the Bank Secrecy Act and requiring them to maintain effective customer identification programs. The proposal establishes minimum standards requiring PPSIs to collect and verify customer information (name, address, date of birth/formation, and identification numbers), maintain records for five years, compare customers against government terrorism lists, and provide customer notice of these identity verification requirements. Key Takeaways & Actions: Compliance Timeline: The rule would be effective 12 months after issuance of the final rule Comment Deadline: August 21, 2026 via regulations.gov Affected Parties: Estimated 50 PPSIs (approximately 60% would be bank subsidiaries; 40% standalone entities) Primary vs. Secondary Market: CIP requirements focus on primary market activity where PPSIs directly interact with customers for issuance and redemption, not secondary market transactions Estimated Cost: ~$1.65 million annually for PPSIs across compliance, recordkeeping, and verification activities Action Required: Stablecoin issuers should prepare documentation of identity verification procedures and customer information collection processes. (Here)
OFAC and FinCEN have jointly proposed new regulations under the GENIUS Act that require permitted payment stablecoin issuers (PPSIs) to implement comprehensive, risk-based economic sanctions compliance programs. To meet these regulatory obligations, issuers must deploy robust internal controls and technological capabilities to actively block, freeze, reject, and even "burn" impermissible transactions across both their primary and secondary stablecoin markets. Because PPSIs are explicitly categorized as U.S. persons under the proposed framework, they face strict civil liability for any sanctions violations, which includes failures to prevent blocked individuals from interacting with their underlying smart contracts. (Here)
Friday, June 19
OFAC and FinCEN have jointly proposed new regulations under the GENIUS Act that require permitted payment stablecoin issuers (PPSIs) to implement comprehensive, risk-based economic sanctions compliance programs. To meet these regulatory obligations, issuers must deploy robust internal controls and technological capabilities to actively block, freeze, reject, and even "burn" impermissible transactions across both their primary and secondary stablecoin markets. Because PPSIs are explicitly categorized as U.S. persons under the proposed framework, they face strict civil liability for any sanctions violations, which includes failures to prevent blocked individuals from interacting with their underlying smart contracts. (Here)
OFSI amended the Continuation of Business of Lukoil International Entities General Licence (INT/2025/8031092) to remove the restriction set out in paragraph 4.2 with respect to transactions with Lukoil entities. (Here)
FATF added Bosnia and Herzegovina and Iraq to the list of jurisdictions under increased monitoring (i.e. Gray List) while Algeria and Namibia were removed. North Korea, Iran, and Myanmar are still on the Black List. (Here)
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