Last Week's Major Developments in Sanctions - June 22 to June 26, 2026

Monday, June 22

• In the wake of Iran-USA MoU, OFAC issued GL X, authorizing all transactions prohibited by the several Iran and Iran-related authorities that are ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil, petrochemical products, or petroleum products of Iranian origin, including transactions involving vessels blocked under the names authorities, through 12:01 a.m. eastern daylight time, August 21, 2026. (Here)

• OFAC imposed blocking sanctions on three individuals (one in France, one in Syria, one in Nigeria), six entities (two in Turkey, one in Syria, three in Nigeria), targeting two networks under its Counter Terrorism sanctions program. The first comprises transregional ISIS facilitators operating across Europe, the Middle East, and North Africa—including Abdelhakim Boukich, who operates Bitcoin Xchange, a Syria-based money service business that transferred funds on behalf of ISIS associates from Norway, Belgium, the Netherlands, South Africa, and the United States. The second is an ISIS-West Africa (ISIS-WA) financial network centered on Nigerian-based Mukhtar Adamu Muhammad, who moved funds through three bureaus de change (Nine to Nine Exchange, Manhattan Bureau, and Generation Currency). This action follows the May 16, 2026 killing of ISIS's number two official, Abu-Bilal al-Minuki, who led ISIS's General Directorate of Provinces. (Here)

Tuesday, June 23

• OFAC and OFSI released guidance following their latest in-person strategic exchange. As the two largest economic sanctions authorities globally, OFAC and OFSI are deepening their partnership to ensure sanctions remain an effective foreign policy tool while maintaining clarity and compliance for the private sector. The new publications, including a comparative overview of U.S. and UK sanctions regimes, reflect their commitment to coordinated enforcement, modernized systems, and shared approaches to emerging threats. Key Takeaways:

  • New Guidance Released – U.S. and UK published comparative overview to help private sector understand obligations under both regimes

  • Enhanced Collaboration Focus – OFAC and OFSI identifying shared opportunities to improve sanctions efficacy, including: - Rapid sanctions escalation mechanisms - Lessons from Russia/Ukraine response applied to other scenarios - Shadow fleet targeting and disruption strategies - Structured sanctions regime dismantling (e.g., Syria)

  • Technology & Modernization – Both agencies investing in advanced impact analysis tools, AI-supported compliance systems, and improved platforms

  • Enforcement Alignment – Similar strict liability standards and voluntary disclosure policies (OFAC: 50% penalty reduction; OFSI: up to 30%)

  • Next Steps – Partnership continues with fall 2026 exchange in Washington DC. (Here)

• OFAC issued General License No. 2 permitting businesses to wind down transactions with CCU Commercial Bank Plc. and its majority-owned subsidiaries through July 23, 2026. The temporary exemption authorizes exit activities such as account closures and fund transfers, though all payments to blocked persons must go to blocked accounts and no other TCOSR violations are permitted. (Here)

• The U.S. Department of State imposed blocking sanctions on one individual and five entities located in Cuba under Executive Order 14404 for generating revenue for the Cuban regime through financial services and mining operations. The designations target entities affiliated with Cuba's state-controlled conglomerate GAESA and the regime's minerals extraction sector, including a commercial bank handling the majority of Cuba's foreign transactions, financial management companies, and mining and steel production operations that funnel proceeds to the government. (Here)

• OFAC imposed blocking sanctions on eight individuals (three in Cambodia, three in Hong Kong, one in Singapore, and one in the United Kingdom) and 26 entities (11 in the United Kingdom, 10 in Hong Kong, two in British Virgin Islands, one in Cambodia, one in Singapore, and one in Thailand) under its Transnational Criminal Organizations sanctions program for operating digital asset investment scams that defraud Americans. In addition, OFAC modified the designation of one individual, Hu Xiaowei, previously designated in October 2025 under the alias Chen Xiao'er, updating his record to reflect his proper name and additional aliases. The designations target Prince Group TCO leadership, including Hu Xiaowei, the organization's second-in-command, along with investors in scam compounds and members of a subordinate business network controlling companies across Asia and the United Kingdom used to launder billions of dollars from cryptocurrency fraud and money laundering operations. (Here)

Wednesday, June 24

• OFSI has published the amended Prince Group Insolvency General Licence INT/2026/9491628. The General Licence was amended as follows: The definition of 'Permitted Insolvency Activities' was amended to “The making, receiving, or processing of payments and any other action that is in connection with the Insolvency Proceedings, whether prior to or after commencement of such proceedings, conducted at the direction of, or with the consent of an Insolvency Practitioner (or Practitioners), are permitted, provided that no funds or economic resources are made available (directly or indirectly) to or for the benefit of any DP other than a Prince Group DP or Subsidiary.” (Here)

• OFSI issues FAQ 196 providing short-form guidance and technical information on financial sanctions relating to amendment of General Licence INT/2025/8031092 on 19 June 2026. (Here)

Thursday, June 25

• OFAC issued General License No. 131G superseding General License No. 131F, extending the authorization deadline for negotiating and executing contingent contracts for the sale of Lukoil International GmbH and related maintenance activities by one month, from June 27, 2026 to July 25, 2026. The license continues to authorize transactions ordinarily incident and necessary to negotiate contingent contracts with Lukoil, provided that performance is contingent upon receipt of separate OFAC authorization, and maintains authorization for maintenance or wind-down of existing operations. The license prohibits transfers of funds to persons or accounts located in the Russian Federation. In addition, OFAC also issued FAQs 1224 and 1225. (Here)

• OFAC imposed blocking sanctions on two individuals (both in Rwanda) and four entities (all in Rwanda) under its Democratic Republic of Congo's sanctions program for smuggling conflict minerals from eastern Democratic Republic of the Congo and supporting the Rwanda-backed M23 armed group. The designations target the chairman and operators of Gasabo Gold Refinery and a network of related Rwandan mining companies involved in laundering gold illegally extracted from M23-controlled areas in the DRC through a minerals trafficking scheme that generated millions of dollars in proceeds to finance M23's destabilizing operations and military activities. The action supports implementation of the U.S.-brokered Washington Accords for Peace and Prosperity signed in December 2025, aimed at establishing a fully licit and transparent regional minerals sector. (Here)

• OFAC issued General License No. 60 authorizing transactions related to earthquake relief efforts in Venezuela through October 23, 2026, including the processing or transfer of funds on behalf of third-country persons to or from Venezuela in support of relief activities. The license does not authorize the unblocking of any property blocked pursuant to Venezuela Sanctions Regulations or any other transactions prohibited by separate executive orders. (Here)

• EU Council adopted Council Decision (CFSP) 2026/1437 extending economic sanctions against Russia until 31 July 2027. The decision amends the original Decision 2014/512/CFSP by renewing restrictive measures for a further 12 months in response to Russia's ongoing military aggression in Ukraine. The measure includes sanctions on key sectors—trade, finance, energy, and dual-use technology—as well as a ban on seaborne crude oil imports, restrictions on Russian financial institutions and crypto service providers, and suspension of Kremlin-backed disinformation outlets. The EU stated it stands ready to take additional measures if Russia continues its illegal actions and violations of international law. (Here)

• ECJU has published an open general export licence (OGEL), covering an extensive range of dual-use goods to a wider list of global destinations. As well as destinations covered by existing general licences for dual-use goods (including EU member states, the United States, Japan, New Zealand, Australia and Canada), the OGEL permits exports to South Korea, Singapore, Chile and Uruguay, and British Overseas Territories. (Here)

Friday, June 26

• The EU Council extended its restrictive measures against individuals and entities responsible for threatening Haiti's peace, stability, and security until 29 July 2027, following an annual review. Nine individuals and one entity remain subject to asset freezes and travel bans in response to persistent gang violence and destabilizing criminal activities. The measure complements the EU's broader support for Haiti, including macroeconomic assistance, support to institutional capacity, education, food security, and the Haitian National Police. (Here)

• OFAC imposed blocking sanctions on five individuals (one in India, three in Panama, and one in Sudan) and three entities (two in Sudan and one in India) under its Sudan sanctions program for supplying weapons, explosives, and recruiting foreign fighters to both the Sudanese Armed Forces and the Rapid Support Forces. The designations target leadership and operators of procurement networks sourcing explosives and military equipment from foreign suppliers, including an Indian explosives manufacturer providing over 200 shipments of explosives used in bombs deployed by Sudanese forces, as well as members of a Colombian-led recruitment network operating through Panama-based companies that have recruited former Colombian military personnel to fight for the RSF, an armed group designated for committing genocide. (Here)