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Last Week's Major Developments in Sanctions - June 8 to June 12, 2026

  • 2 days ago
  • 7 min read
You can now listen to the audio version of our weekly sanctions updates here.

Monday, June 8

  • OFSIpublished FAQ 187 on whether and how post sanctions mandatory corporate actions (like stock splits) impact the issue date of a transferable security.(Here) 

  • The EU Council adopted Council Decision (CFSP) 2026/1226 imposing asset freezing sanctions against two individuals and one entity threatening freedom of navigation in the Middle East. Specifically, the EU designated the Hormozgan Provincial Command of the Islamic Revolutionary Guard Corps Navy (IRGCN), alongside its Commander and Deputy Commander for executing an unauthorized toll and screening system that selectively blocks international vessels transiting the Strait of Hormuz. (Here, EU Council’s press release) 


Tuesday, June 9

  • France imposed asset-freezing sanctions against four individuals and three entities under France's autonomous counter-terrorims sanctions regime. (Here)

  • The UK Government imposed asset freezing sanctions on one individual and six entities under its Global Human Rights Sanctions Regime. These sanctions were announced to be coordinated alongside Australia, Canada, France, New Zealand, and Norway targeting financial and operational networks enabling settler violence against Palestinians in the West Bank. The joint restrictions penalize key figures and entities facilitating illegal outposts and extremist financing, coinciding with a diplomatic push for the implementation of the 20 Point Peace Plan. (Here, UK government’s press release) 


Wednesday, June 10

  • OFAC imposed blocking sanctions on five individuals (four in China and one in Iran) and three entities (two in Hong Kong and one in Shanghai) under its Non-Proliferation (WMD) and Iranian sanctions programs for being part of two separate procurement networks supporting Iran's Islamic Revolutionary Guard Corps (IRGC) and Ministry of Defense and Armed Forces Logistics (MODAFL), including facilitating the purchase of MANPADS and other weapons through China and Hong Kong-based intermediaries. OFAC also imposed blocking sanctions on one Hong Kong-based entity under its Iran sanctions program (pursuant to E.O. 13902) for operating within Iran's clandestine banking network and facilitating payments on behalf of Iranian blocked persons. Concurrently, the U.S. Department of State imposed blocking sanctions on two individuals and two entities (all in Iran) under E.O. 13949 for arms trade and provision of technical or financial services for arms trade, with OFAC subsequently updating the SDN entries for those four to add the [IRAN-CON-ARMS-EO] tag reflecting the State designations. (Here, the Department of the Treasury's press release, the Department of State's press release, and the Department of State's fact sheet) 

  • OFAC issued a wave of updated Venezuela General Licenses (specifically 46C, 47A, 48B, 50B, 51B, 52A, and 54A), replacing and superseding their respective previous versions. While the core substance and underlying authorizations of each individual license remain entirely intact, OFAC carried out legal updates across the licenses. OFAC also issued FAQ 1259 and 1260 to clarify the updated GLs. The two key changes across all of these licenses are:

    • Relaxing the previous requirement restricting legal venues strictly to the United States, all updated licenses now permit contract dispute resolution proceedings to take place in the United States, the United Kingdom, France, or Singapore.

    • The governing law provisions have been standardized to require that the terms of the authorized contracts be construed and interpreted in accordance with U.S. jurisdictional laws, providing broader flexibility for complex international operations compared to the previous mandatory "governing law" standard.

The specific updates include:

  • General License 46C: OFAC issued General License 46C on June 10, 2026, replacing and superseding GL 46B (dated March 13, 2026) in its entirety. The substance of the license remains the same, authorizing transactions ordinarily incident and necessary to the lifting, exportation, sale, storage, marketing, and transportation of Venezuelan-origin oil or petrochemical products for importation into the United States by established U.S. entities. (Here)

  • General License 47A: OFAC issued General License 47A on June 10, 2026, replacing and superseding GL 47 (dated February 3, 2026) in its entirety. The substance of the license remains the same, authorizing transactions ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, marketing, delivery, or transportation of U.S.-origin diluents to Venezuela. (Here)

  • General License 48B: OFAC issued General License 48B on June 10, 2026, replacing and superseding GL 48A in its entirety. The substance of the license remains the same, authorizing transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, or production of oil, gas, or petrochemical products in Venezuela, or for the electrical sector. (Here)

  • General License 50B: OFAC issued General License 50B on June 10, 2026, replacing and superseding GL 50A (dated February 18, 2026) in its entirety. The substance of the license remains the same, authorizing transactions ordinarily incident and necessary to oil or gas sector operations in Venezuela for specific designated corporate entities listed in its Annex. (Here)

  • General License 51B: OFAC issued General License 51B on June 10, 2026, replacing and superseding GL 51A (dated March 27, 2026) in its entirety. The substance of the license remains the same, authorizing transactions ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin minerals, including gold, involving Minerven Entities by established U.S. entities. (Here)

  • General License 52A: OFAC issued General License 52A on June 10, 2026, replacing and superseding GL 52 (dated March 18, 2026) in its entirety. The substance of the license remains the same, authorizing certain transactions involving Petróleos de Venezuela, S.A. (PdVSA) or PdVSA Entities by established U.S. entities, specifically dealing with the export or supply of oil and petrochemical products to non-U.S. destinations. (Here)

  • General License 54A: OFAC issued General License 54A on June 10, 2026, replacing and superseding GL 54 (dated March 27, 2026) in its entirety. The substance of the license remains the same, authorizing transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, mining, extraction, processing, refining, or production of minerals, including gold, in Venezuela involving Minerven Entities. (Here)

  • U.S. Federal authorities seized 13 fraudulent internet domains operated by suspected Chinese intelligence agents. Disguised as legitimate geopolitical and business consulting firms, these sham websites used promises of lucrative compensation to target current and former U.S. security clearance holders in order to illicitly acquire classified and sensitive U.S. government information. (Here)


Thursday, June 11

  • The U.S. Department of State imposed blocking sanctions against Cuba's state-owned oil and gas company, Unión Cuba-Petróleo (CUPET) under. The sanctions target the Cuban communist government’s systematic diversion and weaponization of energy resources for military use and self-serving kleptocracy while the Cuban public faces severe fuel shortages and blackouts. (Here, the Department of State’s press release)

  • OFAC issued Russia-related General License 55F replacing and superseding GL 55E (dated December 17, 2025) in its entirety. The substance of the license remains the same, i.e., authorizing certain transactions and services ordinarily incident and necessary to the Sakhalin-2 project. The key change is the extension of the authorization's expiration date from June 18, 2026, to December 18, 2026. (Here)

  • OFAC issued Russia-related General License 115D replacing and superseding GL 115C (dated December 17, 2025) in its entirety. The substance of the license remains the same, i.e., authorizing certain transactions ordinarily incident and necessary to civil nuclear energy involving specified blocked Russian financial entities. The key change is the extension of the authorization's expiration date from June 18, 2026, to December 18, 2026. (Here) Furthemore,OFAC amended FAQs 967, 978, 999, 1011, 1117, 1182, 1203, and 1216 to reflect these changes.

  • The U.K. OFSI published new FAQs (188-195) clarifying how UK financial sanctions apply in relation to Transneft and associated activity. These FAQs provide guidance on how relevant prohibitions operate, including when a licence may be required and how firms should approach compliance risks. (Here)


Friday, June 12

  • In a breaking development, the U.S. Department of Commerce issued an emergency export control directive ordering Anthropic to block all foreign nationals including its own overseas employees from accessing its newly released Fable 5 and Mythos 5 models. The order was triggered by national security concerns after Amazon (investor in Anthropic) researchers successfully "jailbroke" Fable 5's safety guardrails to expose software vulnerabilities. Unable to isolate foreign users cleanly, Anthropic disabled both models globally for all customers. (Anthropic’s statement) 

  • FinCEN issued updated guidance and an expanded Fact Sheet modernizing the voluntary information-sharing framework under Section 314(b) of the USA PATRIOT Act. Released in alignment with the White House Task Force to Eliminate Fraud, the framework completely replaces FinCEN’s December 2020 guidance. Key Takeaways for Financial Institutions:

    • Real-Time Sharing & Safe Harbor: The guidance explicitly permits and encourages real-time, point-to-point digital or verbal communications to verify suspicious accounts instantly. Doing so triggers a statutory safe harbor protecting institutions from civil liability under privacy laws.

    • Fraud Covered under SUAs: FinCEN clarified that because most significant fraud schemes constitute Specified Unlawful Activities (SUAs) that generate illicit proceeds, sharing information to detect or prevent fraud falls squarely within the 314(b) safe harbor. Conclusive proof of a money laundering scheme is not required to initiate an exchange.

    • Operationalizing Shared Data: Institutions may actively use data acquired via 314(b) to make immediate, proactive account-management decisions—including whether to block transactions, close accounts, or onboard new customers.

    • Internal Collaboration: While institutions must register at least one central point of contact (POC) with FinCEN, the guidance clarifies that other internal employees, fraud units, and departments may actively participate in the information exchange under internal policies.

    • Strict Purpose Limitations: Shared data must be securely safeguarded and used strictly for AML/CFT compliance and fraud detection. Utilizing 314(b) data for commercial purposes or general credit-worthiness underwriting remains strictly prohibited. (Here, the Department of the Treasury’s press release)


Recommendation of the Week

  • The European Union Court of Justice issued its judgment in the sanctions-related case C‑81/24 (LH v OTP banka d.d). See more about this case which discusses whether mere inclusion on an OFAC list is a sufficient ground to deny basic banking products in Europe under relevant EU directives. (Here) 

  • As the pressure on the shadow fleet mounts, last week there were two notable developments that are worth your attention: 

    • DoJ announced that Avtandil Kalandadze, 47, the former ship master of a shadow fleet tanker that historically transported Iran- and Venezuela-origin oil for the ultimate benefit of U.S. adversaries, pleaded guilty today in the U.S. District Court for refusing to obey orders from the U.S. Coast Guard during a multi-week pursuit from the Caribbean Sea through to the North Atlantic Ocean. (Here)

    • UK forces intercept a Russian shadow fleet vessel for the first time in the English Channel. The vessel SMYRTOS was boarded by Royal Marine Commandos and specially trained law enforcement officers from the National Crime Agency. (Here)

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