top of page

Last Week's Major Developments in Sanctions - March 16, 2026, to March 20, 2026

  • 7 hours ago
  • 4 min read
You can now listen to the audio version of our weekly sanctions updates here.
Before we jump into this week’s issue, I have an exciting update: I’m building a new solution for the sanctions space that’s truly revolutionary. This will supercharge your sanctions compliance function. We’re leveraging decades of sanctions expertise and the power of AI. So far, we’ve been getting great feedback from the community. If this resonates, I’d love to chat with you. Just send an email to info@sanctionsexpert.com. Sharing more soon!

Monday, March 16

  • This week started with several sanctions related to the EU. The EU Council adopted:

    • Council Decision (CFSP) 2026/588 amending Decision (CFSP) 2019/797 concerning restrictive measures against cyber-attacks threatening the Union or its Member States. This decision imposed asset-freezing sanctions against two individuals and three entities. Both sanctioned individuals and two of the sanctioned entities are in China; the last sanctioned entity is located in Iran. (Here, and press release)

    • Council Decision (CFSP) 2026/614 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. This decision imposed asset-freezing sanctions against nine individuals who were allegedly involved in the Bucha massacre.(Here, and press release)

    • Council Decision (CFSP) 2026/646 amending Decision (CFSP) 2024/2643 concerning restrictive measures in view of Russia’s destabilising activities. This decision imposes asset-freezing sanctions against four individuals who were allegedly involved in information manipulation activities. (Here, and press release)

    • Council Implementing Decision (CFSP) 2026/645 implementing Decision 2011/235/CFSP concerning restrictive measures directed against certain persons and entities in view of the situation in Iran. This decision imposed asset-freezing sanctions against 16 individuals and three entities over alleged serious human rights violations. (Here, and press release)

  • Also, over the weekend, Council Decision (CFSP) 2026/696 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine was published. This decision extended parts of the EU sanctions against Russia for another six months until September 15, 2026. (Here, and press release)


Tuesday, March 17

  • OFSI published an updated version of its guidance on the Central African Republic sanctions regime for better clarity and usability and to reflect some recent changes in the relevant regulations.(Here)

  • OFAC announced that TradeStation Securities, Inc. has agreed to pay $1,110,661 to settle its potential civil liability for 481 apparent violations of OFAC sanctions programs arising from TradeStation’s provision of brokerage and investment services to persons in Iran, Syria, and Crimea, between June 2021 and June 2022. This enforcement action is the most IP-focused public enforcement action announced by OFAC. If you do not have decent controls around IP blocking, it is time to think hard about them. (Here)


Wednesday, March 18

  • OFAC issued Venezuela-related General License 52, "Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A." This General License authorizes established U.S. entities to engage in transactions with PdVSA and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest, subject to its conditions and exclusions. Additionally, OFAC is issuing two new Venezuela-related Frequently Asked Questions, FAQ 1245 and FAQ 1246 in relation to this new General License. (Here)

  • OFAC removed three individuals and four entities from the SDN list that were designated under the Russia sanctions program of the United States. The removed entities were in Turkey and the UAE. (Here)


Thursday, March 19

  • For the 21st time, OFAC revised the General License to postpone the authorization related to transactions involving a certain bond issued by the PdVSA, this time until May 5, 2026. (Here)

  • OFSI issued General License INT/2026/9247168 related to Kazakh Oil Exports involving Transneft. (Here)

  • In and AML-related development, FinCEN published frequently asked questions and responses regarding its recently issued Geographic Targeting Order, aimed at further combating the illicit activities and money laundering of Mexico-based cartels and other criminal actors along the southwest border of the United States. (Here)

  • OFAC issued Russia-related General License 134A, which revised General License 134, which authorized the the delivery and sale of crude oil and petroleum products of Russian Federation origin loaded on vessels as of March 12, 2026, by explicitly mentioning that the General License does not authorize any transaction involving a person located in or organized under the laws of the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, the Covered Regions of Ukraine, as defined by E.O. 14065, the Crimea Region of Ukraine, as defined by E.O. 13685, or any entity that is owned or controlled by or in a joint venture with such persons. (Here)

Friday, March 20

  • OFAC imposed blocking sanctions on ten individuals and six entities for being part of a network that allegedly has financed Hizballah under the counter-terrorism program of the United States. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • Three individuals were sentenced in a U.S. federal court after pleading guilty to one count of Wire Fraud Conspiracy for their roles in a nationwide scheme that enabled North Korean workers to access U.S.-based computer networks. The sentences included a 12-month prison term and a $193,265 forfeiture for Alexander Paul Travis, alongside forfeitures of $409,876 for Jason Salazar and $681,926 for Audricus Phagnasay. (Here)

  • OFAC issued General License U under its Iran sanctions program authorizing all transactions that are ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Iranian origin loaded on any vessel, including vessels blocked, on or before March 20, 2026. (Here) To see rationale behind this unexpected license check out this post from Secretary Bassent. Here is an excerpt of his argument: "At present, sanctioned Iranian oil is being hoarded by China on the cheap. By temporarily unlocking this existing supply for the world, the United States will quickly bring approximately 140 million barrels of oil to global markets, expanding the amount of worldwide energy and helping to relieve the temporary pressures on supply caused by Iran. In essence, we will be using the Iranian barrels against Tehran to keep the price down as we continue Operation Epic Fury."


Recommendation of the Week

  • If you are in NYC, come say hi at the latest ACSS event, the Evolving Sanctions Landscape: Current Developments and Emerging Risks, this Thursday, March 26. Click here to register.

bottom of page