Last Week's Major Developments in Sanctions - March 23, 2026, to March 27, 2026

---

You can now listen to the audio version of our weekly sanctions updates here.

---

Monday, March 23

• OFSI published a new guidance document titled "How to use exceptions and licenses to comply with sanctions." The guidance explains the difference between exceptions and licenses under the UK sanctions regulations. (Here)

Tuesday, March 24

• OFAC issued Venezuela-related General License 53, "Official Missions of the Government of Venezuela to the United States." This General License authorizes all transactions related to the provision of goods or services in the United States to official

  missions of the Government of Venezuela to the United States or to permanent missions of the Government of Venezuela to international organizations in the United States provided certain conditions are met. (Here)

Wednesday, March 25

• OFSI undertook a welcome effort in updating its sanctions guidance documents for each of its sanctions regime by adding a summary of the regime’s purposes, scope and prohibitions. (Here)

Thursday, March 26

• OFSI imposed asset freezing sanctions against six individuals and four entities under its Global Human Rights sanctions regime for being part of the network of illegal scam centers across Southeast Asia. (Here, and press release)

• OFAC announced actions to ease some of the sanctions imposed on Belarus. (Here) Specifically:

  • Removed 20 entries designated under Belarus sanctions from the SDN list;

  • Issued General License 14 which authorizes transactions involving Belarussian Bank of Development and Reconstruction Belinvestbank Joint Stock Company and Limited Liability Company Belinvest-Engineering, and CJSC Belbizneslizing; and

  • Rescinded Directive 1 under Belarus sanctions which had prohibited transactions with respect to the Ministry of Finance of the Republic of Belarus and the Development Bank of the Republic of Belarus.

Friday, March 27

• OFSI updated General License INT/2023/2824812 by extending its validity through 26 March 2028. (Here)

• OFSI imposed blocking sanctions against two individuals under the UK's ISIL (Da’esh) and Al-Qaeda sanctions regime. (Here)

• OFAC issued three new Venezuela-related general licenses, continuing its rapid expansion of sanctions relief into Venezuela's minerals sector. (Here)

  • GL 51A (amended from GL 51, issued March 6) authorizes established U.S. entities to export, resell, store, and transport Venezuelan-origin minerals, including gold. Compared to the original, GL 51A adds an explicit prohibition on transactions involving China-connected entities, extending the existing Russia/Iran/North Korea/Cuba carveout, and separately bans the processing or refining of Venezuelan-origin minerals in any of those five countries. Payments to blocked persons must be routed to the Foreign Government Deposit Funds per EO 14373. Reporting to both State and DOI is required within 10 days of the first transaction and every 30 days thereafter.

  • GL 54 authorizes U.S. persons to supply goods, technology, software, and services for minerals operations in Venezuela. Reporting is due within 10 days of the first transaction and every 90 days thereafter. Formation of new joint ventures in Venezuela is not authorized.

  • GL 55 authorizes the negotiation and execution of contingent contracts for new investment in Venezuela's minerals sector, provided actual performance requires a separate OFAC authorization.

Recommendation of the Week

• This week recommendation is a March 12 judgment from the Court of Justice of the EU, the EM System matter. The case arose when two Lithuanian banks froze the assets of EM System, a Lithuanian company not on any sanctions list, solely because a Belarus-sanctioned individual held a 50% stake in it. The company challenged the freeze, and the case reached the CJEU on a preliminary ruling from Lithuania's Supreme Court. The Court held that funds and economic resources of a company not on the sanctions list may still be frozen if they are owned, held, or controlled by a listed person, and that a 50% shareholding creates a presumption of control sufficient to justify a freeze. European Court of Justice The concepts of "held" and "controlled" are to be read broadly, covering both direct and indirect means of influence.