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Last Week's Major Developments in Sanctions - March 30, 2026, to April 3, 2026

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

Monday, March 30

  • OFAC issued amended Russia-related General License 131D under Russian Harmful Foreign Activities Sanctions Regulations, which extended General License 131C for one more month through May 1, 2026. As a reminder, this General License authorizes certain transactions pertaining to the negotiation of and entry into contingent contracts for the sale or transfer of Lukoil International GmbH or any of its affiliates and related maintenance activities. OFAC also updated FAQ 1224 and 1225 to reflect the new GL.  (Here, press release, FAQ 1224, FAQ 1225)

  • The EU Council renewed restrictive measures imposed on Bosnia and Herzegovina (originally imposed through Decision 2011/173/CFSP in view of the security situation in Bosnia and Herzegovina) until March 31, 2027. (Here, and press release) 

  • The EU Council extended EU restrictive measures on Iran until April 13, 2027 responding to serious human rights violations in Iran. (Here, Press release) 

  • UNSC ISIL (Da’esh) and Al-Qaida Sanctions Committee added one individual to its list of sanctions. (Here) 

  • The UK Export Control Joint Unit (ECJU) issued a Notice to exporters 2026/09 introducing a change to the way the ECJU assesses and processes amendment requests for Open Individual Export Licences (OIELs). (Here) 

  • OFSI announced a settlement agreement for £390,000 with Apple Distribution International, an Irish Subsidiary of Apple Inc., for violating UK sanctions against Russia. Specifically, the Irish subsidiary of Apple, a non-UK person, instructed a UK-based bank to make two payments, one in June 2022 and another in July 2022, totalling £635,618.75 to Okko LLC, a company wholly owned at the time of the payments (and in the case of the July payment also at the time of payment instruction) by the designated person JSC New Opportunities. Following the introduction of a new enforcement framework on February 9, 2026, that enabled OFSI to settle penalty cases, this is the first time OFSI settles a case. Another interesting fact about this case is the fact that OFSI used its relatively new strict liability basis to establish two breaches. Lastly, this case involves a non-UK person that used a UK financial institution to pay a sanctioned party. It appears that OFSI considers this a conduct in the UK and as such asserted jurisdiction over this payment. (This sounds very similar to the notion of “causing to breach” under the U.S. sanctions.) (Here)

  • FinCEN issued a notice of proposed rule to establish a whistleblower program that offers incentives and protections to encourage individuals who have information about potential violations of the Bank Secrecy Act (BSA), International Emergency Economic Powers Act (IEEPA), Trading With the Enemy Act of 1917 (TWEA), and Foreign Narcotics Kingpin Designation Act (Kingpin Act) to voluntarily report such information. The notice is open to public comments till June 1, 2026. (Here, and press release) 

  • The Department of Justice announced a guilty plea related to a conspiracy to export U.S. made ammunition to Russia via Kyrgyzstan. (Here) 

  • The Department of Justice’s National Security Division issued a press release regarding the recently issued department-wide corporate enforcement policy and the importance of voluntary self-disclosures under the new policy. (Here)


Tuesday, March 31

  • OFAC issued a new Venezuela-related FAQ 1247 clarifying certain conditions imposed under GLs 46B, 51A, or 52 which authorize established U.S. entities to engage in certain transactions involving Petróleos de Venezuela, S.A. (PdVSA), Venezuelan-origin oil petrochemical products, or minerals, (Here, press release) 

  • OFAC issued a sanctions advisory to highlight sanctions risks arising from sham transactions used to evade sanctions and to identify factors to consider when evaluating whether property may be the subject of a sham transaction. (Here) This advisory sheds light on Sham transactions, which occur when blocked persons, often operating through proxies or other intermediaries, effectuate transfers or establish arrangements that conceal—rather than genuinely extinguish—a continuing interest in property. This advisory helps explain the last December enforcement action against an individual. 

  • OFAC removed 13 Counter Narcotics and three Russia-related designations from the SDN List. (Here) 

  • OFSI amended General License INT/2022/2300292 to permit all forms of utility payment, including cash. (Here) OFSI also amended General License INT/2022/2009156 to allow designated persons to make Insurance Premium Finance repayments to UK intermediaries in addition to insurers or brokers. (Here)

Wednesday, April 1

  • OFAC removed Delcy Rodriguez, the acting president of Venezuela, from the SDN List. (Here)

  • The UK's ECJU issued an updated document 'General trade licence Russia sanctions: sectoral software and technology' and the previous version of the general trade license was revoked. (Here)


Thursday, April 2

  • There was no major development on this day. 


Friday, April 3

  • OFAC removed one individual, who was listed under Russia sanctions program, from the SDN List (Here) 


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