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Last Week's Major Developments in Sanctions - March 9, 2026, to March 13, 2026

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

Monday, March 9

  • The U.S. Department of State designated the Sudanese Muslim Brotherhood as a Specially Designated Global Terrorist (SDGT). The group was also designated as a Foreign Terrorist Organization (FTO), effective March 16, 2026. The armed wing of the Sudanese Muslim Brotherhood, the al-Baraa Bin Malik Brigade, which was previously designated under the Sudan and Darfur sanctions program of OFAC, was also designated as a SDGT and FTO. (Here, the Department of State's press release, the Department of State's fact sheet)

  • The U.S. Department of State designated Afghanistan as a State Sponsor of Wrongful Detention. This designation can lead to additional sanctions under Executive Order 14078. (The Department of State's press release)

  • Following the removal of Al-Nusrah Front for the People of the Levant (aka Hay'at Tahrir al-Sham) on 27 February 2026, by the relevant Sanctions Committee of the United Nations Security Council, the EU Council removed HTS from the list of sanctions targets in the EU. (Here)


Tuesday, March 10

  • The UK government published its strategic approach to sanctions enforcement. The document emphasizes the importance of enforcement of sanctions for the UK government. Moreover, it clearly states the roles and responsibilities of different agencies within the UK government. I highly recommend reading the entire document. (Here)

  • FinCEN issued an expanded Geographic Targeting Order (GTO) to help law enforcement combat the illicit activities and money laundering of Mexico-based cartels and other criminal actors along the southwest border of the United States. The GTO subjects certain money services businesses—which provide financial services outside of a formal bank—to enhanced reporting requirements with FinCEN. (Here)


Wednesday, March 11

  • France imposed asset freezing sanctions against one individual under its autonomous counter-terrorism sanctions regime. (Here)

  • OFSI revised 35 of its regime-specific guidance documents for better clarity and usability. (Here) While most of these updates did not change anything substantively, the guidance documents for countering Russian sanctions evasion and circumvention and Haiti Sanctions had some substantive updates. Countering Russian sanctions evasion and circumvention guidance was updated to reflect changes to the UK goods at higher risk of circumvention, and the list of third country exporters. The Haiti Sanctions guidance was updated to reflect changes made by UN Security Council Resolution 2794 (2025) and Haiti (Sanctions) (Amendment) Regulations 2025.


Thursday, March 12

  • OFAC imposed blocking sanctions against six individuals (four in Vietnam, one in Spain, and one in North Korea) and two entities under its North Korea and counter-proliferation sanctions programs for their roles in DPRK government-orchestrated IT worker schemes. (Here, the Department of the Treasury's press release, and the Department of State's press release) Included in this designation package were several digital currency addresses including in Ether, TRON, and Bitcoin.

  • OFAC imposed blocking sanctions on four entities under its counter-terrorism sanctions program for allegedly acting as NGOs funneling funds to Hamas’s Military Wing and its terrorist activities militants and enable the group to sustain its terrorist operations. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFAC issued Russia-related General License 134, "Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026." This General License authorizes all transactions prohibited under several programs that are ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Russian Federation origin loaded on any vessel, including vessels blocked under the above listed authorities, on or before 12:01 a.m. eastern daylight time, March 12, 2026 through 12:01 a.m. eastern daylight time, April 11, 2026. (Here) Note that this General License does not allow transactions related to crude oil or petroleum products that were loaded after the give time on March 12. So, despite how some people framed it as a very broad authorization, it is not in my opinion.


Friday, March 13

  • The EU Commission published 13 updated new FAQs on the provision of payments services concerning sanctions adopted following Russia’s military aggression against Ukraine. (Here)

  • OFSI published an online form for "relevant persons" under the UK sanctions to notify OFSI when they engage in certain humanitarian activities in relation to Syria that involves petroleum products. (Here)

  • OFAC issued Venezuela-related General License 46B, "Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;" Venezuela-related General License 48A, "Authorizing the Supply of Certain Items and Services to Venezuela;" and Venezuela-related General License 49A, "Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela." Additionally, OFAC amended FAQ 1226 and FAQ 1227. (Here)


Recommendation of the Week

  • ICYMI: Take a look at the U.S. 2026 National Money Laundering Risk Assessment.

  • Sanctionsexpert is collaborating with Sanctrust, an AI-native sanctions-focused firm, to explore sanctions compliance pain points and needs. If you are interested in sharing your pain points with the hope that someone finally builds a solution to solve them, you can book 30 minutes with Sanctrust (book here) or send an email toinfo@sanctionsexpert.com

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