Last Week's Major Developments in Sanctions - May 11 to May 15, 2026
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Monday, May 11
The EU Council adopted Council Decision (CFSP) 2026/1072 and imposed asset freezing sanctions on 16 persons and seven entities responsible for the systematic unlawful deportation and forcible transfer of Ukrainian children to the Russian Federation and within temporarily occupied territories. (Here, and press release)
The EU Council, in a non-substantive move, extended its sanctions regime against cyber-attacks threatening the Union or its Member States for another year, through May 18, 2027. (Here)
OFSI imposed asset freezing sanctions on nine individuals and three entities under its Iran sanctions Regime. (Here and press release)
Furthermore, OFSI imposed asset freezing sanctions on 63 individuals and 22 entities under its Russia sanctions regime. (Here and press release)
OFAC imposed blocking sanctions on three individuals (all in Iran) and nine entities (four in Iran, four in Hong Kong, and one in Oman) under its Iran Sanctions program and Specially Designated Global Terrorist Sanctions programs for their roles in enabling Islamic Revolutionary Guard Corps’s (IRGC) shadow network to sell and ship Iranian oil, primarily to China. (Here, the Department of the Treasury's press release, and the Department of State's press release)
In two AML-related developments:
FinCEN issued an alert warning financial institutions about the IRGC's use of front companies, shadow banking networks, shipping intermediaries, and digital assets to evade sanctions and launder proceeds linked to oil smuggling, weapons procurement, and terrorist financing. The alert highlights typologies involving “shadow fleet” vessels, falsely labeled oil cargoes, opaque offshore trading structures, exchange houses, and increasing use of stablecoins and digital asset service providers (DASPs) to move funds outside the traditional financial system. FinCEN urged institutions to apply heightened due diligence on transactions including those referring to “Malaysian blend oil”, those involving company types that are at high risk for IRGC abuse, and for those companies using digital assets to effect significant payments for Iranian oil. FinCEN also requested that (1) related SARs include the term “FIN-2026-Alert002;” and, (2) select SAR field 33(a) for terrorist financing. (Here, and press release)
FinCEN issued a Notice on the Threat of Human Trafficking During the 2026 FIFA World Cup. Some key takeaways for financial institutions are:
FinCEN is warning that the 2026 FIFA World Cup will likely increase risks of both sex trafficking and labor trafficking due to higher tourism, hotel demand, temporary labor needs, and cash flows around host cities.
Financial institutions, especially those operating in or near host cities, are expected to increase monitoring and vigilance for suspicious activity linked to trafficking.
Frontline banking staff are specifically encouraged to watch for behavioral indicators because victims may only interact with outsiders during visits to financial institutions.
FinCEN emphasizes that human trafficking is a major AML/CFT priority and is frequently linked to Transnational Criminal Organizations (TCOs).
Banks should file Suspicious Activity Reports (SARs) as soon as possible for suspected trafficking activity related to the World Cup, regardless of transaction threshold. SARs should (1) include the keyword “FIN-2026-HTWORLDCUP;” and, (2) select SAR field 38(h) for human trafficking.
FinCEN also strongly encourages information sharing under Section 314(b) of the USA PATRIOT Act, including cross-border information sharing with foreign financial institutions.
The Notice also sets out several red flag indicators including rapid movement of funds between ATMs and P2P platforms, Sequential P2P transfers that may indicate illicit massage business payments, etc. (Here, and press release)
In a sanctions adjacent action, the EU Council repealed Decision 2011/523/EU which had partially suspended the 1977 Cooperation Agreement between the European Economic Community and the Syrian Arab Republic. The now repealed decision suspended imports from Syria into the Union of crude oil, petroleum products, gold, precious metals, and diamonds in line with then-in-place EU sanctions. (Decision, and press release)
Tuesday, May 12
Australia imposed asset freezing sanctions against seven individuals and four entities under the Ausitralia's autonomus sanctions regime against Iran. Some of the targets were the same as the ones included in May 11th action by OFSI. (Here, and press release)
OFSI implemented some changes made to the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 which have now come into force. (Here) Key changes to note are:
Changes in the requirement of reporting from euros to pounds (Euro thresholds are replaced with Pound thresholds, aligning the reporting obligations with upcoming changes to UK money laundering regulations);
OFSI and other authorities can now send electronic notices for license;
A clarification that the exception for Treasury debt applies to all transfers of funds across the entire payment chain, including intermediaries;
OFSI now has greater flexibility to license legitimate pre-designation obligations in some cases while maintaining safeguards against sanctions circumvention; and
FAQs 137-138 updated and FAQ 185 added. (Here)
Wednesday, May 13
The U.S. District Court for the District of Columbia granted a motion for a preliminary injunction in favor of the daughter and the husband of Francesca Albanese, the Special Rapporteur on the situation of human rights in the Palestinian territory occupied since 1967. (Here) The plaintiffs had motioned the court to request the U.S. government to remove Francesca Albanese as a Specially Designated National and Blocked Person and enjoin Defendants from enforcing Executive Order 14203 against Plaintiffs and Francesca Albanese. (Here)
The UK Export Control Joint Unit issued a Notice to Exporters 2026/13 rolling out a new requirement for exporters using Open General Export Licences (OGELs) and General Export Authorizations (GEAs) to declare their unique licence reference (format: GBOGE20XX/XXXXX) in box 44 of the UK Customs Declarations System (CDS), bringing them in line with Standard Individual Export Licenses (SIELs) and Open Individual Export Licenses (OIELs). (Here)
Thursday, May 14
There was no major development on this day.
Friday, May 15
In the wake of the May 13 court order, OFAC published notice with regard to its International Criminal Court-Related Sanctions, on its International Criminal Court-Related Sanctions Program page. The notice reads as follows: "Alert: Ongoing Litigation - L.C. et al. v. Trump et al., No. 1:26-cv-688 (D.D.C.). On May 13, 2026, in L.C. et al. v. Trump et al., No. 1:26-cv-688 (D.D.C.), the U.S. District Court for the District of Columbia issued an order enjoining the U.S. Department of State, U.S. Department of the Treasury, and U.S. Department of Justice, as well as their “officers, agents, servants, employees, attorneys, and all other persons in active concert” with them, from, among other things, implementing or enforcing the designation of Francesca Albanese as a designated foreign national under Section 1(a)(ii)(A) of Executive Order 14203. The designation of Francesca Albanese is not being implemented or enforced while this order remains in effect."
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