top of page

Last Week's Major Developments in Sanctions - May 18 to May 22, 2026

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

Monday, May 18

  • The EU Council renewed the EU’s sanctions regime targeting individuals and entities linked to the former al-Assad regime in Syria until June 1, 2027 (Here and press release)

  • OFAC announced a $275 million settlement with Adani Enterprises Limited (AEL), an Indian company, over apparent violations of U.S. Iran sanctions. Between November 2023 and June 2025, AEL allegedly imported 35 shipments of Iranian-origin LPG through a Dubai-based intermediary that falsely claimed the cargo originated in Oman or Iraq. OFAC found that AEL caused U.S. financial institutions to process 32 USD-denominated payments worth approximately $192.1 million linked to the shipments, in violation of the Iranian Transactions and Sanctions Regulations (ITSR). OFAC indicated that multiple red flags were overlooked, including suspicious vessel activity, falsified shipping documents, implausible cargo origins, and pricing significantly below market rates. (Here, enforcement action notice and press release). 

  • The U.S. Department of State imposed blocking sanctions against nine individuals and one entity (all in Cuba) under its Cuba sanctions regime. These sanctions target Cuban regime elites, government organizations, government officials and, military figures associated with Cuba’s security apparatus that are responsible for or have been involved in repressing the Cuban people. (Here, the Department of State’s fact sheet and the Department of State's press release)

  • OFAC issued General License 134C, extending by one month the authorization for transactions related to the delivery and offloading of Russian-origin crude oil and petroleum products loaded onto vessels by April 17 2026. The authorization, previously set to expire on May 16 under GL 134B, will now remain in effect until June 17 2026. The scope of permitted activity and existing restrictions, including prohibitions involving Iran, North Korea, Cuba, and occupied regions of Ukraine remains unchanged. (Here)


Tuesday, May 19

  • The UK Export Control Joint Unit (ECJU) updated the Military End-Use Controls (MEUC) guidance to improve understanding of the regulations for exporters. Updates include updated lists of embargoed destinations, typical exports impacted by MEUC, refreshed case studies and further information often covered in engagement. (Here)

  • OFAC imposed blocking sanctions against four individuals (three in Iran, one in Turkey), 28 entities (nine in Hong Kong, six in Marshall Islands, three in UAE, two in Panama, two in UK, two in Liberia, one in China, and one in Saint Kitts and Nevis), and 19 vessels (five flagged in Panama, two flagged in Hong Kong, two flagged in Palau, two in flagged Gabon, two flagged in Cameroon, one flagged in Barbados, one flagged in San Marino, one flagged in Vanuatu, one flagged in Cook Islands, one flagged in Comoros and, one flagged in Sierra Leone) under the Iran sanctions regime, targeting Iran's shadow banking network and shadow fleet. At the center of the action is Amin Exchange (formally Ebrahimi and Associates Partnership Company), an Iran-based foreign currency exchange house that has facilitated hundreds of millions of dollars in transactions for sanctioned Iranian banks and petrochemical exporters. Eight front companies linked to Amin Exchange's financial and sanctions evasion activities were designated alongside 19 shadow fleet shipping companies and their associated vessels, which have collectively transported millions of barrels of Iranian oil, naphtha, LPG, methanol, and petrochemicals since as early as 2023. (Here, the Department of the Treasury’s press release and the Department of State's press release)

  •  OFAC also imposed blocking sanctions against eight individuals (three in Turkey, two in Spain, one in Jordan, one in Belgium, one in Egypt) and one entity (one in Gaza) under its counter-terrorism sanctions for their involvement with the flotilla going to Gaza, Hamas, or Muslim Brotherhood.  (Here, the Department of the Treasury’s press release and the Department of State's press release)

  • The UK Government published the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 amending several parts of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Regulations“). The new regulations introduce certain new trade prohibitions and expand existing controls including:  

    • Import-related restrictions on both the import into the UK of refined oil products processed outside Russia from Russian-origin crude oil, and on the import/acquisition of Russian/Russian-origin uranium; 

    • Export-related restrictions on a range of goods including industrial products, chemicals, metals, carbon fibre, and items related or ancillary to quantum, AI, semiconductor, and engineering biology technologies; 

    • Sanctions on construction services and on maritime services relating to Russian Liquefied Natural Gas (“LNG“); and 

    • Additional shipping sector sanctions. 

  • Concurrently, the UK government issued two general trade licences under the Russia (Sanctions) (EU Exit) Regulations 2019. Both licences take effect on May 20 2026. To find out more about the UK changes visit this update from the Bakermckenzie team. 

    • General trade licence: sanctioned processed oil products (licence number: GBSAN0004) (Here)

    • General trade licence: maritime transportation of liquefied natural gas (Here)

  • OFSI published a penalty notice imposing £165,000.00 on Deutsche Bank AG London Branch (DBLB), a branch of Deutsche Bank AG. The penalty was imposed for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019, namely regulation 12 which prohibits (among other conduct) making funds available to a person owned or controlled by a designated person. DBLB processed two payments (one in June 2022 and another in July 2022) totalling £635,618.75 on behalf of a customer to a beneficiary, Okko LLC, a company wholly owned by the designated person JSC New Opportunities. (Here)


Wednesday, May 20 

  • OTSI added 'Construction', 'Services related to specified ships' and 'Procurement of services related to specified ships' to the list of services under 'Apply for a licence from OTSI' heading in line with legislative changes that came into effect on May 19 2026. (Here)  

  • OFAC imposed blocking sanctions against eleven individuals (all in Mexico) and two entities (both in Mexico) under the Global Terrorism and Illicit Drugs sanctions programs targeting two distinct Sinaloa Cartel-linked fentanyl trafficking and money laundering networks. (Here, the Department of the Treasury’s press release and the Department of State's press release)

  • Following the court order (see last week if you missed that) regarding the designation of Francesca Albanese, OFAC removed her name from the SDN list. (Here)


Thursday, May 21 

  • OFAC imposed blocking sanctions against nine individuals (eight in Lebanon, one in Lebanon/Iran) under the Counter Terrorism sanctions program, targeting Hizballah-aligned officials embedded across Lebanon's parliamentary, military, and security institutions who are actively obstructing the Lebanese government's peace process and Hizballah disarmament efforts. (Here, the Department of the Treasury’s press release and the Department of State's press release)


Friday, May 22 

  • The EU Council decided to extend the scope of EU’s restrictive measures originally established to address Tehran’s military support for Russia’s war of aggression against Ukraine and various armed groups in the Middle East and the Red Sea region. The amended sanctions framework will now also target individuals and entities involved in Iran’s actions and policies threatening the freedom of navigation in the Middle East. (Decision, and press release)

  • The EU Commission published nine FAQs about sale of tankers and two related to targeted vessels under its Russia sanctions regime. (Here, and here) 


Recommendation of the Week

  • Check out this article from the Journal about licenses issued for scrapping sanctioned vessels: U.S. Clears Scrap Dealer to Buy Ships Sanctioned for Iran Activity

  • Check out this decision from the Court of Justice of the European Union that establishes that asset freezes applied to trust-held assets are fully compatible with EU law. Key takeaways from this decision :

    • "Belonging to" and "control" are interpreted broadly—no formal legal link required; actual power or influence over assets is sufficient.

    • Both settlors and beneficiaries can be caught if they can use, benefit from, or influence decisions over the assets

    • Ownership can be inferred from factual circumstances or the presence of unnecessarily complex legal structures.

  • Don't forget to check Sanctrust.com - Sanctrust is the new firm that the founder of SanctionsExpert.com created to provide all sorts of services related to sanctions and export controls. Their focus areas are:

    • The use of AI in sanctions and export controls compliance;

    • Reviewing and auditing the work done by agents;

    • Helping entities in higher risk jurisdictions at a reasonable cost;

    • Elevating compliance programs to a level that is acceptable by top-tier banks in the United States.

bottom of page