Last Week's Major Developments in Sanctions - May 25 to May 29, 2026

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Monday, May 25

There was no major development on this day.

Tuesday, May 26

The EU Council adopted Decision (CFSP) 2026/1149, amending Decision (CFSP) 2024/1484 concerning restrictive measures in view of the situation in Russia. The decision does two things: first, it renews the existing measures for a further year until May 28, 2027; and second, it updates the identifying information and statements of reasons for seven already-listed individuals (all Russian judges and prosecutors) originally designated in connection with the persecution of Alexei Navalny. The updated entries reflect changes in their current positions. (Here and press release)
The EU Council adopted Decision (CFSP) 2026/1157, amending Decision (CFSP) 2023/1532 to expand the scope of the EU's existing Iran-related sanctions regime. The key change is the addition of a new designation ground covering persons and entities responsible for, supporting, implementing, or benefitting from Iran's actions or policies undermining the freedom of navigation in the Middle East, specifically referencing Iran's imposition of tolls on vessels transiting the Strait of Hormuz, which the EU considers contrary to international law. The decision also updates the title of the underlying 2023 decision to reflect this expanded scope. No new designations were made at this stage; the decision is a legal framework expansion, enabling the EU to impose asset freezes and travel bans on individuals and entities connected to Iran's interference with freedom of navigation. (Here, and press release)
The UK government imposed asset freezing sanctions on four individuals and 14 entities under the Russia (Sanctions) (EU Exit) Regulations, 2019 targeting Russia’s illicit financial infrastructure used to move funds, procure goods, and sustain its war against Ukraine. The sanctions also target certain A7 network links, a Kremlin-backed system designed to bypass Western sanctions, finance military procurement, and process funds from the sale of oil to fund its war economy. (Here and press release)
OFSI amended General Licence INT/2024/4761108 to include a new definition of cryptoasset, and include a new reporting requirement for anyone using cryptoassets to make or receive a payment under the General Licence. (Here)

Wednesday, May 27

Very interestingly, following the removal of Francesca Albanese from the SDN List (see last week if you missed that), OFAC reimposed blocking sanctions on Francesca Albanese under the International Criminal Court sanctions regime. (Here)
OFAC imposed blocking sanctions against the Persian Gulf Strait Authority under the Iran sanctions program and Global Terrorism sanctions program. By doing so under the Global Terrorism sanctions program, the United States increased the risk of engaging with the Persian Gulf Strait Authority for non-U.S. persons. (Here)

Thursday, May 28

The U.S. government imposed blocking sanctions on one individual (in India), 16 entities (nine in Hong Kong, three in UAE, two in Marshall Islands, one in India, one in Qatar, and one in Singapore), and eight vessels (three flagged in Panama, one flagged in Marshall Islands, one flagged in Palau, one flagged in San Marino, one flagged in Comoros, and one flagged in Cameroon) under its Iran sanctions program. The action targets Iran's shadow oil economy, attempting to dismantle the network of front companies, vessel managers, and petrochemical traders that generate revenue for the IRGC and Iran's Armed Forces General Staff. To break it down, OFAC imposed blocking sanctions on five Hong Kong-based front companies linked to Sepehr Energy Jahan Nama Pars Company, the oil sales arm of Iran's Armed Forces, for facilitating tens of millions of barrels of Iranian crude oil exports to China. U.S. Department of State simultaneously targeted eight vessel management companies whose tankers repeatedly transported Iranian petroleum using deceptive shipping practices, and three petrochemical traders alongside one individual for importing and exporting hundreds of millions of dollars' worth of Iranian-origin products. (Here, the Department of the Treasury’s press release, the Department of State's press release and fact sheet)
OFAC issued General License 131F on May 28, 2026, replacing and superseding GL 131E (dated April 29, 2026) in its entirety. The substance of the license remains the same, i.e. authorizing negotiations and entry into contingent contracts for the sale of Lukoil International GmbH (LIG) and its majority-owned subsidiaries, as well as maintenance and wind-down activities of LIG entities. The key change is an extension of the authorization deadline from May 30, 2026 (under GL 131E) to June 27, 2026. Concurrently, OFAC amended FAQs 1224 and 1225 to reflect the updated GL. (Here, FAQ 1224, FAQ 1225)
OFAC removed sanctions on 76 outdated targets, and removed them from the SDN List. The removals were part of Treasury’s ongoing sanctions modernization initiative, which Secretary of the Treasury Scott Bessent recently discussed at the No Money For Terror conference in Paris. The removed entries included deceased individuals, scrapped or decommissioned vessels, persons designated as part of illicit financial networks that no longer exist, and individuals designated more than 10 years ago who lack sufficient identifiers for continued screening and do not appear to pose an ongoing threat. (Here, and the Department of the Treasury’s press release)
The U.S. Department of Justice indicted Mohammad Baqer Saad Dawood Al-Saadi, a dual Iranian-Iraqi national, on eight counts of terrorism-related offenses for his role as a senior operative of Kata'ib Hizballah and the IRGC. Al-Saadi is alleged to have been involved in nearly 20 attacks and attempted attacks across Europe, carried out under the front group Harakat Ashab al-Yamin al-Islamiya, and to have attempted to plan attacks inside the United States, including against a synagogue in New York, as recently as April 2026. Al-Saadi, who described himself as a leader of "the resistance" encompassing the IRGC and its proxies, was detained abroad on May 1 and transferred to FBI custody on May 14. He faces charges carrying maximum penalties ranging from 15 years to life in prison. (Here)
The EU Council adopted Decision (CFSP) 2026/1173, amending Decision (CFSP) 2024/385 to expand the EU's Hamas and Palestinian Islamic Jihad sanctions regime by explicitly adding members of Hamas's Political Bureau (Politburo) as a designated category subject to asset freezes and travel bans. The decision also added 10 Politburo members to the sanctions list. (Here)
In a separate action, the EU Council adopted Decision (CFSP) 2026/1176, amending Decision (CFSP) 2020/1999 (the EU's Global Human Rights Sanctions Regime) to impose asset freezes and travel bans on three individuals and four entities in connection with settler violence and forced displacement of Palestinians in the West Bank and Gaza. (Here and press release)
FCA published the results of its second sanctions-focused review. The report identifies the most common root causes of reported sanctions breaches. To know more about this and get a table of best practices and poor practices identified in the report check out the relevant post from our founder, Amir Fadavi, on Linkedin. (Here)

Friday, May 29

OFSI published a new FAQ 186 on the application of UK financial sanctions to the HTX cryptocurrency exchange. The FAQ explains that, following the UK’s designation of Huobi Global S.A. on 26 May 2026, OFSI considers that the HTX cryptocurrency exchange is subject to UK financial sanctions. (Here)
The U.S. government imposed blocking sanctions on eight individuals (all in Iran) and four entities (two in Iran, and two in UAE) under both Iran and Global Terrorist sanctions programs for being part of a procurement network that impersonated U.S. small businesses to fraudulently procure millions of dollars' worth of restricted goods, including network security and encryption hardware, for Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). OFAC also amended FAQ 1249 which discusses toll being paid to Iran for safe passage through the Strait of Hormuz authorized. (Here, the Department of the Treasury’s press release, the Department of State’s press release, and FAQ 1249)
In a major escalation related to Brazil, the U.S. Department of State is designated Comando Vermelho and Primeiro Comando da Capital (PCC) as Specially Designated Global Terrorists (SDGTs) and intends to designate both groups as Foreign Terrorist Organizations (FTOs), effective June 5, 2026.  PCC was already on the SDN list pursuant to the counter-narcotics sanctions regime of the United States. The new designations have drastically increased the risk of dealing with those groups and the risk associated with Brazil. (Here, and the Department of State press release) To know more, check out this client alert from Akin.
The United States, alongside Australia, Canada, France, Germany, Italy, Japan, New Zealand, South Korea, the United Kingdom, and the European External Action Service issued a joint statement welcoming the April 30 Open Source Centre briefing to the UN Security Council on DPRK maritime sanctions evasion. The statement identified five vessels as having recently engaged in violations of UN Security Council resolutions prohibiting the export of DPRK coal and iron ore: Dream Wave, Peaceful 8, Orion, Fu Run Da 1, and Ostrov Antsiferova. The signatories also called on the UN Security Council's 1718 Committee to swiftly designate seven additional vessels nominated in December 2025 that remain pending: Flyfree, Casio, Mars, Cartier, Sophia/Prada, Armani, and Yi Li 1, noting that prompt designations are essential to preserving the credibility of the UN sanctions regime. (Department of State’s press release)
The UN Security Council adopted Resolution 2821 (2026) extending for one year the sanctions imposed on South Sudan, including asset freezes, travel bans and an arms embargo amid concerns expressed by some speakers that the African position on the issue is being overlooked and that sanctions are hindering progress towards lasting peace. (Here and UNSC press release)
France imposed asset-freezing sanctions against one individual under France's autonomous counter-terrorims sanctions regime. (Here)

Recommendations of the Week

Check out this guest article by Catherine M. Woods that offers an analysis of the Figueira professional crypto laundering and sanctions evasion indictment: Green and White Money
If you are in NYC this week, you can attend ACSS’s NYC chapter event where you will hear about recent cartel and counter-narcotics sanctions developments: Register Here!