Last Week's Major Developments in Sanctions - May 4 to May 8, 2026

OFAC issued Venezuela-related General License 5W, "Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 Percent Bond on or After June 19, 2026.” Once again OFAC delayed when U.S. persons could engage with the PdVSA named bond; this time to June 19, 2026. (Here) OFAC accordingly revised Venezuela-related FAQ 595. (Here)

OFAC imposed bOFAC issued Venezuela-related General License 58, "Authorizing Certain Services to the Government of Venezuela in Connection with Potential Debt Restructuring." authorizing legal, financial advisory, and consulting services to the Government of Venezuela and PdVSA in connection with potential debt restructuring of the Government of Venezuela and PdVSA entities. The license also restricts involvement of certain jurisdictions (Russia, Iran, China, North Korea, and Cuba) and requires reporting of service contracts to the U.S. Government. (Here)
OFSI imposed asset-freezing sanctions on 12 individuals and five entities under the Global Irregular Migration sanctions regime. (Here) Additionally, OFSI imposed asset-freezing sanctions against 10 individuals and 8 entities under the Russian sanctions regime targeting the production of Russian drones and nefarious networks responsible for human trafficking networks, funneling exploited migrants into Russia’s war against Ukraine. (Here, and press release)

Two U.S. nationals were sentenced to 18 months in prison for facilitating fraudulent remote IT worker schemes that enabled North Korean operatives to pose as U.S.-based employees, infiltrate company networks, and generate over $1.2 million in illicit revenue for the DPRK. (Here)

OFAC imposed blocking sanctions against four individuals and four entities (all based in Iraq) under its Iran Sanctions program, targeting an Iraqi oil official and senior leaders of Iran-aligned militias. The action focuses on individuals facilitating the diversion of Iraqi oil to benefit Iran and its proxy groups, as well as militia leaders involved in oil smuggling, weapons procurement, and terrorist financing. (Here, the Department of the Treasury's press release, and the Department of State's press release)
The U.S. Department of State designated two entities and one individual pursuant to the recently-issued Executive Order 14404, Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy. Both entities were already on the SDN list under existing Cuba authorities; however, the new designations attached the risk of "secondary sanctions" to those two entities. (Here, and the Department of State's press release) Concurrently, OFAC issued General License 1 under Cuban Assets Control Regulations which extends all the authorizations under CAR to the sanctions imposed under EO 14404. (Here) OFAC also published six new Cuba-related Frequently Asked Questions, FAQs 1251-1256, to clarify the new changes to the Cuba program of the United States.

OFAC and Department of States imposed blocking sanctions on three individuals and nine entities across China, UAE, Belarus and Hong Kong tied to Iran’s overseas military procurement networks, including actors supporting weapons procurement, satellite imagery support, and the supply of UAV and ballistic missile-related materials. Out of these 12 designations, OFAC imposed blocking sanctions on 10 new parties under its Weapons of Mass Destruction and Iranian Financial Sanctions programs, while the State Department designated two new entities under Iran’s Conventional Arms Activities Program. The State Department also designated two entities under Iran’s Conventional Arms Activities Program that were already sanctioned under the U.S. Weapons of Mass Destruction and Iranian Financial Sanctions programs. The total number of designations under Iran’s Conventional Arms Activities Program is now 33. This designation package is a great reminder of the complexity of the U.S. sanctions against Iran. . (Here, the Department of the Treasury's press release, and the Department of State's press release)

If you are using Claude Cowork, check out this post from our founder, Amir Fadavi, about a skill he created to help you test whether the sanctions lists you are using are updated.
Check out this white paper from SIFMA which calls for a fundamental reset of how U.S. sanctions are applied to capital markets, arguing that the current patchwork regime harms everyday investors by trapping them in illiquid positions and restricting secondary trading in ways that hurt investors without meaningfully impacting sanctions targets. The paper urges OFAC to establish a standardized framework that allows pre-existing sanctioned securities to trade on secondary markets, provides transition periods for compliance, and issues general licenses for routine investment lifecycle activities like dividends, distributions, and securities lending.

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