Last Week's Major Developments in Sanctions - November 2 to November 6, 2026

Monday, November 2, 2026

• There was no major development on this day.

Tuesday, November 3, 2026

• The EU announced that Albania, Bosnia and Herzegovina, Iceland, Moldova, Montenegro, North Macedonia and Norway aligned with seven existing Russia-related sanctions decisions. Liechtenstein also aligned with five of those decisions. The statements record commitments to bring national policies into conformity with existing EU measures; they do not announce new EU designations or establish national implementation dates. (Here)

• BIS renewed Rossiya Airlines’ temporary denial order for one year, effective November 3, following findings of repeated, ongoing apparent violations of the Export Administration Regulations. The order continues restrictions on transactions involving covered items and services for the airline, subject to its BIS-authorized safety-of-flight exceptions. It was published in the Federal Register on November 5. (Here)

Wednesday, November 4, 2026

• The United States imposed blocking sanctions against five individuals listed in India and Russia and ten entities listed in India, Singapore and Turkey under E.O. 13902 or the Iran-related conventional-arms sanctions authority. Treasury targeted Suniel Kumar Sharma’s network for supplying false flags and certifications to Iran’s shadow fleet, and Fugo Ground Services for supporting sanctioned Iranian airlines. OFAC also applied the conventional-arms authority to the existing listings of Mohammed Ali Tolibov and Vanguard Tactical Supply Limited. (Here)

• OFAC issued an alert warning maritime service providers of designation and penalty risks associated with vessels using false flags to evade Iran sanctions. It encourages enhanced due diligence where registration claims appear false, including conflicting maritime identity codes and unverifiable registration documents. OFAC also encourages affected countries to investigate fraudulent registries and report them to the International Maritime Organization. (Here)

• OFAC issued Venezuela General License 5AA, replacing General License 5Z and postponing until December 18, 2026 the authorization for specified transactions involving the PDVSA 2020 8.5 percent bond. Updated FAQ 595 explains that, before that date, sales or transfers of CITGO shares connected with the bond remain prohibited under E.O. 13835 unless specifically licensed by OFAC. The license does not authorize transactions otherwise prohibited by Venezuela sanctions or other OFAC regulations. (Here)

• The UK House of Lords agreed the approval motion, as amended, for the Global Human Rights and International Humanitarian Law Sanctions Regulations 2026. The regulations had already entered into force on October 15, replacing the 2020 framework while preserving existing designations and licenses. The expanded designation grounds cover serious international humanitarian law violations, liberty and security of person, and obstruction of humanitarian assistance. (Here)

• The Swiss Federal Council adopted further Russia and Belarus sanctions, with sectoral measures effective November 5; EAER listing measures adopted November 3 took effect at 11 p.m. on November 4. The package subjects 254 additional individuals, companies and entities to asset freezes and a ban on providing economic resources, tightens export controls on 41 companies, and introduces restrictions affecting financial institutions, infrastructure and 41 vessels. Sectoral changes include reporting requirements for LNG tanker transfers to third countries and restrictions on Russian nationals and residents acquiring interests in Swiss crypto-service companies. An exemption for certain Russian crude oil shipments to Japan was extended until March 31, 2028. (Here)

• The EU General Court largely dismissed the Russian Maritime Register of Shipping’s challenge to EU restrictive measures in Case T-535/24, upholding the investment and transaction bans and rejecting its challenge to the port and lock access ban as inadmissible. It annulled the decision provision withdrawing RMRS’s EU recognition as a ship inspection and certification organisation, finding that suspension would have been less onerous. However, the Court maintained that provision’s effects for a period not exceeding two months and ten days from delivery of the judgment. The corresponding regulation provision was not annulled, so the ruling did not immediately restore recognition or lift the remaining restrictions. (Here)

Thursday, November 5, 2026

• OFAC imposed blocking sanctions against five individuals and 41 entities supporting global scam networks. Four individuals and 41 entities were targeted under the transnational criminal organizations authority for supporting or operating within Prince Group’s corporate and financial network, including structures used to conceal assets and evade earlier sanctions. OFAC separately designated Chui Kok Wa, a Malaysian national located in Madagascar, under its cyber sanctions authority for leading scammers who defrauded U.S. victims. (Here)

• OFAC added two individuals, six entities and two vessels to the SDN List under E.O. 14404, with the individuals listed in Cuba and Panama and the entities in Cuba, China and Panama. It also applied that Cuba sanctions authority to two entities and three vessels already blocked under other authorities. A separate determination, effective November 5, extends the order’s sectoral designation authority to Cuba’s electronics, manufacturing, marine and technology sectors. The determination provides a basis for designating foreign persons operating in those sectors; it does not automatically block every sector participant. (Here)

• DOJ announced that a nine-count third superseding indictment against Tren de Aragua leaders, returned in July, was unsealed during the week. The prosecution includes charges of conspiring to provide and providing material support to the designated Foreign Terrorist Organization; Giovanni Vicente Mosquera Serrano also faces cocaine-trafficking charges. The State Department offered rewards totaling up to $50 million for information leading to the arrests and/or convictions of Yohan José Romero, Mosquera Serrano and Juan Gabriel Rivas Núñez. These are criminal allegations, including material-support charges, rather than announced sanctions-violation charges; the defendants are presumed innocent. (Here)

• BIS filed a final rule for public inspection extending the suspension of its Affiliates Rule through January 10, 2027. The suspension had been scheduled to end on November 9, 2026; the extension takes effect that day and continues the stay of the rule’s amendments to 15 CFR parts 732, 734, 736, 744 and 748. Federal Register publication was scheduled for November 9, and BIS said comments on the Affiliates Rule would be considered in future rulemakings. (Here)

• Australia imposed asset freezing sanctions against four Sudanese individuals and one entity under its autonomous human rights sanctions framework, with travel bans on the individuals. The targets are Abdel Fattah Abdelrahman Al-Burhan, Mohamed Hamdan Dagalo Mousa, Al-Tijani Al-Tahir Karshoum, Hussein Barsham and Al-Baraa Bin Malik Brigade. Unauthorized dealings with controlled assets and making assets available to or for the benefit of listed persons or entities are prohibited. The Foreign Minister also issued class-based humanitarian permit SAN-2026-00229 to facilitate certain humanitarian activities in Sudan. (Here)

Friday, November 6, 2026

• OFAC imposed blocking sanctions against eight Canada-based money services businesses under E.O. 13902 for operating in the digital asset sector of the Iranian economy. Treasury said the businesses facilitated transactions involving Iran, including dealings with sanctioned Iranian exchanges and digital asset addresses associated with the IRGC; several also handled funds linked to Ryan Wedding. FINTRAC confirmed coordination with OFAC and FinCEN without announcing individual Canadian compliance actions against the eight businesses. The blocking restrictions also extend to entities owned 50 percent or more, individually or in the aggregate, by blocked persons. (Here)

• FinCEN issued an order under section 9714(a) of the Combating Russian Money Laundering Act finding MEXC Global to be of primary money laundering concern in connection with Russian illicit finance. The order prohibits covered financial institutions from transmitting funds from or to MEXC Global, including its non-U.S. subsidiaries, branches, offices and successors. The prohibition takes effect 30 days after Federal Register publication, rather than immediately on November 6. Other Bank Secrecy Act and OFAC obligations remain applicable. (Here)

• FinCEN and the Federal Reserve announced withdrawal of their October 2020 proposal to lower the Recordkeeping Rule threshold from $3,000 to $250 for funds transfers beginning or ending outside the United States. The proposal also included a corresponding Travel Rule threshold reduction and clarification of coverage for convertible virtual currencies and digital assets with legal tender status. The withdrawal was filed for public inspection on November 6, with publication scheduled for November 9, and takes effect upon Federal Register publication. It does not adopt the proposed changes. (Here)

• The European Commission announced the launch of an EU Crypto Sanctions Task Force to strengthen detection of and responses to attempts to circumvent EU financial sanctions through crypto assets. The statement followed the November 5 meeting of the High-Level Expert Group on Union Restrictive Measures, where participants discussed crypto-related risks, OLAF investigations and consistent sanctions enforcement. (Here)