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Last Week’s Major Developments in Sanctions — October 12 to October 16, 2026

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Monday, October 12

  • The EU Council imposed asset freezing sanctions against 743 individuals and 826 entities in Russia for supporting Russia’s military-industrial complex. The listings target companies and individuals involved in supplying components for missiles, drones, aircraft, and other military equipment. This was the EU’s largest single expansion of its sanctions listings since Russia’s full-scale invasion of Ukraine. (Council’s announcement)

  • The EU Council imposed asset freezing sanctions against 77 individuals for their involvement in the September 2026 Russian State Duma elections in temporarily occupied Ukrainian territories. The listings cover 74 candidates who stood in occupied Donetsk, Luhansk, Zaporizhzhia, Kherson, Crimea, and Sevastopol, and three members of Russia’s Central Election Commission. The individuals are also subject to travel bans. (Council’s announcement)

  • The EU Council imposed asset freezing sanctions against three individuals associated with activities in Russia and four entities in Russia and North Korea for supporting North Korea’s weapons programmes and violating or evading UN sanctions. The targets include a North Korean missile technician deployed to Russia, executives of Russian businesses, Samolet Group, Black Horse, Golden Autumn Agroholding, and Paekyangsan Shipping. The conduct includes employing North Korean workers, facilitating commercial and industrial cooperation, and transporting petroleum products to North Korea. (Council’s announcement)

  • The EU Council extended its chemical weapons sanctions framework until October 30, 2031, and the individual listings under that framework until October 30, 2027. (Council’s announcement)

  • The UK imposed asset freezing sanctions against two Iranian individuals, Ruhollah Bazghandi and Shahram Ali Reza Tamarzadeh Jakki, for facilitating or engaging in hostile activity on behalf of the Iranian government, including threatening, planning, or conducting attacks overseas. Bazghandi heads counterespionage operations within the IRGC; Tamarzadeh Jakki facilitates the Zindashti criminal network. The measures also include travel bans and director disqualifications. (FCDO’s announcement, and sanctions notices)

  • OFSI issued General Licence INT/2026/10050568, authorizing designated persons, or persons acting on their behalf, to make qualifying ground-rent, service-charge, and late-payment payments relating to eligible properties in England and Wales. The licence permits payments to specified UK bank accounts of landlords, managing agents, or their representatives, subject to its conditions. It expires on October 11, 2027, and does not authorize payments to designated landlords. (General licence and explanatory notice)

  • The Export Control Joint Unit temporarily paused its Control List Classification service from October 12. The service provides advice on whether goods appear on the UK’s strategic export control lists. (Notice to Exporters 2026/22)

  • China announced sanctions against Gustavo Emigdio Villate Samaniego, Paraguay’s Minister of Information and Communication Technologies, and Francis Fonseca, Belize’s Minister of Foreign Affairs and Foreign Trade. China cited their dealings with Taiwan and statements concerning alleged Chinese cyberattacks. The measures freeze assets in China and prohibit transactions or cooperation with them by Chinese organizations and individuals. (Foreign Ministry’s announcement)


Tuesday, October 13

  • OFAC imposed blocking sanctions against four individuals and 11 entities, all in Mexico, for supporting Cartel del Noreste through businesses involved in horse racing, construction, trucking, and the oil and gas sector. Treasury highlighted the use of legitimate commercial activities to launder proceeds and finance the cartel’s operations. (OFAC’s announcement, and Treasury’s press release, State Department's press release)

  • OFAC announced an $11,662,930 settlement with Bank of America for 475 apparent violations of sanctions programs targeting Russia, Belarus, Iran, Burma, Somalia, narcotics, and global terrorism. The failures included processing payments involving blocked banks, inadequate prioritization of screening alerts, delays in updating watchlists, and mishandling accounts associated with blocked persons. OFAC considered the violations non-egregious and largely not voluntarily self-disclosed. (OFAC’s announcement)

    In related actions, FinCEN imposed a $1.2 billion penalty for willful Bank Secrecy Act violations involving the bank’s AML program, foreign correspondent account due diligence, and suspicious activity reporting. The bank failed to timely report over $5 billion in suspicious transactions. FinCEN required a third-party review of historical transactions and independent reviews of compliance controls. The OCC imposed a $750 million penalty for deficient BSA/AML controls and failures to remediate deficiencies identified in its December 2024 order. FinCEN credited the OCC payment against its penalty, leaving $450 million payable to Treasury under FinCEN’s order. Together with OFAC’s settlement, the penalties total approximately $1.212 billion after that credit. (Treasury’s announcement, and FinCEN’s consent order)

  • DOJ announced coordinated actions targeting North Korean remote IT worker schemes affecting more than 70 U.S. companies. An indictment in Ohio charged 14 individuals, including two U.S. nationals who were arrested, in an alleged scheme involving wire fraud, money laundering, and identity theft. According to DOJ, the scheme generated approximately $3 million through remote IT employment obtained using stolen or fabricated identities and U.S.-based “laptop farms.” The proceeds were believed to have been sent to sanctioned North Korean entities. DOJ also announced that September operations at more than 40 suspected laptop-farm residences in Texas resulted in the seizure of approximately 187 computer devices. The FBI issued accompanying guidance on identifying and mitigating North Korean IT worker schemes. (DOJ’s announcement, indictment, and FBI guidance)

  • The EU Council adopted a regulation removing Mikail Gutseriev and Viktar Shautsou from its Belarus sanctions list. The regulation was published on October 14 and took effect on October 15. The removals concern the Belarus regime and should not be read as removing any separate restrictions under other sanctions regimes. (Council Implementing Regulation (EU) 2026/2313)


Wednesday, October 14

  • OFAC removed Jorge Jesús Rodríguez Gómez from its SDN List under the Venezuela sanctions program. (OFAC’s announcement)

  • DOJ announced that Sasa Micev, a Bosnian national, was sentenced to five years in prison after pleading guilty to violating IEEPA and the North Korea Sanctions Regulations. Micev worked with a New Mexico-based co-conspirator to broker the purchase of SA-18 Igla portable surface-to-air missiles from North Korea without OFAC authorization. He provided pricing information, participated in efforts to obtain the weapons using falsified documentation, and traveled to Ankara in 2020 to complete the transaction. The sale fell through following a price dispute with the North Koreans. (DOJ’s announcement)

  • The UN Security Council adopted Resolution 2831 (2026), renewing the Haiti sanctions measures, including the travel ban, asset freeze, and arms embargo. The resolution was adopted with 14 votes in favor and Russia abstaining. (UN announcement, and resolution)


Thursday, October 15

  • OFAC imposed blocking sanctions against 16 individuals in Iran and the UAE and 10 entities—eight in Iran, one in Iraq, and one in Hong Kong for their roles in Iran’s international financial networks and shadow banking activities. The action was taken under Executive Order 13902 as part of Operation Economic Outcast. OFAC also issued General Licence FF, authorizing qualifying wind-down transactions involving International Development Bank for Investment and Finance through 12:01 a.m. EDT on October 30, 2026. (OFAC’s announcement, Treasury’s press release, and GL FF)

  • The State Department imposed blocking sanctions against Banco Internacional de Comercio, S.A. (BICSA), a Cuban state-owned bank, under Executive Order 14404. OFAC added the bank to the SDN List and issued FAQ 1276, explaining its limited approach to certain wind-down activity through November 14, 2026. (OFAC’s announcement, including the State Department release, and FAQ 1276)

  • OFAC issued Russia-related General Licences 128D and 130B, replacing GLs 128C and 130A. The licences extend specified authorizations involving Lukoil retail service stations outside Russia and certain Lukoil entities in Bulgaria through 12:01 a.m. EDT on April 24, 2027, subject to their respective conditions. OFAC also amended FAQ 1225. (OFAC’s announcement, GL 128D, GL 130B, and FAQ 1225)

  • FinCEN issued an alert concerning the Iranian government’s abuse of religious charity networks, including the diversion of religious tithes known as khums. The alert identifies red flags to help financial institutions detect and report suspicious activity involving charities used to channel funds to the Iranian government or its terrorist proxies. FinCEN also emphasized that legitimate charities should retain access to financial services. (FinCEN’s announcement and alert)

  • The EU Council imposed asset freezing sanctions against three individuals associated with Russian businesses and nine entities in Russia, Türkiye, the UAE, India, and Seychelles for facilitating imports of restricted goods into Russia and circumventing oil and financial sanctions. The targets include logistics companies, payment intermediaries, trading companies, and firms associated with Russia’s shadow fleet. The individuals are also subject to travel bans. (Council’s announcement, and implementing regulation)

  • The UK’s Global Human Rights and International Humanitarian Law Sanctions Regulations 2026 entered into force, replacing the 2020 global human rights sanctions regime. The new framework expands the grounds for sanctions to include serious violations of international humanitarian law and obstruction of humanitarian assistance, alongside broader serious human rights violations and abuses. Existing designations continue under the new framework. (Regulations)

  • DOJ announced the extradition of Alexander Suvorov, a Russian national, from Sweden to the United States to face charges involving the unlawful export of U.S. microelectronic components to Russia through a Hong Kong front company. According to the criminal complaint, Suvorov led a procurement network that obtained dual-use components from U.S. companies between approximately March 2022 and April 2023. The FBI and BIS investigated the case. (DOJ’s announcement)


Friday, October 16

  • President Trump issued an executive order implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, waiving specified sanctions, restrictions, and tariffs under the Act on national-interest grounds. The order preserves sanctions imposed under pre-existing Russia-related executive orders. (Executive order)

  • OFAC issued Venezuela-related General Licence 60A, replacing GL 60 and authorizing qualifying earthquake-relief transactions through 12:01 a.m. EDT on April 21, 2027. OFAC also amended FAQ 1263, addressing the Foreign Government Deposit Funds Account. (OFAC’s announcement, GL 60A, and FAQ 1263)

  • China’s Ministry of Commerce and Ministry of Science and Technology proposed adding 40 technologies in artificial intelligence, biotechnology, and photovoltaic manufacturing to China’s catalogue of prohibited or restricted technology exports. Comments are due by November 15, 2026. Separately, the announcement immediately requires pre-export registration for the technologies identified in the proposal, including exports already started but not completed. The proposed catalogue amendments and the interim registration requirement are distinct measures. (Announcement No. 48, and Ministry’s explanatory Q&A)

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