Last Week's Major Developments in Sanctions - October 19 to October 23, 2026

Recommendation of the Week

• This week, I would like to start with the recommendation section. If you are interested in how China is responding to the Western sanctions, do not miss this comprehensive report from Sanctrust on U.S.-China Economic Security Handbook.

Monday, October 19

• OFAC added Shanghai Zhisuan Technology Co Ltd, Qiji Chuangtan Beijing Investment Management Co Ltd (MiraclePlus), and three affiliated Beijing entities to its Non-SDN Menu-Based Sanctions List under the Protecting American Intellectual Property Act of 2022. The entries impose blocking and specified lending, foreign-exchange, banking and investment restrictions; the statutory blocking provision excepts imports of goods. PAIPA General License 1 authorizes transactions to the extent authorized or exempt under the Cyber-Related Sanctions Regulations, subject to exclusions. General License 2 authorizes qualifying wind-down transactions involving MiraclePlus, its three named affiliates and entities they own 50 percent or more, individually or in aggregate, through 12:01 a.m. EST on January 19, 2027, with payments to blocked persons required to enter blocked U.S. accounts; it does not cover Shanghai Zhisuan. (Here)

Tuesday, October 20

• Australia’s Foreign Minister designated two individuals and two entities under the North Korea sanctions framework. The instrument targets YU Pu Ung, SIM Hyon Sop, Korea Mangyondae Computer Technology Company, and Chinyong Information Technology Cooperation Company for assisting North Korea’s evasion of UN sanctions. The two individuals are subject to targeted financial sanctions and travel bans, and the two entities to targeted financial sanctions. The instrument was made on October 20, registered on October 22, and entered into force on October 23. (Here)

Wednesday, October 21

• OFAC sanctioned facilitators of Iran’s shadow fleet, while FinCEN announced related investigative steps. OFAC imposed blocking sanctions under E.O. 13902 against five individuals located in Panama and four entities located in Panama, Greece, Singapore and the UAE, and identified nine vessels as blocked property. The entities are Karnakis and Karnakis, Roxette Maritime Shipping and Trading S.A., Amigoz Singapore Pte. Ltd., and Whales Shipping Line LLC. Separately, FinCEN reported issuing an administrative subpoena under 31 U.S.C. § 5318(k) in an investigation into an unnamed Greek bank’s potential ties to Iran and its proxies, and requests for information about banks’ relationships with designated Iranian financial institutions. (Here)

• OFAC issued Iran General Licenses GG and HH. GL GG authorizes specified wind-down transactions involving Karnakis and Karnakis and entities it owns 50 percent or more through 12:01 a.m. EST on November 20, 2026. GL HH provides specified wind-down, crew-safety, environmental and cargo authorizations involving Roxette and seven vessels listed in its annex through the same deadline. Cargo must be non-Iranian-origin and loaded on or before October 21, and the specified docking and cargo activities exclude Iranian and Russian ports and ports controlled by their governments. Both licenses require payments to blocked persons to enter blocked accounts and retain other restrictions. (Here)

• OFAC extended specified Lukoil International authorizations. Russia-related GL 131K replaces GL 131J and authorizes specified negotiations and contingent sale contracts involving Lukoil International GmbH and entities it owns 50 percent or more, together with specified maintenance and wind-down activities, through 12:01 a.m. EST on November 21, 2026. Completing a sale requires separate OFAC authorization, and transfers of funds to persons or accounts in Russia remain excluded. OFAC also amended FAQs 1224 and 1225; FAQ 1225 distinguishes GL 131K from the separate retail-service-station authorization under GL 128D, which runs to April 24, 2027. (Here)

• OFAC removed two individuals and two entities from the SDN List. The removals cover China-based Lu Hezheng, Moxing Cartoon and Shanghai Hongman Cartoon and Animation Design Studio under the North Korea sanctions program, and Belarus-based Andrei Alekseevich Rybakov under the Belarus program. Repeated alias entries in the notice refer to the same persons and do not represent additional delistings. (Here)

Thursday, October 22

• Treasury proposed expanded outbound investment controls under the COINS Act. The proposed regulations would expand covered technology sectors to include high-performance computing and supercomputing, hypersonic systems, and biotechnology, while revising transaction prohibitions and notification requirements. Comments are due December 7, 2026. The proposal itself does not implement the new requirements; the final rule will set their effective date. (Here)

• OFSI’s Iran Nuclear Interim Necessities General Licence expired. GL INT/2025/7628424 expired at 23:59 UK time on October 22, 2026. The license had permitted specified employee, director, pension, IT and accountancy payments involving listed designated persons and qualifying UK subsidiaries, subject to conditions. OFSI moved it to the expired-license collection on October 23; the expiry date should be distinguished from that administrative update. (Here)

Friday, October 23

• ECJU announced proposed amendments to UK strategic export controls. Notice to Exporters 2026/24 previews military and dual-use control-list changes, including controls on semiconductor manufacturing equipment, advanced computing technologies and specialized materials, and proposed changes to Schedule 4 country listings. The proposals would also revoke GEA001 in Great Britain, with transitional use by existing registrants until April 1, 2027; EU GEA001 would continue to apply in Northern Ireland. Subject to ministerial and Parliamentary approval, regulations are expected to be laid in November and take effect in early December 2026; these are proposed changes and anticipated dates. (Here)