Last Week’s Major Developments in Sanctions - October 26 to October 30, 2026

Recommendation of the Week

• First, check out this blog post (and the table within it) to see how a Swedish bank got into trouble for compliance shortcomings and how you can use it as an opportunity to check your organization's compliance program.

Monday, October 26

• UK imposed asset freezing sanctions and travel bans against 15 senior commanders associated with the Rapid Support Forces, Sudanese Armed Forces and allied forces. The designations concern suspected violations of international humanitarian law in Sudan, including attacks on civilians and conflict-related sexual violence. (Here)

• OFAC amended 11 FAQs concerning blocking and rejecting transactions and filing reports. The amendments cover FAQs 10, 32–36, 41–42, 49–50 and 53, including the distinction between payment instructions and customer inquiries, when transactions must be rejected rather than blocked, and reporting through the OFAC Reporting System. (Here)

• OFSI issued Legal Services General License INT/2026/11112108, permitting qualifying legal-fee and expense payments involving designated persons under the autonomous sanctions regimes listed in its annex. The license applies from October 29, 2026 until April 28, 2027, subject to its conditions and caps. Recipients must report payments within 14 days after each calendar month ends. (Here)

• EU Council renewed its autonomous ISIL/Da’esh and Al-Qaeda restrictive measures until October 31, 2027. Decision (CFSP) 2026/2378 was adopted October 26, published October 27 and entered into force October 28. The Council announcement identifies 15 individuals and eight groups covered by the autonomous measures. (Here)

• EU Council amended its DRC sanctions framework, adding deliberate and grave obstruction of MONUSCO’s mandate as a listing criterion and revising arms-related controls. Decision (CFSP) 2026/2372 and Regulation (EU) 2026/2374 also update reporting, information-sharing, anti-circumvention and penalty provisions. Both acts were published October 27; the Decision entered into force that day and the Regulation on October 28. (Here)

• EU Council renewed restrictive measures against the leadership of Moldova’s Transnistrian region until October 31, 2027. Decision (CFSP) 2026/2397 was adopted October 26, published October 27 and entered into force October 28. (Here)

• MOFCOM proposed provisions permitting restrictions against foreign entities infringing Chinese trade secrets where the infringement harms or threatens China’s sovereignty, security or development interests. Proposed measures include trade and investment restrictions, entry and work-permit restrictions, and fines. Comments are due November 24, 2026; the provisions remain proposed. (Here)

Tuesday, October 27

• OFAC and DOJ resolved sanctions and export-control cases involving Extreme Networks’ dealings with Russian weapons manufacturer MMZA. OFAC agreed to a $1,529,685 settlement; DOJ’s non-prosecution agreement requires a $487,860.92 criminal fine and $487,860.92 forfeiture. OFAC recognizes a $487,861 credit for payments under the DOJ agreement, leaving $1,041,824 payable to Treasury. DOJ treated the disclosure as a “near miss,” while OFAC treated the apparent violations as voluntarily self-disclosed and egregious. (Here)

• OTSI published guidance on trade sanctions relating to specified ships and construction services connected with Russia. The guidance explains the scope of relevant services prohibitions and applicable exceptions. OTSI also updated its professional and business services guidance. (Here)

• DOJ announced Ilya Pankov’s arrest on a 12-count indictment alleging unlawful exports to Russia through third-country buyers. Prosecutors allege that restricted mining and other equipment was routed through buyers in Korea, Turkey and Kazakhstan without required authorization. Pankov pleaded not guilty; the charges remain allegations. (Here)

• A federal court sentenced Dimitri Beix to 66 months in prison for illegal firearms exports to Dominica. DOJ’s October 28 announcement states that sentencing occurred October 27. The scheme involved firearms, components and ammunition exported without required Commerce Department licenses. (Here)

Wednesday, October 28

• OFAC imposed blocking sanctions against Rwanda’s Ministry of Defence and Zigama Credit and Savings Society. Treasury attributed the action to their support for Rwanda’s military and the M23 armed group and its political wing. Both entities were listed under the DRC-related sanctions program. (Here)

• OFAC imposed blocking sanctions against 10 individuals and one entity supporting North Korean IT-worker schemes. Treasury said the networks use fraudulent identities and financial intermediaries to generate and transfer revenue for North Korea’s weapons programs. The designated individuals are listed in Russia, including one also listed in Laos; the First Financial and Technical Development Center is listed in North Korea and Russia. (Here)

• DOJ announced a prison sentence for Yana Leonova for illegally exporting U.S.-origin aircraft components to Russia. Leonova received 12 months and one day in prison following her guilty plea. DOJ described a procurement scheme using intermediaries and false documentation to evade U.S. restrictions. (Here)

• OFSI extended General License INT/2025/7895596 until February 26, 2027, allowing specified business operations involving four named Lukoil Bulgaria entities and their subsidiaries. The license permits specified payments and the provision and receipt of economic resources, and allows relevant UK institutions to process authorized payments. Entities relying on its business-operation permissions remain subject to notification conditions. (Here)

Thursday, October 29

• OFAC issued Iran General License FF-1, replacing General License FF. It authorizes qualifying wind-down transactions involving International Development Bank for Investment and Finance, also known as Iraq Development Bank, and entities it owns 50 percent or more, through 12:01 a.m. eastern standard time on December 1, 2026. Payments to blocked persons must go into blocked accounts; other prohibited transactions remain excluded unless separately authorized. (Here)

Friday, October 30

• FATF removed Bulgaria, Côte d’Ivoire, the DRC and Monaco from its gray list following successful on-site visits. No jurisdictions were added. Gray-list status does not itself impose sanctions or a blanket FATF requirement for enhanced due diligence; FATF calls for a risk-based approach. (Here)

• FATF retained North Korea, Iran and Myanmar on its high-risk list. Calls for countermeasures against North Korea and Iran continue. Myanmar remains subject to enhanced due diligence, with countermeasures to be considered if it makes no further progress by February 2027. FATF also called for Iran to address deficiencies in criminalizing terrorist financing and implementing targeted financial sanctions. (Here)

• FinCEN issued an alert on suspicious cross-border payments involving U.S.-based money services businesses and a notice on the exploitation of charities and non-profit organizations for terrorist financing, fraud and other illicit activity. The documents identify risks and request specific references in relevant suspicious activity reports. FinCEN emphasized individual, risk-based assessments rather than treating either sector as uniformly high risk. (Here)