Last Week's Major Developments in Sanctions - October 5 to October 9, 2026

Monday, October 5

• OFAC removed 125 individuals and entities from its sanctions lists and updated 22 additional list entries, the third round of removals under the sanctions modernization effort. The delisted parties include deceased individuals, defunct companies, and entries lacking enough identifying information for reliable compliance screening. (Here)

• OFAC alerted foreign financial institutions (FFIs) that continued business with Iran or its financial sector may expose them to sanctions. FFIs transacting with sanctioned Iranian financial institutions could be targeted at any time without advance notice and are advised to terminate such activity immediately. Additionally, OFAC is publishing one amended Iran-related Frequently Asked Question (FAQ 156). (Here)

• FinCEN announced that it withdrew the following proposed rules that would have imposed certain regulatory requirements on financial institutions related to certain digital assets, specifically convertible virtual currencies: 1. a proposal that would have imposed recordkeeping, verification, and reporting requirements on certain transactions involving convertible virtual currencies and unhosted wallets and 2. a proposal that would have imposed a special measure with regards to convertible virtual currency mixing. FinCEN stated that it had considered the comments submitted in response to these proposals and is withdrawing them as part of the Trump Administration’s deregulatory agenda and ongoing efforts to ensure digital asset regulations are fit-for-purpose. (Here)

• FinCEN announced that it withdrew the following proposed rules that would have imposed certain regulatory requirements on financial institutions related to certain digital assets, specifically convertible virtual currencies: 1. a proposal that would have imposed recordkeeping, verification, and reporting requirements on certain transactions involving convertible virtual currencies and unhosted wallets and 2. a proposal that would have imposed a special measure with regards to convertible virtual currency mixing. FinCEN stated that it had considered the comments submitted in response to these proposals and is withdrawing them as part of the Trump Administration’s deregulatory agenda and ongoing efforts to ensure digital asset regulations are fit-for-purpose. (Here)

Tuesday, October 6

• There was no major development on this day.

Wednesday, October 7

• The U.S. Department of State publicly designated the Director of the Overseas Chinese Service Center in Fiji under Section 7031(c) of the National Security, Department of State, and Related Programs Appropriations Act, 2026 (Div. F, P.L. 119-75) for involvement in significant corruption. Department says he abused his public position by paying bribes to Fijian citizens to advance China-based government, business, and criminal interests, adversely affecting U.S. interests in Fiji. The designation renders him and his immediate family members generally ineligible for entry into the United States. (Here)

• The French Government imposed asset freezing sanctions on one individual under France's autonomous counter-terrorism sanctions regime. (Here)

• OFSI published amendments to the Maritime Mutual Re-Insurance Wind Down General Licence (INT/2026/8893924). OFSI amended the licence to introduce a new definition of a "Qualifying Overseas Wind-down Payment" and expand the permissions available under the licence. The General Licence has also been extended by 12 months and now expires on 6 October 2027. (Here)

Thursday, October 8

• OFAC imposed blocking sanctions on 17 entities (10 in Marshall Islands, five in Hong Kong, one in UK and one in British Virgin Islands) under E.O. 13902 for operating in Iran’s petroleum or petrochemical sectors, and identified 17 of their tankers as blocked property. The action targets the remnants of Iran’s shadow fleet, which moved Iranian crude, bitumen, LPG, naphtha, methanol, and fuel oil to markets in South and East Asia. In a parallel action, the Department of State imposed blocking sanctions on six individuals (five in India and one in Türkiye) and 10 entities (three in Türkiye, three in UAE, two in India, one in UK and one in Iran) under E.O. 13846 for involvement in trade in Iranian-origin petroleum and petrochemical products, and identified 5 vessels as blocked property. State’s targets are six petrochemical trading companies, an India-based customs broker, two UAE-based vessel managers, and a UK-based registered owner of a tanker. The six individuals were blocked as principal executive officers of Noorzad Petrokimya, SSPL Solutions and Samudra. Additionally, OFAC issued Iran-related General License EE, "Authorizing the Wind Down of Transactions Involving Samudra Marine Services Private Limited." (Here)

• OFAC issued Russia-related GL 13S, replacing GL 13R in its entirety and extending the expiry from October 9, 2026 to 12:01 a.m. EST, January 9, 2027. The license continues to authorize U.S. persons and U.S.-owned or -controlled entities to pay taxes, fees, and import duties, and to obtain permits, licenses, registrations, certifications, and tax refunds otherwise prohibited by Directive 4 under E.O. 14024. (Here)

• The U.S. Justice Department and FBI announced seizures of domains supporting two hacking tools, “Microscan” and “FishHub,” which were operated by actors working for PRC-based Integrity Technology Group. Microscan used a Mirai-variant botnet of internet-of-things devices to scan for vulnerabilities for clients to exploit, with targets including a U.S. power company, a multinational NGO, Japanese and Polish airports, and Taiwanese critical infrastructure and universities. FishHub facilitated spear phishing and follow-on malware delivery, with approximately 20 Taiwanese universities among confirmed victims. (Here)

• The EU Council adopted Council Decision (CSP 2025/2258) prolonging by one year, until October 9, 2027, its asset-freezing and travel-ban measures under the framework for restrictive measures in view of Russia’s destabilising activities (Decision (CFSP) 2024/2643), citing Russia’s continued and intensified hybrid activities, including Foreign Information Manipulation and Interference (FIMI). (Here)

• The EU Council adopted Decision (CFSP) 2026/2264, amending Decision 2014/145/CFSP imposing asset freezing sanctions on one individual in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The designated person is a Russian businesswoman and owner of companies active in the agriculture, manufacturing, finance, consulting, construction and real estate sectors. The Council lists her as a leading businessperson operating in Russia and involved in economic sectors providing a substantial source of revenue to the Russian government. (Here)

• The UK Government imposed asset freezing sanctions on three individuals (one in Kyrgyzstan, one in the Netherlands and one in Russia), 23 entities (14 in Russia, three in Kyrgyzstan, three in China, one in Canada, one in Thailand and one in Türkiye) and 12 vessels under its Russia Sanctions Regime. The entities include a Moscow bank and four payment and crypto platforms, among them Canada-based owner of Cryptomus and Heleket, designated for operating in the Russian financial services sector. Others were designated for operating in the Russian defence and energy sectors or for supplying goods and technology that could contribute to destabilising Ukraine. The vessels were designated for carrying Russian-origin oil or oil products to third countries. The UK also expanded measures on Rostec (internet services and correspondent banking sanctions) and HeliCo Group (detained transport sanctions). Following the designation of Zarubezhneft JSC, OFSI has issued the Zarubezhneft JSC Wind Down General Licence (INT/2026/11080040). The General Licence permits the wind down or divestment of transactions involving Zarubezhneft JSC and entities it owns or controls directly or indirectly. It also permits activities reasonably necessary to complete that wind down or divestment. The General Licence takes effect from 8 October 2026 and expires at 23:59 on 21 November 2026. (Here)

Friday, October 9

• In a major development, the U.S. Department of State imposed blocking sanctions on the International Criminal Court (ICC) under section 1(a)(ii)(A) of E.O. 14203 to defend U.S. sovereignty and U.S. citizens against the threat of the ICC. Concurrently, OFAC issued four ICC-related general licenses (GLs). GL 13 authorizes transactions ordinarily incident and necessary to the maintenance or wind down of ICC operations, contracts and agreements, including States Parties’ payments, salaries, rent and utilities, through April 7, 2027, a 180-day window that State says gives States Parties time to show progress on its concerns and can be adjusted. GL 14 authorizes telecommunications, internet-based communications services and enterprise software (including cloud services), GL 15 authorizes pension payments, and GL 16 authorizes the continued detention of nine ICC detainees, including their health, safety and welfare and the operation of detention facilities. GLs 14 to 16 carry no stated expiry. (Here)

• OFAC announced a $175,015 settlement with Pegasus Worldwide Logistics, a freight forwarding firm, for four apparent violations of the Illicit Drug Trafficking Sanctions Regulations and six apparent violations of the Reporting, Procedures and Penalties Regulations. Between September 2023 and February 2024, Pegasus dealt in blocked property by facilitating the import of a machine supplied by a designated company, and it also failed to respond fully to an OFAC subpoena for six months. OFAC treated the conduct as non-egregious and not voluntarily disclosed. (Here)

• OFAC issued Russia-related General License (GL) 135, authorizing all transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587) or the Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589) that are related to the sale, delivery, offloading, or importation of diesel fuel of Russian Federation origin, including importation into the United States, through 12:01 a.m. EDT on April 7, 2027. The license does not authorize any debit to a U.S. financial institution account of the Central Bank of the Russian Federation, the National Wealth Fund, or the Ministry of Finance. (Here)

• A former senior executive-level federal employee holding a TS/SCI clearance pleaded guilty in the Eastern District of Virginia to executing a scheme to defraud the federal government, causing a loss of approximately $194 million. According to court documents, the defendant created fictitious government authorities, including a fabricated Special Access Program, to obtain approximately $193.6 million in U.S. government funds, then acquired gold bars and directed approximately $145 million in wire transfers toward luxury real estate, watches, and vehicles. The FBI recovered 298 gold bars, which cost the government approximately $46 million, along with cash and luxury watches in a May 2026 search, all of which are subject to forfeiture under the plea agreement. Sentencing is set for January 28, 2027, with a maximum penalty of 20 years in prison. (Here)

• The EU Council prolonged by one year, until October 15, 2027, its restrictive measures under Decision (CFSP) 2019/1720 in view of the situation in Nicaragua. The regime, first introduced in October 2019, addresses the ongoing deterioration of human rights, democracy and the rule of law in the country and is reviewed annually by member states. The measures currently apply to 21 persons and 3 entities, all subject to an asset freeze and a prohibition on making funds available to them. (Here)

• The EU Council adopted Decision (CFSP) 2026/2261, amending Decision (CFSP) 2023/2135 and extending the EU’s restrictive measures for activities undermining the stability and political transition of Sudan by one year, until October 10, 2027. The Decision also updates the entries for three listed individuals: a Sudanese Armed Forces (SAF) lieutenant general who directs the Defence Industry System, a financial director of the Rapid Support Forces (RSF), and the leader of the SAF-affiliated Sudan Shield Forces. (Here)

• OFSI has published a new FAQ 205 explaining what happens to specific licences when a designated person is delisted. The FAQ confirms that, once a designated person is delisted, UK financial sanctions no longer apply to that person or entity and any specific licences relating solely to them are no longer required. It also explains how OFSI will treat pending licence applications and what happens if a person or entity is subsequently re-listed. (Here)