Last Week's Major Developments in Sanctions - September 14 to September 18, 2026

Monday, September 14

• After speculations that followed the Secretary of the Treasury's announcement that the United States would impose sanction againsts a large bank under the U.S. sanctions against Iran, OFAC imposed blocking sanctions against VTB Bank under its Iran sanctions program (E.O. 13902) for operating in the financial sector of the Iranian economy, and for establishing correspondent banking relationships with sanctioned Iranian financial institutions and building a rial/ruble settlement system to expand bilateral trade and move frozen Iranian assets. The action, taken under "Operation Economic Outcast," is layered onto VTB's existing Russia-program designations. Arguably being designated under Iran sanctions in addition to Russia sanctions programs, increased the risk associated with VTB, albeit being already very high. The other implication is that if there is a Russia sanctions relaxation in the future, VTB will still be sanctioned pursuant to this new designation under Iran program. (Here)

• OFAC issued Venezuela General License 52C, effective September 14, 2026, superseding GL 52B (August 27, 2026) under the Venezuela Sanctions Regulations, 31 CFR part 591. The license continues to authorize established U.S. entities (organized in the U.S. on or before January 29, 2025) to engage in transactions otherwise prohibited by E.O. 13884 or E.O. 13850 involving PdVSA or PdVSA-majority-owned entities, conditioned on dispute resolution in the U.S., UK, France, or Singapore and on payments to blocked persons routing through the Foreign Government Deposit Funds under E.O. 14373. Related Government of Venezuela transactions necessary to effectuate this remain authorized on the same payment condition, and the standard exclusions carry over unchanged along with the 10-day/90-day reporting requirement to State and DOE for oil and petrochemical exports. The key change from GL 52B is that GL 52C adds (i) a new authorization for blocked individuals to sign contracts and transaction documents solely in their official PdVSA capacity, and (ii) a new prohibition barring any transaction to alter the corporate governance of PDV Holding, Citgo Holding, or CITGO Petroleum. OFAC is also issuing one amended Venezuela-related FAQ 1245. (Here)

• A Russian, Estonian, and Swiss national pleaded guilty to conspiracy to violate the Export Control Reform Act for running a scheme, from early 2022 through September 2024, to supply prohibited Russian end users with export-controlled aerospace and aviation components without the required Bureau of Industry and Security licenses. The defendant co-founded a UAE-based trading entity roughly four weeks after Russia's invasion of Ukraine, through which dozens of shipments of U.S.-origin aerospace goods were procured from U.S. companies and reexported to Russia. Sentencing is scheduled for January 13, 2027, with a statutory maximum of 20 years' imprisonment. (Here)

• OFSI has published a new FAQ 203 clarifying whether a relevant institution may credit interest or other earnings accruing on one frozen account into a separate frozen account held for the same designated person. (Here)

Tuesday, September 15

• The Council of the EU adopted Decision (CFSP) 2026/2103 amending Decision 2014/145/CFSP concerning restrictive measures over actions undermining or threatening Ukraine's territorial integrity, sovereignty, and independence. The amendment extends the sunset clause under Article 6 to September 22, 2026 intended to give the Council additional time to comprehensively review the underlying listing regime before its next substantive renewal decision. (Here)

Wednesday, September 16

• OFAC issued Venezuela-related General License 5Z, "Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After November 5, 2026." GL 5Z, effective September 16, 2026, supersedes GL 5Y (dated August 3, 2026) and continues to authorize transactions related to, financing for, and other dealings in the PdVSA 2020 8.5 Percent Bond that would otherwise be prohibited under subsection 1(a)(iii) of E.O. 13835, as amended by E.O. 13857, and incorporated into the VSR. The key change is that GL 5Z pushes the authorized transaction date back from September 17, 2026 (per 5Y) to November 5, 2026. OFAC is also issuing one amended Venezuela-related FAQ 595. (Here)

• The State Department reported to Congress that the PLO and Palestinian Authority have again failed to meet their commitments under the PLO Commitments Compliance Act of 1989 and the Middle East Peace Commitments Act of 2002, citing continued efforts to internationalize the Israeli-Palestinian conflict through the ICC and ICJ, pursuit of unilateral recognition outside negotiations, and continued stipend payments to individuals who committed acts of terrorism alongside glorification of terrorism in official statements and school curricula. As a result, the U.S. is extending visa-denial sanctions on PLO members and PA officials under Section 604(a)(1) of MEPCA, while maintaining the standing waiver for personnel notified to the PLO's UN Observer Mission, consistent with prior determinations. (Here)

• FinCEN convened a FinCEN Exchange with global financial institutions to advance Operation Economic Outcast, briefing the private sector on the nodes, facilitators, and networks that give Iran and its proxies access to U.S. correspondent banking relationships to launder funds, procure weapons, and fund regional terrorist activity. The session builds on the April 2025 IMPACT public-private partnership event and reflects Treasury's continued push for public-private information sharing, with financial institutions encouraged to monitor FinCEN's related alerts, advisories, and financial trend analyses alongside OFAC's Iran-related sanctions actions. (Here)

Thursday, September 17

• OFAC imposed blocking sanctions on three individuals (all in Iran) and two entities (all in Iran) under its Iran sanctions program (E.O. 13902) for operating in Iran's digital asset sector to enable IRGC sanctions evasion. The designations target BitBank, a cryptocurrency exchange controlled by previously-designated Iranian financier Babak Zanjani; its developer, among others, for acting on behalf of Zanjani, Pishtaz Simorgh, and Dot One. (Here)

• The Department of State imposed blocking sanctions on three individuals (in Cuba) and eight entities (in Cuba) under E.O. 14404 for operating in Cuba's defense and metals/mining sectors. Four military research enterprises were designated for developing simulators, naval research, infantry armaments, and electronics/communications for Cuba's armed forces, along with their respective directors general, all senior FAR officers; four state-owned nickel-sector entities were separately designated for sustaining the regime's hard-currency nickel exports through mining, engineering, R&D, and support services. (Here)

Friday, September 18

• The national emergency declared in Executive Order (E.O.) 14046 of September 17, 2021, "Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia," has expired. Following the expiration of the national emergency declared in E.O. 14046, OFAC has removed from the List of Specially Designated Nationals and Blocked Persons (SDN List), persons designated pursuant to E.O. 14046 whose property had been blocked. In addition, OFAC has removed Frequently Asked Questions pertaining to this program from its website. (Here)

• OFAC issued Russia-related General License 131J, "Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities."GL 131J extends the wind-down/contract-negotiation deadline from September 19, 2026 (under 131I) to October 22, 2026 which is a further rolling extension with no other substantive changes to the license's terms. OFAC is also issuing two amended Russia-related FAQs 1224 and 1225. (Here)

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