Last Week's Major Developments in Sanctions - September 21 to September 25, 2026

Monday, September 21

• There was no major development on this day.

Tuesday, September 22

• The EU Council announced that it prolonged the restrictive measures under Regulation 269/2014 targeting those responsible for undermining Ukraine's territorial integrity, sovereignty, and independence until 22 September 2029, maintaining travel bans, asset freezes, and the funds-availability prohibition against more than 3,000 listed individuals and entities. As part of the periodic review, the Council declined to renew the listings of three individuals (including Alisher Usmanov and Mikhail Friedman, two of Russia's wealthiest individuals) and one entity and removed three deceased persons from the list. (Here)

Wednesday, September 23

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

• In an important update, OFSI published new guidance highlighting that, with immediate effect, HM Treasury will apply a presumption of denial to license applications made by the five designated Iranian banks listed below. OFSI clarifies that license applications involving these banks will generally be refused unless there are clear and compelling reasons to justify an exception. The five banks are: Bank Sepah, Melli Bank plc, Bank Saderat, Persia International Bank, and Bank Tejarat.

  OFSI issued a subsequent FAQ on 24 September in this regard, and notes that applications will continue to be assessed on a case-by-case basis, but licenses will generally only be granted where required by law or in exceptional and urgent circumstances, such as risks to life, environmental safety, essential regulatory payments, asset preservation, or the wind-down of operations. In addition, OFSI has clarified that it will not renew the Iran Interim Basic Necessities General Licence INT/2025/7628424, which expires on 22 October 2026. Following its expiry, transactions previously authorised under that General Licence will no longer be authorised unless permitted by another applicable general licence or by a specific licence issued by HM Treasury. (Here)

• The Secretary of the Treasury announced that the United ‌States and China agreed on Wednesday to extend "the Busan ​agreement." Considering that the suspension of the BIS Affiliate Rule was part of that agreement, this potentially means that the suspension will be extended until January 10, 2027. (Here)

Thursday, September 24

• OFAC has issued a final rule adding the Sanctions Penalties Regulations at 31 CFR Part 505, effective September 25, 2026, consolidating existing enforcement procedures and penalty provisions including pre-penalty notice, settlement, Findings of Violation, and the rights of persons under investigation, for violations arising under IEEPA and the UN Participation Act, with no substantive changes to the underlying penalty standards. OFAC has indicated it will subsequently amend other chapter V parts to cross-reference Part 505 in place of their standalone penalties text. (Here)

• OFAC announced that it is amending the Terrorism List Governments Sanctions Regulations to remove and reserve a Syria-specific general license, a change made necessary by the prior rescission of Syria's designation as a State Sponsor of Terrorism. With that designation lifted, the authorization the general license provided is no longer operative, and OFAC is formally removing it as it would no longer be necessary. (Here)

• OFAC released its Third Quarter Report of Licensing Activities under Section 906(b) of the Trade Sanctions Reform and Export Enhancement Act of 2000, covering April through June 2026 activity under the Section 906(a)(1) licensing regime governing exports of agricultural commodities, medicine, and medical devices to Iran. During the quarter, OFAC's Licensing Division received 11 applications (5 agricultural commodities, 1 medicine, 5 medical devices) and issued 18 total licensing determinations, comprising 8 licenses (4 agricultural commodities, 1 medicine, 3 medical devices), 1 license amendment (agricultural commodities), 1 return-without-action letter, 3 general license guidance letters, and 0 denials. (Here)

• The EU Council adopted Decision (CFSP) 2026/2164 imposing asset freezing sanctions on the former President and Director of Information of RT France (2017–2022) under its Russia hybrid-activities sanctions regime for engaging in foreign information manipulation and interference (FIMI). The press release cites her continued dissemination, via French outlets including CNews, Europe 1, and Le JDNews, of narratives aligned with Russian government on the Ukraine war, NATO, and EU-Russia relations following RT's EU broadcasting suspension; French authorities have separately identified her as relaying Kremlin disinformation and issued an expulsion measure against her in July 2026. (Here)

Friday, September 25

• The EU Commission updated three FAQs in the Consolidated FAQs on sanctions against Russia and Belarus: a refreshed correlation table linking Advanced Technology items to CN customs codes, a clarification that Russian diplomats' travel notification duty bends for force majeure (e.g., emergency rerouting), and confirmation that the JSC Russian Railways asset-freeze exemption covers rail transit between Kaliningrad and mainland Russia via EU territory. (Here)