Last Week's Major Developments in Sanctions - September 28 to October 2, 2026

Monday, September 28

• The EU Council imposed asset freezing sanctions on ten individuals (Russian nationals) under its Russia human rights sanctions regime (Decision (CFSP) 2026/2192 and Implementing Regulation (EU) 2026/2193) for repression of democratic opposition and undermining democracy and the rule of law in Russia. The listings target judges, prosecutors and election and prosecutorial officials involved in barring the Yabloko party from the September 2026 State Duma elections and in the anti-war speech prosecutions of its leaders, bringing the regime total to 108 individuals and 7 entities. (Here)

• OFAC issued three Venezuela-related general licences, each with a single change: the annex defining "petrochemical products" now lists methanol under five new HS codes (2905111000, 2905112010, 2905112015, 2905112085 and 9817290200). The operative text is otherwise unchanged. GL 46E (Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products) replaces GL 46D of 27 August 2026. GL 48D (Authorizing the Supply of Certain Items and Services to Venezuela) replaces GL 48C of 27 August 2026. GL 49B (Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela) replaces GL 49A of 13 March 2026. (Here)

• The EU Council imposed asset-freezing sanctions and travel bans on 10 individuals and 17 entities under its Ukraine territorial integrity sanctions framework (Decision 2014/145/CFSP). The package specifically targets those responsible for the systematic unlawful deportation, forcible transfer, and forced ideological re-education/militarised schooling of Ukrainian children to Russia, occupied territories, and external facilities (such as a state-operated camp in North Korea). The designations focus on: Key Officials & Administrators: Regional leaders, occupation ministers of education/sports, and school directors enforcing pro-Russian curricula and military-patriotic drills. Camps & Infrastructure: 17 entities—including children's recreation centers, municipal tourism committees (like Moscow's Mostourism), and digital monitoring centers—engaged in cultural reorientation and erasing Ukrainian identity. (Here)

• The EU Council adopted Decision (CFSP) 2026/2197 on 28 September 2026, extending the restrictive measures concerning the situation in Burundi (Decision (CFSP) 2015/1763) for an additional year until 31 October 2027. (Here)

Tuesday, September 29

• OFSI amended the General Licence INT/2025/7363752 to include (as prohibitions listed at paragraph 2) regulations 17A (investments in relation to Iran) and 17C (insurance and reinsurance services) of the Iran Nuclear Regulations. Regulations 17A and 17C came into force on 29 September 2026, and were introduced in The Iran (Sanctions) (Amendment) Regulations 2026 (S.I. 2026/983) laid on 8 September 2026. Additionally, OTSI also published a General Trade Licence regarding the services necessary for the continued operation of the Shah Deniz project which came into force on 29 September 2026. (Here)

• OFSI updated FAQ 204 on how it will assess license applications involving the designated Iranian banks covered by HM Treasury's licensing guidance. The FAQ now clarifies for the avoidance of doubt that this policy will be applied to all open license applications. (Here)

• OFAC removed subpart G (a repetative subpart under various parts of title V which discussed the penalties) from 36 parts of 31 CFR chapter V, effective 30 September 2026. Instead, OFAC created a new part, part 505, dedicated to the Sanctions Penalties Regulations (31 CFR part 505, issued 25 September 2026). The change was done to make it easier to find relevant regulations on penalties, and to fill a number of gaps where older parts had incomplete or no penalties information, including the United Nations Participation Act penalties in parts 510, 547, 576 and 594. (Here)

• Similarly, OFAC amended the Iranian Transactions and Sanctions Regulations (31 CFR part 560), effective 30 September 2026, to implement E.O. 13902. New § 560.211(c)(1)(iii) has incorporated the relevant parts of E.O. 13902. The rule adds exemptions for agricultural commodities, food, medicine and medical devices and for official United Nations business, and a definition of "Iran" for these provisions that includes the Government of Iran. (Here)

• Moreover, OFAC issued the Cuba Sanctions Regulations (31 CFR part 516), effective 30 September 2026, implementing E.O. 14404 of 1 May 2026. The regulations provide for blocking sanctions on foreign persons operating in Cuba's energy, defense, metals and mining, financial services or security sectors, persons acting for or supporting the Government of Cuba, and those responsible for serious human rights abuse or corruption. Foreign financial institutions that facilitate significant transactions for blocked persons face correspondent account restrictions or blocking. OFAC also amended the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR) to implement portions of the President's foreign policy toward Cuba. (Here)

• OFAC issued an alert highlighting increased Cuba sanctions risk for US and non-US persons following E.O. 14404, the new Cuba Sanctions Regulations and the amended CACR. It warns foreign financial institutions to exercise caution with sanctioned persons, summarises the CACR changes, and notes that General License 1 (7 May 2026) authorises transactions prohibited by E.O. 14404 where otherwise authorised or exempt under the CACR. OFAC issued five new, Cuba-related Frequently Asked Questions (FAQs 1271–1275) and 29 amended, Cuba-related Frequently Asked Questions (Here)

• OFAC imposed blocking sanctions on 21 individuals (all in Mexico) and 25 entities (all in Mexico) under its Counter Narcotics (E.O. 14059) and Counter Terrorism (E.O. 13224, as amended by E.O. 13886) sanctions programs for acting for or supporting the Sinaloa Cartel. The 18 newly listed individuals comprise the Los Mayos leader, four members of his inner circle (including its head of security), three Tijuana cell leaders, five money launderers and financial facilitators, four Baja California political enablers, and one narcotics trafficker and money launderer associated with a senior cartel leader. The other three individuals are re-designations: the two Tijuana plaza bosses and a senior cartel leader and fentanyl precursor supplier, all previously listed only under E.O. 14059 and now also designated under E.O. 13224. The entities are front companies and money exchanges linked to the launderers and politicians, spanning real estate, entertainment, private security, fuel, hospitality, transport and financial services. (Here)

• OFAC imposed blocking sanctions on five individuals (two in Iran, two in China, one in Pakistan) and five entities (one each in Iran, Hong Kong, Pakistan, Saudi Arabia and Türkiye) under its Non-Proliferation (E.O. 13382) sanctions program for procuring weapons and weapons components for Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). The individuals include MODAFL's representative in Beijing, who coordinates procurement of finished weapons systems and dual-use components in China, and the director and a representative of Iran-based Kavoshcom, which supplied electronics to an aircraft and UAV manufacturer and to a solid-fuel ballistic missile subordinate. They also include the China-based representative of Kavoshcom's Hong Kong electronics supplier and the chairman of a Pakistani defence company acting as a third-party intermediary for MODAFL.

  In a simultaneous action, the U.S. Department of State imposed blocking sanctions on three entities (two in Russia, one in Iran) under its Iran Conventional Arms sanctions program (E.O. 13949, section 1(a)(iii)) for activity that materially contributes to the proliferation of arms and related materiel to or from Iran, including violations of the renewed UN measures. The Russian entities are an aircraft manufacturer that supplied Yak-130 jets and related equipment to Iran, with nearly all of 24 reportedly contracted aircraft now delivered, and a shipping company whose vessels carried Iranian close-range ballistic missiles to Russia in 2024 and air defense vehicles in late 2025. The Iranian entity is an airline affiliated with the Iranian Air Force that has helped transport arms and related materiel. All three were previously designated under other programs (the Russian entities under E.O. 14024, the airline under E.O. 13902), so on the SDN list they appear as amendments to existing entries. The designations were announced alongside Treasury's action on Iran's military procurement networks under Operation Economic Outcast. (Here)

Wednesday, September 30

• OFSI has launched its annual Frozen Asset Review 2026, requiring all persons holding or controlling funds or economic resources owned, held or controlled by a designated person to submit a report by Monday 30 November 2026. Reports must cover all assets frozen in the UK and overseas that fall under UK financial sanctions legislation, valued as of close of business on Wednesday 30 September 2026, with shares, securities and other debt or payment instruments reported at their GBP value. Firms that have previously reported frozen assets to OFSI must still file a return, and all returns must be made on the 2026 reporting template from GOV.UK, which has been updated since last year. (Here)

• ECJU has made further updates to the end-user and stockist undertaking (EUSU) form which must be completed for a standard individual export licence (SIEL), standard individual trade control licence (SITCL) or a licence to provide technical assistance. The changes have been made following feedback received from exporters. Instead of having to select the relevant sections, ECJU mandates that all sections must now be completed, an additional section for third parties and intermediate users has been added and more guidance has been included on the form. (Here)

• OFAC imposed blocking sanctions on nine individuals (five in Venezuela, four in Mexico) and two entities (both in Mexico) under its Transnational Criminal Organizations (E.O. 13581) and Counter Terrorism (E.O. 13224) programs, for supporting the Foreign Terrorist Organization Tren de Aragua (TdA). Eight individuals and both entities form a network that uses malware to force US ATMs to dispense cash and launders the proceeds through cryptocurrency, led by an FBI Ten Most Wanted fugitive. The ninth individual is a senior TdA leader involved in illicit gold mining. (Here)

• The EU commission updated FAQs concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it: Transit Restrictions on Grain: Question 6 was updated on 30 September 2026 to clarify that under EU sanctions regulations (Council Regulation (EU) 2022/263), the term "import" is interpreted broadly to include transit. (Here)

Thursday, October 1

• OTSI published two general trade licences under the Russia sanctions regime authorising UK involvement in the maritime transportation of Russian LNG to Japan and South Korea. The licences are targeted and time-limited, and apply only where all conditions are met: the imports must come from the Sakhalin-2 Project, be made under a supply contract concluded before 17 June 2025, and take place between 1 January 2027 and 31 March 2028. They come ahead of the extension, from 1 January 2027, of the UK's 20 May 2026 maritime LNG transportation ban to trade under long-term contracts concluded before 17 June 2025, and were published on 1 October 2026 alongside the designation of 31 individuals, entities and ships under the UK's Russia sanctions regulations. (Here)

• The UK imposed asset freezing sanctions on 22 individuals (Russian, Ukrainian and Georgian nationals) and one entity (Singapore) under the Russia (Sanctions) (EU Exit) Regulations 2019, alongside shipping and trade sanctions on eight vessels (six Russia-flagged, one Turkey-flagged, one Sri Lanka-flagged) specified for carrying Russian-origin LNG to third countries. The individuals are listed for involvement in the arbitrary detention, torture and ill-treatment of civilians in occupied Ukraine (8), the forced deportation and re-education of Ukrainian children (7), and support for Russian occupation and disinformation efforts, including a delegation of Georgian politicians that met the head of the so-called Donetsk People's Republic (6), with one further individual listed as a former director of the Kurchatov Institute. The entity, a Novatek subsidiary, is listed for operating in the Russian energy sector and is also subject to transport sanctions, while the individuals also face travel bans, trust services sanctions and director disqualification. (Here)

• OFSI updated the Oil Price Cap General Licence: Exempt Projects and Countries (INT/2022/2470156) and the General Licence: Russian Oil Exempt Projects (INT/2025/5635700), extending the Sakhalin-2 expiry dates to 31 December 2026. (Here)

• OFAC imposed blocking sanctions on two individuals (one in China, one in Hong Kong) and 28 entities (12 in Iran, seven in Hong Kong, three in China, three in the UAE, and one each in Indonesia, Türkiye and Germany) under its Iran sanctions program. OFAC also published a determination, effective 1 October 2026, applying E.O. 13902 to the automotive and rail sectors of the Iranian economy, and updated FAQ 831 on the sector definitions. The E.O. 13902 designations cover: the automotive sector (Iran's two largest carmakers, their subsidiaries, two motorcycle makers and five foreign parts suppliers) the rail sector (three operators) the manufacturing sector (a mining and construction machinery maker and its China-based subsidiary) the financial sector (five Hong Kong shell companies used for shadow banking) The E.O. 13871 designations target Iran's iron, steel, aluminum and copper sector. They cover a Hong Kong-based Iranian businessman's steel and oil export network (him, a co-shareholder and three steel companies in China and Iran) and three steel suppliers and payment recipients in the UAE and Germany. (Here)

• OFAC imposed blocking sanctions on one entity, the A7 Network (listed in Russia, Kyrgyzstan, Nigeria and Zimbabwe), under its Transnational Criminal Organizations program, tagged [TCO], for operating a Russia-linked shadow banking network used to evade sanctions. All property of the network, including transactions involving Sub-Agents acting for it, is now blocked. The network moves payments for Russian and other sanctioned customers through "Sub-Agent" companies in third countries that appear as the paying party on trade documents, and Iran (including its central bank and the IRGC) has used it. FinCEN issued a finding and proposed rule under section 9714(a) of the Combating Russian Money Laundering Act, treating transactions involving any foreign company controlled by the network as a class of primary money laundering concern. The proposal would prohibit transmittals of funds involving the Sub-Agents. FinCEN also issued Alert FIN-2026-Alert007, which: asks institutions to cite the key term "FIN-2026-A7NETWORK" in SARs reports that, as of June 2026, the network ran hundreds of Sub-Agents with accounts at about 435 institutions in at least 83 countries reports that more than 180 entities processed at least $179.1 billion in A7A5 ruble-backed stablecoin transactions between February 2025 and June 2026 lists red flags covering Sub-Agent use, invoice falsification and digital asset abuse (Here)

• The US Department of Justice announced the arrest on 1 October 2026 of the owner of a California technology company on a three-count indictment (returned 29 September, Central District of California) for smuggling more than $300 million in high-end computer servers containing export-controlled US-made GPUs to China. Between 2023 and 2024, he allegedly bought the servers from US manufacturers using false end-user documentation, shipped them to Malaysia and Singapore, where no licence is required, and re-exported them to China without the required Commerce Department licences. His company allegedly received more than $176 million from two Malaysia-based shipment companies between January and October 2024. He is charged with conspiracy to violate the Export Control Reform Act and the Export Administration Regulations (maximum 20 years), outbound smuggling (maximum 10 years) and conspiracy to commit money laundering (maximum 20 years). The case is being investigated by Commerce's Office of Export Enforcement, the Defense Criminal Investigative Service and the FBI. (Here)

Friday, October 2

• OFAC imposed blocking sanctions on three individuals (one in Gaza, two in France) and two entities (both in France) under its Counter Terrorism sanctions program (E.O. 13224, as amended by E.O. 13886) for financing Hamas. The individuals are a Gaza-based deputy battalion commander in Hamas's Al-Qassam Brigades who oversees a network using money services businesses and cryptocurrency wallets to fund the group, and two France-based fundraisers who ran purported humanitarian charities. The two entities are charities, each controlled by one of the French fundraisers. The network collected more than $2 million for Hamas between 2020 and 2026, including $1.5 million after 7 October 2023, partly in cryptocurrency sent directly to the Gaza-based member for onward transfer. (Here) The DoJ also took action simultaneosly by the unsealing of an indictment charging an individual, as well as the arrests of three individuals for their involvement in paying, soliciting and collecting funds for Hamas.