Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

On 26 May 2026 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £1,000,920.59 monetary penalty on Sabre Global Technologies Limited (SGTL), a UK-registered travel-technology firm, for repeated breaches of UK financial sanctions. SGTL continued to provide Russian carrier Ural Airlines access to its Global Distribution System (GDS) service for seven months after Ural Airlines was designated by the UK in May 2022, and during July–August 2022 actively explored routing payments through a US bank account to avoid detection by its UK bank — the conduct that makes this the **first OFSI penalty issued for a circumvention offence**. At £1,000,921 this is also OFSI's **largest financial-sanctions penalty since Russia's 2022 invasion of Ukraine**, surpassing the prior record (HSF £465k).

The UK laid the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (SI 2026/543) before Parliament on 19 May 2026; it came into force on 20 May 2026. The instrument inserts a new Chapter 4KA (regulations 46Z23A-46Z23G) into the Russia (Sanctions) (EU Exit) Regulations 2019, prohibiting the import into the UK of uranium (HS 2844.10/2844.20/2844.30) that originates in or is consigned from Russia, the direct or indirect acquisition of Russian-origin or Russia-located uranium, and the supply or delivery of uranium from Russia to a third country — plus associated technical assistance, financial services/funds, and brokering services. Each prohibition carries a criminal offence with a reasonable-cause-to- suspect defence, subject to narrow exceptions and licensing grounds at regulations 16-19 of the amending instrument. The same instrument separately extends the existing ban on imports of relevant (2709-origin) Russian crude to cover oil products refined from that crude in a third country (new regulations 46Z9F-46Z9I).

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 18 May 2026 that Adani Enterprises Limited (AEL), a flagship publicly traded entity of India's Adani Group (NSE: ADANIENT), agreed to pay $275,000,000 to settle apparent civil liability for violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) arising from AEL's purchases of liquefied petroleum gas (LPG) shipments through a Dubai-based commodity trader between November 2023 and June 2025, where red flags should have placed AEL on notice that the LPG originated from Iran. Approximately $192 million in payments for the Iranian-origin LPG shipments were processed through US financial institutions, providing the US nexus for OFAC jurisdiction. OFAC determined the apparent violations were EGREGIOUS and not voluntarily self-disclosed; AEL did not admit fault but committed to implementing enhanced compliance measures. The settlement is the largest OFAC enforcement action against an Indian corporate entity on record and was announced concurrently with parallel DOJ and SEC resolutions forming part of a broader US legal-relief package for the Adani Group.

On 2 May 2026, MOFCOM issued Announcement No. 21 of 2026 — the first concrete prohibition order ever issued under China's 2021 "Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures" (Blocking Rules) and the Anti-Foreign Sanctions Law (AFSL). The order prohibits any Chinese organisation, individual, or foreign party operating in China from recognising, enforcing, or complying with US sanctions imposed under Executive Orders 13902 and 13846 against five Chinese independent ("teapot") refineries — Hengli Petrochemical (Dalian) Refining Co., Ltd., Shandong Shouguang Luqing Petrochemical Co., Ltd., Shandong Jincheng Petrochemical Group Co., Ltd., Hebei Xinhai Chemical Group Co., Ltd., and Shandong Shengxing Chemical Co., Ltd. — all designated by OFAC for purchasing Iranian crude. The announcement is the first operational test of the framework built up across the AFSL (2021), the AFSL Implementation Regulations (Order 803, March 2025), and State Council Order 835 on Countering Foreign Unlawful Extraterritorial Jurisdiction (April 2026), and creates a direct compliance conflict for banks, insurers, traders, and shipping companies operating in or with China that had been winding down their exposure to the listed refineries.

President Trump signed Executive Order 14404, "Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy," on 1 May 2026. The order operationalises the country-specific national emergency declared by EO 14380 (29 January 2026) — which had been preserved after the SCOTUS *Learning Resources* vacatur of the IEEPA tariff authority — by establishing a sectoral OFAC blocking regime. Section 2 authorises asset-blocking against any foreign person determined by the Secretary of Treasury (in consultation with State) to operate in Cuba's energy, defense and related materiel, metals and mining, financial services, or security sectors, or "any other sector" subsequently designated. Section 3 suspends entry under INA § 212(f) for covered aliens. Section 4 authorises secondary sanctions against foreign financial institutions that knowingly conduct or facilitate significant transactions for blocked persons, with both correspondent-account and SDN-listing remedies. The EO itself includes no annex of named designations — those are issued by OFAC under separate determinations.

On May 1, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated China-based independent ("teapot") refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. — described as China's second-largest teapot — together with approximately 40 shipping firms and vessels operating as part of Iran's shadow fleet. OFAC sanctioned 19 shadow-fleet vessels (crude, LPG, and petrochemical tankers) as blocked property of designated owners or managers. The action was taken under Executive Order 13902 (Iran petroleum and petrochemical sectors) in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. Treasury press release SB0472. Concurrent with the designations, OFAC issued Iran-related General License W authorising the wind-down of transactions involving the persons newly blocked on May 1, 2026, and published a structurally novel Iran-related Alert, "Sanctions Risks of Iranian Demands for Strait of Hormuz Passage." The Alert states that payments to the Government of Iran or the IRGC — directly or indirectly — for safe passage through the Strait of Hormuz are not authorised for US persons (including US financial institutions) or US-owned/-controlled foreign entities. OFAC also issued new FAQ 1250 to accompany the Alert and GL W. The wave is one of the largest single-day Iran enforcement actions of the Trump 2.0 administration. Treasury characterises it as part of a campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The Strait of Hormuz Alert is the operational US response to Iranian regulatory threats against the ~20% of global oil and ~25% of global LNG transiting Hormuz, putting tanker owners, P&I clubs, flag states, and oil-buyer compliance teams on direct notice.

On April 30, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added former Democratic Republic of the Congo President Joseph Kabange Kabila to the Specially Designated Nationals (SDN) List pursuant to Executive Order 13413, as amended by Executive Order 13671 (the DRC sanctions program), for having materially assisted, sponsored, or provided financial, material, or technological support to the March 23 Movement (M23) and its political-military coalition the Congo River Alliance (Alliance Fleuve Congo, AFC). Treasury press release SB0480 ("Treasury Sanctions Former Democratic Republic of the Congo President for Ties to Armed Conflict") frames the designation as enforcement of the Washington-brokered DRC-Rwanda framework: M23 controls a substantial share of mineral-rich eastern DRC (cobalt, coltan, tin, tungsten, gold) and AFC's renewed rebellion has fuelled a mass-displacement crisis. The notice was published in the Federal Register on May 5, 2026 (FR Doc. 2026-08672). The designation blocks all property and interests in property of Kabila subject to US jurisdiction and prohibits US-person dealings with him. It is a discrete enforcement step under the broader US-DRC Strategic Partnership Agreement (4 December 2025 — the "Washington Accords") and complements earlier 2026 designations of Rwanda Defence Force-linked actors. Treasury frames the action as signalling that political support to M23/AFC, not just direct military or commercial activity, will trigger blocking sanctions.

On 23 April 2026, the Council of the European Union adopted the 20th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2026/506 amending Regulation 833/2014 (sectoral sanctions) and Council Regulation (EU) 2026/511 amending Regulation 269/2014 (asset-freeze listings — 120 additional individuals and entities, the largest single tranche in two years). The package operationalises and extends the crypto-sanctions architecture introduced in the 19th package and constructs the legal scaffolding for a future full prohibition on maritime services to vessels carrying Russian crude/petroleum products. Headline measures: (i) full sectoral prohibition on transactions with crypto-asset service providers and exchange platforms established in Russia or Belarus, plus designation of the rouble-backed stablecoin RUBx and the digital rouble (CBDC) on Annex LIII — effective 24 May 2026, with EU support for the digital rouble's development banned outright; (ii) 36 new energy-sector listings spanning upstream extraction, refining and transportation; (iii) prohibition on providing technical, financial, brokering and insurance services to Russia-flagged, Russian-certified or Russian-managed LNG tankers and icebreakers effective 25 April 2026, extending to foreign-flagged vessels operating in Russian interests by January 2027 and culminating in a categorical ban on LNG terminal services to Russian-controlled entities on 1 January 2027; (iv) full transaction ban on 20 Russian banks plus four third-country banks listed for SPFS connectivity / sanctions circumvention; (v) 46 newly listed shadow-fleet vessels and new tanker sale-due-diligence obligations on EU shipping operators; (vi) 58 designations of companies and associated individuals in the Russian military-industrial complex including drone developers/manufacturers; (vii) further Annex IV third-country circumvention enabler listings (China, Hong Kong, Turkey, UAE); (viii) parallel measures against Belarus. Entry into force on 24 April 2026 (day following publication in OJ L_202600506), except for measures with explicit deferred application dates.

On 25 February 2026 the Swiss Federal Council adopted extensive amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (Ukraine Ordinance) and the Ordinance on Measures against Belarus, completing implementation of the EU's 19th sanctions package with effect from 26 February 2026. Headline measures: a complete ban on the purchase and import of Russian LNG taking effect 25 April 2026 (transition period until end-2026 for pre-existing long-term contracts); a complete prohibition on the provision of crypto-asset services to Russian persons and companies; new service bans covering advanced-technology / AI / high-performance-computing services and tourism-related services; expansion of the dual-use end-user list (Annex 2) including additional Chinese entities; SECO authority to grant divestment-exemption licences until end-2026 under Art. 30a; and parallel adoption of the EU October 2025 Belarus measures via amendment to the Belarus Ordinance.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 25 February 2026 that a U.S. person agreed to pay $3,777,000 to settle potential civil liability for 20 apparent egregious violations of the Syrian Sanctions Regulations (31 CFR Part 542) occurring between January 2018 and December 2021. The individual provided managerial services — reviewing and signing financial statements, approving operational and employee expenses, and supervising service-fee collection — as an officer and board member of four Syrian real-estate companies supporting luxury real-estate development projects in Syria. OFAC determined the conduct was egregious and not voluntarily self-disclosed, setting the settlement at 10× the statutory IEEPA base amount per apparent violation (the maximum egregious multiplier) and establishing a significant personal-liability precedent for U.S. persons serving on boards or in officer roles of companies in sanctioned jurisdictions.

On 7 February 2026 Ukrainian President Volodymyr Zelenskyy signed Presidential Decree No. 103/2026, enacting a National Security and Defence Council (NSDC) decision to apply personal special economic and other restrictive measures (sanctions) against 42 individuals and 35 legal entities based in Russia, Kyrgyzstan and the United Arab Emirates. The tranche specifically targets the "A7" cryptocurrency payment ecosystem, which Ukraine assesses is used to settle payments for components supplied for Russian missile production, alongside wider financial-sector sanctions-circumvention activity. Designation imposes asset freezes and a bar on commercial transactions and investment instruments involving the designees; the decree entered into force on 10 February 2026.

The Council of the EU adopted Implementing Regulation (EU) 2026/262, implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran's military support to Russia's war of aggression against Ukraine. The listing adds 4 individuals and 6 entities to the EU asset freeze, bringing the total under this regime to 24 individuals and 26 entities. Newly listed entities include Fanavaran Sanat Ertebatat Company and front-company trader Sahara Thunder (UAV electronic components and guidance systems), and Shahid Bagheri Industrial Group, Khojir Missile Development and Production, and procurement firm Pishgaman Tejarat Rafi Novin Co. (ballistic missile manufacturing and propellant-precursor procurement). All funds and economic resources of the listed parties are frozen within the EU, and EU persons/entities are barred from making funds available to them.

On 29 January 2026 Switzerland's Federal Department of Economic Affairs, Education and Research (WBF) amended Annex 28 of the Ordinance on Measures Relating to the Situation in Ukraine (SR 946.231.176.72), lowering the price cap on Russian seaborne crude oil from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. The amendment prohibits Swiss-domiciled operators from providing financial and transport (maritime, insurance, brokering) services related to Russian crude oil priced above the new cap. Switzerland is not an EU member but autonomously aligns its Ukraine Ordinance with EU sanctions packages; this cut mirrors the EU's Implementing Regulation 2026/124 and the UK OFSI general licence amendment adopted two weeks earlier under the same six-monthly dynamic-adjustment formula.

On January 23, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated eight vessel-owning/management firms — based in the UAE, India, Oman, the Seychelles, and the Marshall Islands — and identified nine of their tankers as blocked property, for transporting hundreds of millions of dollars' worth of Iranian crude oil, LPG, naphtha and high-sulfur fuel oil to buyers across East Asia, South Asia and East Africa. The action was taken under Executive Order 13902 (Iran petroleum/petrochemical sector) as part of the maximum-pressure campaign under National Security Presidential Memorandum 2, and OFAC concurrently issued General License T authorizing limited safety, environmental and cargo-offloading transactions involving the newly blocked vessels.

On 14 January 2026 the European Commission adopted Implementing Regulation (EU) 2026/124, amending Annex XXVIII to Council Regulation (EU) No 833/2014, lowering the price cap on seaborne Russian crude oil (CN code 2709 00) from USD 47.6 to USD 44.1 per barrel, effective 1 February 2026. This is the first application of the automatic dynamic-adjustment mechanism introduced by the 18th sanctions package (Council Regulation (EU) 2025/1494, July 2025), which re-indexes the cap every six months to 15% below the 22-week trailing average Urals market price. Contracts concluded before 31 January 2026 with cargo offloaded by 16 April 2026 remain subject to the prior USD 47.60/bbl cap. The UK aligned with an equivalent reduction the same day.

On 15 January 2026 the UK Office of Financial Sanctions Implementation (OFSI), acting under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, amended the 'Oil Price Cap' General Licence (INT/2024/4423849) to lower the price cap on Russian seaborne crude oil from USD 47.60 to USD 44.10 per barrel, effective 23:01 on 31 January 2026. Contracts signed at the prior USD 47.60 cap before that time are subject to a wind-down period, remaining valid provided the oil is offloaded at the port of destination by 22:59 on 16 April 2026. The cut applies the six-monthly dynamic-adjustment formula (15% below the 22-week trailing average Urals price) and was announced in lockstep with the EU's equivalent Implementing Regulation 2026/124.

Ukraine's President Volodymyr Zelenskyy signed Decree No. 8/2026 on 3 January 2026, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 95 individuals and 70 legal entities, the large majority of them Russian citizens, residents, and companies. The designees manufacture or supply communications equipment, radio-electronic warfare (REB) systems, and microelectronics for Russia's defense-industrial complex, alongside chemical, mining, metallurgical, and fuel-and-energy-sector entities and their managers. The decree entered into force on 6 January 2026, the date of official publication.

Presidential Decree No. 1011 of 31 December 2025 amends the standing Decree No. 302 (25 April 2023) list of foreign-owned assets under "temporary management," adding 100 percent of the shares in Rockwool LLC and 68 percent of the shares in Rockwool-Volga LLC — the Russian operating subsidiaries of Danish insulation producer ROCKWOOL A/S — and transferring control to Construction Assets Development JSC (Развитие Строительных Активов, "RSA"), a newly formed Russian administrator. The decree entered into force on its date of official publication (13 January 2026) despite being signed two weeks earlier, and covers four ROCKWOOL factories (Moscow, Leningrad and Chelyabinsk regions, and Tatarstan) producing heat and sound insulation. ROCKWOOL A/S disclosed in a 13 January 2026 regulatory announcement to Nasdaq Copenhagen that it has determined it has lost control of the four plants.

Presidential Decree No. 1012 of 31 December 2025 amends the standing Decree No. 302 (25 April 2023) list of foreign-owned assets under "temporary management," adding 100 percent of the shares in Can-Pak LLC (owned by Poland's Canpack S.A.) and Can-Pak Packaging Plant LLC (owned by Tapon France) — the two Russian operating subsidiaries of the CANPACK Group's aluminium-beverage-can business — and transferring control to StalElement LLC, a newly formed Russian administrator. The decree entered into force on its date of official publication (13 January 2026) despite being signed two weeks earlier, and covers Can-Pak's Volokolamsk (Moscow region) and Novocherkassk plants, which together hold an estimated 25-35% share of Russia's aluminium-can market. It is one of a running series of company-specific amendments to Decree 302, Russia's mechanism for placing Russian assets of "unfriendly state" companies under state administration in reciprocal response to Western sanctions and asset freezes.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) designated 10 individuals and entities in Venezuela and Iran on 30 December 2025 for facilitating Iran's proliferation of unmanned aerial vehicles (UAVs) and ballistic-missile inputs. Venezuela-based Empresa Aeronautica Nacional SA (EANSA) and its chair, Jose Jesus Urdaneta Gonzalez, were designated for negotiating directly with Iran's Qods Aviation Industries (QAI) and overseeing local assembly of QAI's Mohajer-series UAVs, re-branded in Venezuela as the ANSU series — an arrangement OFAC states has run since 2006. Separately, three Iran-based persons were designated for procuring sodium perchlorate, sebacic acid and nitrocellulose — precursor chemicals for ballistic-missile propellant and warhead production — on behalf of Parchin Chemical Industries (PCI), a unit of Iran's Defense Industries Organization (DIO). The action was taken under Executive Order 13382 (WMD proliferators and supporters) and Executive Order 13949 (Iran conventional-arms activities), in furtherance of National Security Presidential Memorandum 2.

China's Ministry of Foreign Affairs announced on 26 December 2025 that it is imposing countermeasures under Articles 3, 4, 5, 6, 9 and 15 of the Law of the People's Republic of China on Countering Foreign Sanctions against 20 US defense-related companies and 10 senior executives, in response to the Trump administration's 18 December 2025 announcement of roughly $11.1bn in arms sales to Taiwan — the largest single US weapons package for the island to date. Measures freeze the named entities' assets within China, prohibit organizations and individuals in China from transacting or cooperating with them, and deny visas/entry to the named executives. This is a Foreign Ministry Anti-Foreign Sanctions Law designation, distinct in legal basis from MOFCOM's parallel Unreliable Entity List mechanism used in prior 2025 Taiwan-arms-sale tranches (e.g. the 9 April 2025 six-firm UEL listing).

The Council of the European Union adopted Regulation (EU) 2025/2618 on 18 December 2025, amending Regulation (EU) No 833/2014, to add 41 vessels to Annex XLII of the Russia sanctions regime. Of these, 36 vessels are designated for transporting Russian crude oil and petroleum products while engaging in irregular and high-risk shipping practices characteristic of the "shadow fleet," 5 vessels are designated for transporting stolen Ukrainian grain and cultural property, and 1 vessel (GT HONOR) is designated for facilitating violation or circumvention of EU sanctions. Listed vessels are banned from access to EU member-state ports and locks and from a broad range of maritime-transport-related services, effective 19 December 2025. The measure is an incremental listing update between the 19th (Regulation 2025/2033, October 2025) and 20th (Regulation 2026/506, April 2026) numbered sanctions packages, rather than a new package itself.

HM Treasury's Office of Financial Sanctions Implementation (OFSI) published a Russia-regime notice on 18 December 2025 designating five individuals and 19 entities under the Russia (Sanctions) (EU Exit) Regulations 2019. Of the 19 entities, six are based in Russia, eight in the United Arab Emirates, four in Uzbekistan and one in Kyrgyzstan — reflecting OFSI's continued focus on third-country intermediaries used to route sanctioned Russian trade and finance. Designated persons are subject to a full asset freeze and are barred from commercial transactions and investment instruments with UK persons.

On December 18, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated 29 shadow-fleet vessels and 17 vessel-management/shipping firms — plus Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr and two of his UAE-registered companies (Red Sea Ship Management LLC and High Seas Petroleum LLC) — under Executive Order 13902 for operating in Iran's petroleum sector. The vessels, flagged across Palau, Panama, Cook Islands, Barbados, Jamaica and unknown registries, are said to have transported "hundreds of millions of dollars'" worth of Iranian crude oil, fuel oil, bitumen, naphtha and condensate to buyers in Asia. Treasury frames the action as part of a campaign that has sanctioned more than 180 vessels since President Trump resumed office in January 2025, implementing NSPM-2 maximum-pressure policy.

On 15 December 2025 the Council of the European Union adopted Council Implementing Regulation (EU) 2025/2588 and Council Decision (CFSP) 2025/2594, giving effect to Regulation (EU) No 269/2014 (Ukraine territorial-integrity asset-freeze regime) by adding 9 new designations: 5 individuals who own or control companies enabling Russian oil shipments and controlling a significant share of Russia's "shadow fleet," and 4 shipping companies headquartered in Russia, the United Arab Emirates and Vietnam that manage shadow-fleet tankers and engage in irregular, high-risk shipping practices. Listed persons and entities are subject to an EU asset freeze (and, for the individuals, a travel ban); EU persons and companies are prohibited from making funds or economic resources available to them.

On 12 December 2025 the Swiss Federal Council adopted the first tranche of listings aligning with the EU's 19th Russia sanctions package (Council Regulation (EU) 2025/2033, 23 October 2025), amending the Ordinance on Measures in Connection with the Situation in Ukraine and the Belarus Ordinance with effect from 13 December 2025. The decision adds asset freezes and entry/transit bans for 22 natural persons and 42 entities tied to Russia's military-industrial complex, energy sector and shadow-fleet vessel management; extends purchase/sale/insurance bans to over 100 additional tankers; imposes transaction restrictions on 5 Russian banks and 4 Russian-bank branches in Belarus and Kazakhstan for use of specialised financial-messaging services; sanctions Chinese and Hong Kong trading companies and refineries implicated in circumventing the G7 oil price cap; and designates 5 Belarusian persons linked to military-industrial activities. Divestment-exemption deadlines for Swiss persons winding down Russian holdings are extended to end-2026. This is a partial, listings-only tranche — the more substantive measures of the EU's 19th package (Russian LNG import ban, crypto-services prohibition, AI/HPC service bans) were not adopted until the Federal Council's follow-on decision of 25 February 2026.

On 11 December 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated six shipping companies — registered in the Marshall Islands (4), British Virgin Islands (1), and the United Kingdom (1) — and their six crude-oil tankers as blocked property under Executive Order 13850 for operating in Venezuela's oil sector. The vessels (WHITE CRANE, KIARA M, MONIQUE, LATTAFA, H. CONSTANCE, and TAMIA) had loaded Venezuelan crude in September/October 2025 and allegedly used AIS spoofing and other deceptive shipping practices to evade detection. The same action separately designated four individuals — including two nephews of Cilia Flores (Nicolas Maduro's wife) under the counter-narcotics authority EO 14059, a former PDVSA official under EO 13692, and a Panamanian facilitator under EO 13850 — but the shipping-company/tanker designations are the action's primary trade-control component.

The UK Foreign, Commonwealth & Development Office designated two China-based commercial cyber companies — Sichuan Anxun Information Technology Co Ltd (known as i-Soon) and Integrity Technology Group Incorporated — under the UK's Cyber sanctions regime, freezing their UK assets and imposing controls on commercial transactions and investment instruments involving them. i-Soon was designated for targeting over 80 government and private-sector IT systems worldwide, including UK public-sector and private-industry networks. Integrity Tech was designated for operating a covert botnet of more than 260,000 compromised devices globally and supplying access to it to enable unauthorised intrusion into UK public-sector systems.

On 4 December 2025, OFAC assessed a near-statutory-maximum civil monetary penalty of USD 7,139,305 against Gracetown Inc., a New York-based property-management company, for 24 apparent violations of Russia-related sanctions under EO 13660, EO 13661, and EO 14024 between April 2018 and May 2020, and for separately failing to report blocked assets for over 45 months in violation of 31 CFR §501.603. Gracetown was established in 2006 to manage three luxury real-estate properties in Manhattan and Washington DC ultimately owned by sanctioned Russian oligarch Oleg Deripaska; after Deripaska's April 2018 SDN designation — which OFAC communicated directly to Gracetown — the company continued processing 24 payments totalling USD 31,250 on behalf of a Deripaska-linked British Virgin Islands entity (Baufinanz). OFAC found the violations egregious and not voluntarily self-disclosed, driving the penalty to 80% of the USD 8,906,358 statutory ceiling; the ratio of penalty (USD 7.14M) to underlying transaction value (USD 31,250) underscores OFAC's strict liability approach to post-notice dealings.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into an $11,485,352 settlement with IPI Partners, LLC — a US private-equity data-center fund manager (~$10.5bn AUM) — to resolve 51 apparent violations of the Ukraine-/Russia-Related Sanctions Regulations between July 2018 and June 2022. IPI solicited and accepted two $25 million fund subscriptions in September 2017 and March 2018 from Definition Services, Inc. — a British Virgin Islands entity ultimately owned by Heritage Trust, a Delaware family trust established by sanctioned Russian oligarch Suleiman Kerimov — and continued processing 18 capital calls, 20 distributions, and 13 management-fee payments for four years after Kerimov's April 2018 SDN designation. OFAC simultaneously issued an unusually direct sectoral warning to the private-equity industry, marking the first major OFAC enforcement against a US PE-fund administrator in the data-center / AI-infrastructure segment and the second Kerimov-linked PE/VC settlement of 2025 (after the June 2025 $216M GVA Capital statutory-maximum penalty).

Ukraine's President signed Decree No. 870/2025 on 29 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 26 Russian legal entities involved in crude petroleum and natural gas extraction, petroleum-product refining, and related energy-sector activity. The decree imposes asset freezes and bars commercial transactions and investment dealings with the designated entities. It entered into force on 2 December 2025, the date of official publication.

Ukraine's President signed Decree No. 860/2025 on 25 November 2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 41 legal entities that collectively own 56 maritime vessels. The vessels are alleged to have made illegal port calls at Sevastopol and Feodosia — Ukrainian ports under temporary Russian occupation — to load and export stolen Ukrainian wheat, sunflower seeds, and other food commodities between 2022 and 2025. The sanctions (asset freezes, restrictions on commercial transactions and transit, and foreign- customer limitations) apply for a term of 10 years and entered into force on 27 November 2025, the date of official publication.

On 24 November 2025, OFAC assessed a civil monetary penalty of USD 4,677,552 — the statutory maximum and the largest single OFAC penalty ever imposed against an individual — against an Atlanta-based real-estate investor operating through King Holdings LLC. Between April 2023 and March 2024 the respondent willfully purchased, mortgaged, renovated, and resold US residential property beneficially owned by a family member of a Russian oligarch sanctioned under EO 14024, in direct violation of a prior OFAC cease-and-desist order and in defiance of an administrative subpoena. OFAC found the violations egregious and non-self-disclosed; both aggravating factors drove the penalty to the statutory ceiling.

Canada made SOR/2025-228, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-11-06 and announced by Minister Anand on 2025-11-12. The regulations add 13 individuals to Part 1 of Schedule 1, 11 entities to Part 2 of Schedule 1, and 100 vessels (by IMO number) to Schedule 1.1, freezing their Canadian assets and prohibiting dealings. Targets include Russian LNG-trading entities, drone-programme developers, cyber-infrastructure suppliers for hybrid operations against Ukraine, and Kyrgyzstan-based financial enablers (including Capital Bank of Central Asia and the A7 payments platform) used to evade earlier Russia sanctions. The 100-vessel designation targets Russia's "shadow fleet" used to move crude oil, LNG and arms while evading the G7 price cap and flag-state controls.

The US Treasury's Office of Foreign Assets Control designated 32 individuals and entities based in Iran, the UAE, Turkiye, China, Hong Kong, India, Germany and Ukraine for operating procurement networks that supply Iran's ballistic missile and UAV programmes, including missile propellant precursors and UAV components. The action is Treasury's second round of nonproliferation sanctions since the 27 September 2025 reimposition of UN sanctions on Iran ("snapback") over its non-compliance with international nuclear and missile commitments. Designated entities include Iran-based Kimia Part Sivan Company (KIPAS), which Treasury says has worked with the IRGC-Qods Force to advance Iran's UAV programme. All property and interests of the designated parties subject to US jurisdiction are blocked, and US persons are generally prohibited from transacting with them.

New Zealand's 33rd sanctions round under the Russia Sanctions Act 2022 designated 65 "shadow fleet" tanker vessels involved in transporting Russian-origin crude oil, together with seven entities and two individuals based in Russia, Belarus, North Korea and Iran that refine or transport Russian oil or facilitate oil-related payments. Designated parties are subject to asset freezes and prohibitions on the supply of services (including port access, insurance, chartering and cargo handling) by New Zealand persons. The measure targets the revenue chain funding Russia's war in Ukraine rather than imposing a new tariff or trade-flow control.

On 29 October 2025 the Swiss Federal Council amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 662, completing Switzerland's alignment with the remaining goods, finance and services elements of the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025) and tightening the parallel Belarus regime. The amendment took effect 30 October 2025 and adds: an export ban covering additional structural-metal, general-purpose-machinery and machine-tool goods; an import ban on further petroleum-oil products and waste/scrap categories; and expanded controls on commercial transactions and investment instruments spanning financial services, investment banking, crude-petroleum trade and motor-vehicle/trailer goods. The Federal Department of Economic Affairs (WBF) had already taken over the measures within its own competence on 12 August 2025; this decision closes the remainder. In parallel, the Federal Council's asset-freeze annexes were extended to 14 individuals and 41 companies/organizations.

On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.

On 23 October 2025, the Council of the European Union adopted Council Regulation (EU) 2025/2041 (amending Regulation (EC) No 765/2006) and Council Decision (CFSP) 2025/2040 (amending Decision 2012/642/CFSP), widening the EU's Belarus restrictive-measures regime in lockstep with the 19th Russia sanctions package adopted the same day. The package widens the export ban to industrial goods (salts, ores, rubber articles, tyres, millstones, construction materials, electronic components, rangefinders, propellant chemicals, metals/oxides/alloys), extends the import ban to all acyclic hydrocarbons, introduces a new prior-licensing requirement for services supplied to Belarus, its government, or public bodies, and mirrors the Russia regime's space, AI, and high-performance/ quantum-computing service restrictions. A companion instrument, Council Implementing Regulation (EU) 2025/2039, adds 5 new asset-freeze listings (2 individuals + 3 entities, including JSC Holography Industry, Horizont Holding, and ICT Horizont). Entered into force 24 October 2025.

On October 22, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) added Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil") — together with dozens of named Russia-based subsidiaries — to the Specially Designated Nationals (SDN) List under Executive Order 14024 for "operating or having operated in the energy sector of the Russian Federation economy." It is the first US designation of Russia's two largest integrated oil majors since the 2022 invasion-era sanctions architecture began. Under OFAC's 50% Rule, the blocking extends automatically to all entities owned 50% or more, directly or indirectly, by Rosneft or Lukoil — capturing a sprawling global subsidiary network including Lukoil retail/refining assets in Belgium, Netherlands, Bulgaria, Romania, Italy, Finland, the West Qurna-2 upstream stake in Iraq, and Lukoil Americas. Rosneft and Lukoil together account for roughly half of Russian crude exports (~5 mb/d combined production) and Lukoil holds a ~9% European retail-fuel market share. OFAC simultaneously issued General License 124 (Caspian Pipeline Consortium / Tengizchevroil / Karachaganak Kazakhstan-pipeline carve-out, no expiry), General License 125 (Lukoil retail service stations outside Russia, wind-down to November 21, 2025), General License 126 (general wind-down to November 21, 2025) and General License 127 (debt/equity divestment and derivatives wind-down to November 21, 2025). GL 131 (issued November 14, 2025) opened a divestment window for Lukoil International GmbH; subsequent GL 134/134A/134B extended cargo-offload authorisations through April–May 2026. The action was coordinated same-day with UK OFSI Rosneft/Lukoil designations and the EU's 19th Russia sanctions package adopted October 23, 2025 — the first major US-led Russia-energy escalation under the second Trump administration.

On 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.