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Structured register of government actions in the geoeconomic space — export controls, tariffs, sanctions, FDI screening, subsidies, industrial-policy laws — cross-referenced into the country, minerals, and ETF surface. Charter: docs/IPTM_CHARTER.md.
Severity 1-5 is the qualitative impact rating (1=minor, 5=structural). The bilateral-trade-grounded quant scorer is the next IPTM milestone. RBI (Register Breadth Index) is a complementary structural-breadth indicator from scripts/py/iptm/breadth.py; divergence between RBI and severity is itself informative (high-sev / low-RBI = strategic chokepoint; low-sev / high-RBI = broad but shallow). Every action has at least one primary source URL. Verify-or-don't-file. See also themes, timeline, graph, sankey, map, country exposure, sector exposure, material exposure (+ graph), weekly briefs, portfolio scan, escalation monitor, trans-shipment hubs. Internal triage tools (RSS-poller candidate feed, source-feed health) live under /admin/candidates + /admin/sources. Subscribe via Atom feed (accepts ?country=CN, ?material=lithium, ?issuer=BIS, ?type=export_control, ?etf=SOXX, ?company=NVDA, ?minSeverity=4, ?year=2026, ?q=…) or pull /api/iptm/actions.
The UK Department for Business and Trade and the Office of Trade Sanctions Implementation published two General Trade Licences, one each for Japan and South Korea, authorising UK persons to continue providing maritime transportation and related services for liquefied natural gas sourced from Russia's Sakhalin-2 project and delivered to those two countries. Both licences run from 1 January 2027 to 31 March 2028, succeed a narrower licence due to expire 1 January 2027, and are restricted to LNG supplied under contracts concluded before 17 June 2025 — no new contracts and no dealing with designated persons are authorised. The carve-out is issued under the Russia (Sanctions) (EU Exit) Regulations 2019, the same instrument under which UK maritime-transport restrictions on Russian LNG otherwise apply from 1 January 2027.
On 1 October 2026 the UK government designated 23 individuals and entities and 8 vessels under the Russia (Sanctions) (EU Exit) Regulations 2019. The package targets Russia's "war chest" financing via shadow-fleet LNG tankers evading sanctions, seven individuals spreading pro-Kremlin disinformation, eight people involved in the arbitrary detention and torture of Ukrainian civilians, and seven individuals involved in the militarisation and deportation of Ukrainian children. Designated persons are subject to UK asset freezes and travel bans; the eight vessels are added to the UK's shadow-fleet shipping-sanctions list.
The Council of the EU adopted Council Implementing Regulation (EU) 2026/2191 of 28 September 2026, implementing Regulation (EC) No 1183/2005 concerning restrictive measures in view of the situation in the Democratic Republic of the Congo. The regulation adds Alliance Fleuve Congo (AFC) as a listed entity and four individuals — Charles Sematama, Gustave Kubwayo, Corneille Nangaa Yobeluo and John Imani Nzenze — to Annex I, subjecting them to an EU-wide asset freeze. The listing transfers these five parties from the EU's autonomous DRC sanctions track into the annex implementing corresponding UN Security Council Sanctions Committee designations made on 14 July 2026 under Resolution 1533 (2004), which the UN describes as targeting AFC's political, logistical and operational support to the M23/ARC armed group in eastern DRC.
The Council of the European Union added 10 individuals and 17 entities to the Ukraine territorial-integrity sanctions list (Regulation (EU) No 269/2014 / Decision 2014/145/CFSP) for the unlawful deportation, forcible transfer and forced assimilation of Ukrainian children, including through indoctrination and militarised education. Listed persons and entities are subject to an EU asset freeze and a prohibition on EU persons/companies making funds or economic resources available to them; natural persons also face an EU travel ban. Adopted via Council Implementing Regulation (EU) 2026/2184 (listing instrument) and the accompanying Council Decision (CFSP) 2026/2185, both dated 28 September 2026 and effective on publication.
The Council of the European Union listed 10 Russian individuals — including three Supreme Court judges, an official of the Prosecutor General's Office, and the judges/prosecutors involved in sentencing Yabloko deputy chair Lev Shlosberg to over 11 years in prison — under the EU's Russia human-rights sanctions regime (Decision (CFSP) 2024/1484 / Regulation (EU) 2024/1485), for suppressing freedom of expression, information and association in connection with the barring of the opposition party Yabloko from the September 2026 State Duma elections. Adopted via Council Implementing Regulation (EU) 2026/2193 and Council Decision (CFSP) 2026/2192, both dated 28 September 2026. Listed persons face an EU asset freeze, a prohibition on EU persons/companies making funds available to them, and a travel ban.
On 24 September 2026 the Council of the European Union added one individual, Xenia Fedorova, a Russian media figure and former President and Director of Information of RT France, to the EU restrictive-measures regime in view of Russia's destabilising activities, for engaging in foreign information manipulation and interference (FIMI). The listing was made by Council Decision (CFSP) 2026/2164 (amending Decision (CFSP) 2024/2643) and Council Implementing Regulation (EU) 2026/2165 (implementing Regulation (EU) 2024/2642). The regime is in place until 9 October 2026 and is reviewed yearly.
On 22 September 2026 the Council of the European Union adopted Decision (CFSP) 2026/2161 amending Decision 2014/145/CFSP and Implementing Regulation (EU) 2026/2160 implementing Regulation (EU) No 269/2014, prolonging the asset-freeze / travel-ban regime on persons and entities undermining Ukraine's territorial integrity, sovereignty and independence for 36 months, to 22 September 2029, instead of the customary six-month cycle. Annex I is amended to delist Alisher Usmanov, Mikhail Fridman, Andrey Falaleev and the entity Redbird Corporate Services Ltd, to remove three deceased persons, and to update the entries of 104 individuals and 71 entities.
President Trump signed H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, into law on 18 September 2026, after the House concurred in Senate amendments on 16 September 2026 (262-159) and the Senate passed it on 7 August 2026 (86-11). The Act authorizes a 500% tariff on all US imports of Russian-origin goods and up to 100% tariffs on the top five importers of Russian oil and gas and the top five countries supporting Russia's oil "shadow fleet," alongside sanctions on Russian banks, the Russian financial system, and shadow-fleet vessels. It also extends the Iran Sanctions Act through 2031. All tariff/sanctions authority is discretionary: the President may decline to impose it by certifying to Congress that doing so serves the national interest, and may terminate it if Russia agrees to a durable peace with Ukraine. The Act sunsets five years after enactment.
OFAC added four Cuban state-owned nickel-sector enterprises to the SDN List under Executive Order 14404 — Centro de Investigaciones del Níquel (CEDINIQ), Empresa de Ingeniería y Proyectos del Níquel (CEPRONIQUEL), a technical/computing services entity (SERCONI), and Pinares S.A. — alongside three individual Cuban-national designations and a parallel round of military-modernization-linked designations. The action, publicised as "Further Sanctions on Cuba's Mineral Wealth and Military Modernization Apparatus," blocks all US-person transactions and freezes US-touching assets of the named entities, targeting the research, engineering and technical-services layer behind Cuba's nickel extraction and processing industry.
On 15 September 2026, the Council of the European Union adopted Decision (CFSP) 2026/2103, amending Article 6 of Decision 2014/145/CFSP to extend the individual-listings sanctions regime (asset freeze / travel ban on those responsible for undermining Ukraine's territorial integrity, sovereignty and independence) by only seven days, to 22 September 2026, rather than the customary six-month renewal. EU ambassadors (Coreper) failed to reach consensus on the full six-month renewal on 14-15 September 2026 after France and Slovakia demanded the delisting of Russian oligarchs Mikhail Fridman and Alisher Usmanov, forcing a short bridging extension to allow further consultations. The decision itself makes no change to the underlying 132-individual / 77-entity listing set established by the prior six-month renewal (Decision (CFSP) 2026/696 of 14 March 2026); it is a pure continuity measure pending the full renewal decision.
On September 14, 2026, the US Treasury's Office of Foreign Assets Control designated VTB Bank Public Joint Stock Company under Executive Order 13902 (Iran financial-sector sanctions), citing correspondent banking relationships VTB built with sanctioned Iranian financial institutions and settlement systems VTB created for bilateral rial/ruble trade that Treasury says moved frozen Iranian assets. VTB was already designated under EO 13662 (2025) and EO 14024 (2022) for Russia-related conduct; this action adds an Iran-sanctions legal basis and SDN listing, part of the broader "Operation Economic Outcast" campaign Secretary Bessent announced August 24, 2026. No specific dollar figure for the moved assets was disclosed.
On 11 September 2026 the UN Security Council unanimously adopted Resolution 2828 (2026), extending the Sudan sanctions regime established by resolution 1591 (2005) — the Darfur targeted-sanctions list and arms embargo — for one month, through 9 October 2026, and extending the mandate of the associated Panel of Experts through 9 November 2026. The Council characterised the text as a short-term technical rollover, preserving the existing sanctions tool unchanged while members continue to negotiate whether to widen the embargo's geographic scope from Darfur to all of Sudan and expand designation criteria to cover conflict-related sexual violence, kidnapping for ransom, and attacks on humanitarian personnel.
On 7 September 2026 the UK made the Iran (Sanctions) (Amendment) Regulations 2026 (SI 2026/983), laid before Parliament 8 September 2026 and due to come into force 29 September 2026. The instrument substantially rewrites the Iran (Sanctions) Regulations 2023 and the Iran (Sanctions) Regulations 2019, adding new financial restrictions (bans on loans, credit and joint ventures with Iranian manufacturing, oil/gas, petrochemical and uranium interests; a ban on UK banks opening accounts or representative offices for Iranian banks; an insurance/reinsurance ban; a ban on trading Iranian government bonds issued after the regulation date), new trade-control chapters covering gold/precious metals/diamonds, energy-related goods and services, and sectoral software, new import bans on Iranian gold, oil, petrochemicals and natural gas, and new aircraft/shipping parts restricting Iranian cargo flights, chartering of specified vessels, and UK port entry and ship registration for sanctions-evading vessels.
On September 4, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated Istanbul-based Golden Global Yatirim Bankasi Anonim Sirketi (Golden Global Bank) and two affiliates — Golden Global Portfoy Yonetimi Anonim Sirketi and Golden Global Varlik Kiralama Anonim Sirketi — to the Specially Designated Nationals (SDN) List under Iran sanctions authorities. Treasury said the bank facilitated tens of millions of dollars in transactions for the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), giving the Iranian regime correspondent banking access to move funds internationally through the Turkish financial system. OFAC concurrently issued Iran General License CC, authorizing a wind-down of transactions involving the newly blocked persons. The Federal Register formally published GL CC — alongside GL DD, a separate Iran civil-aviation wind-down license issued September 8 — on September 11, 2026.
On 4 September 2026, OFAC issued Iran General License CC, authorizing wind-down of transactions involving Golden Global Yatırım Bankası, Golden Global Varlık Kiralama, and Golden Global Portföy Yönetimi (three linked Istanbul financial entities blocked the same day under E.O. 13902), through 12:01 a.m. EDT on 19 September 2026. On 8 September 2026, following SDN designation of 34 entities and one individual — chiefly Iranian passenger airlines (Air Shiraz, ATA Airlines, Iran Air Tour, Iran Aseman, Mahan-network carriers among others) and their UAE/UK/Malaysia/Kazakhstan support entities — and suspension of Iran General License J-1 (which had authorized reexport of civil aircraft to Iran), OFAC issued General License DD, authorizing wind-down of civil-aviation-related and other transactions previously authorized under the Iranian Transactions and Sanctions Regulations, through 12:01 a.m. ET on 23 September 2026. Both licenses were formally published in the Federal Register on 11 September 2026. Neither license relaxes the underlying restrictions; both are time-limited exit ramps administering an already-restrictive posture.
On September 2, 2026, OFAC amended its Venezuela minerals-sector general licenses to bring coal within their scope and to name a second Venezuelan state-owned company, Carbones del Zulia S.A. ("Carbozulia"), alongside the existing mining SOE CVG Compañía General de Minería de Venezuela C.A. ("Minerven"). GL 51D (supersedes 51C, dated August 27, 2026) authorizes export, sale, purchase and transport of Venezuelan-origin coal or minerals, including gold; GL 54C (supersedes 54B) authorizes supply of goods, technology and services to coal-or-minerals operations; and new GL 55A authorizes negotiating and entering contingent contracts (bids, MOUs, agreements in principle) for coal-or-minerals investment, each contract conditioned on separate OFAC authorization before execution. OFAC also amended FAQ 1247. All three licenses remain conditioned on US/UK/France/Singapore dispute-resolution forum selection, routing of blocked-person payments into the Foreign Government Deposit Funds established by Executive Order 14373, and continue to exclude Russia-, Iran-, North Korea-, Cuba- and China-linked counterparties.
On 24 August 2026, the Director of OFAC, in consultation with the Department of State and pursuant to 31 CFR 560.802, determined that section 1(a)(i) of Executive Order 13902 shall apply to the aviation, digital asset, gold, shipping, and technology sectors of the Iranian economy, effective the same day and formally published in the Federal Register on 27 August 2026 (FR Doc 2026-17487). The determination — part of a Treasury campaign publicly branded "Operation Economic Outcast" — exposes any person operating in, or knowingly engaging in a significant transaction for the sale, supply, or transfer of significant goods or services to or from, these five sectors to secondary-sanctions and SDN-listing risk under E.O. 13902, and extends potential correspondent/ payable-through account restrictions to foreign financial institutions that knowingly facilitate such transactions. OFAC did not publish sector definitions and concurrently suspended several general licenses covering educational exchange, personal remittance, conference, and academic/ sports-exchange activity with Iran (administered separately via GL AA and GL BB, wind-down through 8 September 2026).
On 24 August 2026, OFAC issued two Iran-related general licenses (GL AA and GL BB), formally published in the Federal Register on 27 August 2026. GL AA authorizes wind-down of transactions and maintenance of operations involving La Nivernaise De Raffinage SAS (a French entity) and any entity in which it owns a 50%-or-greater interest, through 12:01 a.m. EDT, 23 October 2026 — an orderly-exit carve-out tied to exposure under Executive Order 13902. GL BB separately authorizes, through 12:01 a.m. EDT, 8 September 2026, wind-down of transactions previously authorized under five narrower general licenses/regulations covering educational activities, personal remittances, conference-related services, and academic/sports exchanges with Iran. Both are narrow, time-limited carve-outs administering an underlying restrictive sanctions posture, not a relaxation of policy.
On 11 August 2026 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £4,732,830.58 monetary penalty on Citibank N.A., London Branch (CBNA London) under section 146 of the Policing and Crime Act 2017, for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019 and the Global Anti-Corruption Sanctions Regulations 2021. Across eight categorised "Matters" spanning payment processing, correspondent banking and account restrictions — mostly occurring between February and November 2022 following Russia's invasion of Ukraine — CBNA London processed payments and dealt with frozen funds totalling approximately £19,720,127.43 in breach value, including exposure to designated shipping company PJSC Sovcomflot and a designated Russian individual's corporate network. OFSI rated the case Level 4 (its highest severity tier), with conduct assessed as aggravating; the penalty was reduced from a baseline of roughly £7.89 million via a voluntary-disclosure and cooperation discount. Announced 2 September 2026, this is OFSI's largest financial-sanctions penalty since Russia's 2022 invasion of Ukraine, surpassing the prior record held by Sabre Global Technologies Limited (£1,000,921, May 2026).
China's Ministry of Commerce issued Order No. 2 [2026] on 5 August 2026, imposing countermeasures under Articles 3, 4, 6, 9, 10 and 15 of the Anti-Foreign Sanctions Law against six US entities — Applied DNA Sciences, Stratum Reservoir, Altana Technologies, the Responsible Business Alliance, Verite Group, and Human Rights in China — for "assisting and supporting" US sanctions and restrictions targeting Xinjiang. The order prohibits organizations and individuals within China from conducting transactions or cooperation with the six named entities, effective immediately. The stated trigger is Washington's prior import ban on products from 43 Chinese companies over alleged Xinjiang forced-labor practices.
On 10 July 2026 OFAC issued Iran General License Y, authorizing the wind down of transactions involving Smart Global Limited (a Saint Kitts and Nevis holding company designated the same day alongside 5 other entities and 8 individuals), with payments to blocked parties to go into blocked accounts; it expired 9 August 2026. On 14 July 2026 OFAC issued General License Z under E.O. 13902, authorizing wind-down activity for blocked persons and vessels listed in an 11-entry annex (financial wind-down, safe port docking and departure, crew safety, emergency repairs, offloading of pre-14 July cargo); it expired 12 September 2026. Both licenses were formally published in the Federal Register on 23 September 2026 (91 FR 60304).
On June 21, 2026, OFAC issued Iran-related General License X (GL X), authorizing transactions otherwise prohibited under the Iranian Transactions and Sanctions Regulations (31 CFR part 560), the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587), the Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589), and WMD-proliferation sanctions authorities — including new purchases and loadings of Iranian-origin crude oil, petrochemical, and petroleum products, a materially broader carve-out than the cargo-already-loaded window granted by the preceding General License U. Just 16 days later, on July 7, 2026, OFAC issued General License X1, revoking and superseding GL X: as of that date new purchases or loadings of Iranian-origin crude oil, petrochemical, or petroleum products were no longer authorized. GL X1 itself subsequently expired. OFAC formally published both web licenses in the Federal Register on September 30, 2026 — a retrospective publication of licenses already issued and, by then, already revoked and expired.
On 1 June 2026, the U.S. Treasury's Office of Foreign Assets Control (OFAC) announced that FTI Consulting, Inc. (NYSE: FCN), a global business-advisory and expert-witness firm, agreed to pay $1,050,000 to settle apparent civil liability for six indirect dealings in prohibited debt of VTB Bank OAO between April 2019 and May 2021 — constituting violations of the Russia Harmful Foreign Activities Sanctions Regulations (RuHSR) and the then-applicable Directive 1 debt-tenor restrictions. FTI had been engaged via an intermediary global law firm to provide expert economic consulting services supporting VTB in Singapore litigation; invoices issued through that intermediary went unpaid or were paid far beyond the permissible 14-day tenor, extending prohibited debt on six occasions totalling approximately $353,862. OFAC determined the conduct was non-egregious and not voluntarily self-disclosed, and imposed a penalty of $1,050,000 — double the $525,000 base penalty — citing the foundational principle that a party may not do indirectly what it cannot do directly.
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 30 April 2026, the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £165,000 monetary penalty on Deutsche Bank AG London Branch (DBLB) for breaching regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019. DBLB processed two payments totalling £635,618.75 in June and July 2022 to Okko LLC, a Russian streaming-platform operator wholly owned by sanctioned entity JSC New Opportunities. The breach arose because DBLB's third-party sanctions-screening provider failed to identify that Okko had become majority-owned by the designated entity post-listing. DBLB voluntarily disclosed the breach to OFSI in September 2022, qualifying for a 45% reduction from the £300,000 baseline penalty. This is the second resolution under OFSI's new Settlement Scheme (introduced February 2026) and the first involving a major investment-bank counterparty.
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.
The Council of the EU renewed the Myanmar/Burma restrictive measures framework for a further 12 months through 30 April 2027 via Council Decision (CFSP) 2026/927 and Implementing Regulation (EU) 2026/926, both adopted 27 April 2026. The regime remains substantively unchanged: asset freezes, travel bans, and service prohibitions on 105 individuals and 22 entities, including junta-linked actors with documented involvement in mineral resource extraction (Myanmar Mining Enterprise No. 1 and No. 2). This is the first EU Myanmar sanctions action filed in the IPTM register; the parallel US programme (EO 14014 / 31 CFR Part 525) targeting the same mining enterprises is tracked under the us-burma-sanctions-perimeter theme.
On April 24, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added 19 entities and 19 vessels to the Specially Designated Nationals (SDN) List under Executive Order 13902 (Iran petroleum and petrochemical sectors), in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. The action is the first OFAC designation of a Chinese independent ("teapot") refinery — Hengli Petrochemical (Dalian) Refinery Co., Ltd., described as one of Iran's largest single customers for crude oil and petroleum products, having purchased billions of US dollars' worth since at least 2023 from cargoes brokered by Sepehr Energy Jahan Nama Pars Company (the oil sales arm of Iran's Armed Forces General Staff, controlled by the Ministry of Defense / MODAFL). Co-designations span shipping firms and vessels registered in China, Hong Kong, Panama, Marshall Islands, Liberia, and Vietnam. Concurrent with the designations, OFAC issued Iran-related General License V authorising a 30-day wind-down (through May 24, 2026) of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. and certain majority-owned entities. Treasury press release SB0472 ("Economic Fury Targets Global Network Fueling Iran's Oil Trade and Shadow Fleet") frames the action as part of the maximum-pressure campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The April 24 designations directly triggered the first-ever operational use of China's Blocking Rules (MOFCOM Announcement No. 21 of May 2, 2026) and preceded a second OFAC Iran wave on May 1, 2026 (General License W + Strait of Hormuz Sanctions Risk Alert).
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 March 20, 2026, OFAC issued Iran-related General License U (GL U), temporarily authorizing the sale, delivery, offloading and — notably, for the first time in decades — importation into the United States of Iranian-origin crude oil and petroleum products, but only for cargo already loaded onto vessels as of 12:01 a.m. EDT that day. The window ran through April 19, 2026, after which the authorization lapsed. The license excluded any transaction touching Cuba, North Korea, or Russian-government-controlled areas of Ukraine, and did not waive any other, non-Iran sanctions program. OFAC formally published GL U (and the separate, entity-specific GL V wind-down license for Hengli Petrochemical) in the Federal Register on June 10, 2026 — a retrospective publication of licenses already issued and, by then, already expired.
On 19 March 2026 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £390,000 monetary penalty on Apple Distribution International Limited (ADI), the Ireland-incorporated subsidiary of Apple Inc. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. ADI's failure to cancel the payments amounted to conduct in the UK that breached regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019, which prohibits making funds available to a person owned or controlled by a designated person. The enforcement is notable as the **first use of OFSI's new settlement mechanism** (introduced February 2026), which allows OFSI and a subject of an enforcement action to resolve a civil monetary penalty case via time-bound negotiation. OFSI applied a 35% discount to the £600,000 baseline penalty to reach the £390,000 final figure, reflecting ADI's voluntary self-disclosure (made 4 October 2022) and cooperation.
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced on 17 March 2026 that TradeStation Securities, Inc. agreed to pay $1,110,661 to settle 481 apparent violations of the Iranian Transactions and Sanctions Regulations (31 CFR Part 560), the Syrian Sanctions Regulations (31 CFR Part 542), and the Ukraine-/Russia-Related Sanctions Regulations (31 CFR Part 589) that occurred between 21 June 2021 and 15 June 2022. The violations arose from a mobile-platform software update that inadvertently caused the firm's second-tier geo-blocking to screen the IP address of a U.S.-located server rather than the user's IP, allowing customers in Iran, Syria, and Crimea to execute securities-related transactions. OFAC determined the apparent violations were non-egregious and voluntarily self-disclosed, resulting in a significantly reduced settlement amount.
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.
OFAC reached a $1,720,000 civil penalty settlement with IMG Academy LLC on 12 February 2026 to resolve 89 apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations (31 CFR Part 598) arising from tuition-related transactions processed on behalf of two individuals designated as SDNs under the Kingpin Act between 2018 and 2023. OFAC determined the apparent violations were NON-EGREGIOUS and not voluntarily self-disclosed; the penalty reflects substantial cooperation and remedial measures taken by IMG Academy after becoming aware of the violations. This is the first OFAC enforcement action in the register against a US educational or academic-services institution, establishing Kingpin Act SDN-screening obligations for schools and training academies accepting international student tuition payments.
Ukrainian President Volodymyr Zelenskyy signed Decree No. 102/2026 on 7 February 2026, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against 27 legal entities: 22 based in Russia and 5 based in China and Hong Kong. The designees are described as active in defense manufacturing, precision engineering, optics, electronics, aerospace, and applied research, technology and banking/trading activity that Ukraine assesses as supporting Russian weapons production and its financing. The decree entered into force on 10 February 2026.
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, the Council of the European Union adopted Council Implementing Regulation (EU) 2026/267 and the accompanying Council Decision, implementing the EU's Iran human-rights restrictive-measures regime (Regulation (EU) No 359/2011, in place since 2011 and renewed annually). The package designates 15 individuals and 6 entities over the violent repression of peaceful protests, arbitrary detention, and internet/media censorship in Iran, bringing the regime's cumulative total to 24 individuals and 26 entities. The six newly listed entities are the Iranian Audio-Visual Media Regulatory Authority (SATRA), the IRGC-linked Seraj Cyberspace Organization, the Working Group for Determining Instances of Criminal Content (WGDICC), Yaftar Pazhohan Pishtaz Rayanesh Limited Company, Douran Software Technologies, and Masaf Institute. Designated parties are subject to an EU-wide asset freeze and a prohibition on making funds or economic resources available to them; listed individuals additionally face a travel ban.
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 10 November 2025, OFSI imposed a £160,000 monetary penalty on Bank of Scotland Plc (a Lloyds Banking Group subsidiary trading as Halifax) for processing 24 payments totalling over £77,000 in February 2023 to and from a personal current account held by Dmitrii Ovsyannikov, a designated person under the Russia (Sanctions) (EU Exit) Regulations 2019, in breach of Regulations 11 and 12. The screening failure arose because Ovsyannikov had opened the account under a UK-passport spelling variant of his name that defeated Halifax's exact-string sanctions-screen. The base penalty of £320,000 was halved to £160,000 following a 50% voluntary-disclosure discount after Lloyds Banking Group self-reported the breach. The penalty notice was published on 26 January 2026 and OFSI issued a compliance-lessons blog post on 23 February 2026.
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 16 January 2026, the US Treasury's Office of Foreign Assets Control designated 21 individuals and entities and identified one vessel for transferring oil products, procuring weapons and dual-use equipment, and providing financial services to Iran-backed Ansarallah (the Houthis). Designated parties — oil-trading and exchange companies, a shipping/logistics facilitator, and front-company operatives — are based in Yemen, Oman, and the UAE, and are accused of running an oil-sales and financial- facilitation network that Treasury says generates the Houthis over $2 billion in annual illicit revenue. The action was taken pursuant to Executive Order 13224 (as amended) and builds on a multi-year cadence of prior OFAC designations against Houthi leaders, smugglers, financiers, and weapons-procurement suppliers.
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.