Overview
The Sanctions Update is compiled by Steptoe’s International Trade and Regulatory Compliance team and Steptoe’s Strategic Risk team. You can subscribe to receive the Sanctions Update every week through Steptoe’s International Compliance Blog and Stepwise Risk Outlook publication home pages.
For more information or advice on any of the developments discussed below, please contact a member of our sanctions team here.
US Developments
US Removes Sanctions on Acting Venezuelan President
On April 1, 2026, OFAC removed sanctions on Delcy Eloína Rodríguez Gómez (“Rodríguez”), the former Vice President and current Acting President of Venezuela. Rodríguez was first designated by OFAC on September 25, 2018, for being a senior Venezuelan official and member of then-President Nicolás Maduro’s inner circle.
The removal of sanctions on Rodríguez is a significant milestone in the US’s relationship with Venezuela post-Maduro. According to the White House, the decision “reflects progress in the joint efforts between [the US and Venezuela] to promote stability, support economic recovery, and advance political reconciliation in Venezuela.”
As Venezuela continues to work with the Trump administration on oil, mining, and related measures, it is likely that OFAC will continue to ease sanctions. The removal of sanctions on Rodríguez follows a number of incremental general and specific licenses issued by the Trump administration to encourage international access to Venezuela’s natural resources, which we have covered in previous editions of the Sanctions Update on February 2, February 9, February 18, March 23, and March 30, 2026.
OFAC Clarifies Sanctions Risks for Non-US Persons Under Certain Venezuela GLs
On March 31, 2026, OFAC issued Venezuela-related FAQ 1247.
FAQ 1247 clarifies that non-US persons generally do not face sanctions risks for engaging in transactions authorized by Venezuela-related general licenses (GLs) 46B, 51A, and 52, provided that they comply with certain conditions. These conditions are outlined in FAQ 1247. OFAC explains in the FAQ that these conditions are in place to ensure that transactions involving Petróleos de Venezuela, S.A. (“PdVSA”) or Venezuelan-origin oil, petrochemical products, or minerals occur through “legitimate and authorized channels, consistent with efforts to restore prosperity, safety, and security to Venezuela.”
As indicated in FAQ 1247, GLs 46B, 51A, and 52 authorize established US entities to engage in certain transactions involving PdVSA, as well as certain transactions that are ordinarily incident and necessary to, among other activities, the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin oil, petrochemical products, or minerals (including gold).
OFAC Amends Lukoil-Related GL
On March 30, 2026, OFAC issued an amended Russia-related GL 131D, “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.”
GL 131D extends the term of the GL from April 1, 2026, to May 1, 2026. This keeps open the window for negotiations on, and entry into, contracts with Lukoil or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (“LIG”) or any entity in which LIG owns a 50 percent or greater interest (“LIG Entities”), subject to OFAC’s review.
Alongside the GL, OFAC issued two amended Russia-related FAQs: FAQ 1224 and FAQ 1225 relating to which activities are authorized under GL 131D and the differences between GL 128B and 131D.
Treasury Removes More Persons from SDN List
On March 31 and April 3, 2026, OFAC removed the following persons, entities, and vessels from the List of Specially Designated Nationals and Blocked Persons (“SDN List”):
- Luis Rodriguez Olivera and Esteban Rodriguez Olivera, brothers who were designated on February 1, 2011, pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act), for being leaders of Los Gueros, a Mexican drug trafficking organization and part of the Sinaloa Cartel.
- Hector Mario Urdinola Alvarez and JOYERIA MANUELLA H.M., who were designated on July 23, 2014, pursuant to the Kingpin Act, for their leadership in or affiliation with Los Urabenos, a Colombian drug trafficking organization.
- FESCO MONERON and FESCO MAGADAN, which are Russian-flagged container ships identified as blocked property on February 22, 2022, pursuant to EO 14024, for being owned by a subsidiary of Promsvyazbank Public Joint Stock Company (PSB), a state-owned, Russian financial institution, OFAC said was “repurposed… to finance the defense industry…as part of a scheme to assist the government in avoiding new sanctions.”
- SV NIKOLAY, which is a cargo vessel that was identified as blocked property on April 6, 2022, pursuant to EO 14024, for being owned by a subsidiary of Joint Stock Company Alfa-Bank (Alfa-Bank), Russia’s largest privately owned financial institution.
- Mikhail Mikhaylovich Zadornov, who was designated on April 20, 2022 by the State Department, pursuant to EO 14024, for being a member of the Board of Directors of a Russian Bank.
Treasury did not provide a comment on why these persons, entities, and vessels were removed from the SDN List. For the Russia-related de-listings, these follow similarly focused actions taken by OFAC on March 27, March 20, March 18, March 13, March 6, and February 27, 2026. For the Kingpin-related de-listings, two similarly focused actions were taken on March 20 and March 12, 2026.
OFAC Publishes Advisory on Sham Transactions and Sanctions Evasion
On March 31, 2026, OFAC issued a Sanctions Advisory to highlight the sanctions risks arising from “sham transactions” and help identify factors to consider when evaluating whether property may be the subject of such a transaction.
In the Advisory, OFAC defines “sham transaction” as occurring when “blocked persons, often operating through proxies or other intermediaries, effectuate transfers or establish arrangements that conceal — rather than genuinely extinguish — a continuing interest in property.” Notably, OFAC says that it applies a functional definition to “interest” and “property interest” that looks beyond legal formalities to the underlying “practical and economic realities” of a transaction.
OFAC provided multiple examples of “sham transactions” it has seen, including those in which blocked persons employed opaque legal structures (such as trusts) and proxies to conceal their continued interest in property, ranging from investment vehicles and bank accounts to yachts.
OFAC also provided a list of red flags for industry, including:
- Commercially unreasonable transactions
- Transfer to family members or close associates
- Unclear purpose of transfer
- Unduly complex corporate structures involving higher-risk jurisdictions
- Continued involvement of a blocked person
- Transfer near the time of designation
- Evasive responses regarding a blocked person’s involvement
While OFAC emphasized the importance of compliance, it said that the purpose of the Advisory was not to “disturb legitimate dealings performed in good-faith compliance with OFAC sanctions involving property in which no blocked interest exists.” OFAC recommended that parties to a potential “sham transaction” review the available information to evaluate if any of the above-mentioned red flags are present, and if so, to take appropriate action, be it blocking and reporting or refraining from dealing, directly or indirectly, in the property absent explicit authorization from OFAC.
UK Developments
OFSI Director Reflects on the Agency’s First Ten Years
The Director of OFSI, Giles Thomson, marked OFS’s tenth anniversary with a blog post reflecting on the evolving role of financial sanctions as a tool for furthering the UK’s foreign policy, national security, and economic aims and OFSI’s role in their implementation and civil enforcement. Mr. Thomson also announced that OFSI will publish a new three-year strategy for the agency in the coming weeks in pursuit of OFSI’s continued mission to ensure that the UK’s financial sanctions continue to be clearly understood, effectively implemented and robustly enforced.
OFSI Amends General Licence INT/2022/2300292
OFSI has amended General Licence INT/2022/2300292 (“GL”) authorising payments to utility companies for gas and electricity by certain UK designated persons who own or rent properties in the UK. The amended GL authorises all forms of utility payment, including cash. The amended GL also adjusts the reporting requirements under the GL to mandate quarterly reporting of licence usage to OFSI. Any persons intending to use GL should consult a copy of the licence for full details of its permissions and usage requirements.
OFSI Amends General Licence INT/2022/2009156
OFSI has amended General Licence INT/2022/2009156 (“Insurance GL”) authorising certain permitted payments to UK insurance companies. The amended Insurance GL authorises persons designated under certain UK sanctions regimes to make insurance premium finance repayments to UK intermediaries rather than insurers or brokers. Any persons intending to use the Insurance GL should consult a copy of the licence for full details of its permissions and usage requirements.
UK Makes New Designation Under ISIL (Da’esh) and Al-Qaida Sanctions Regime
The UK has designated Hamidah Nabagala under its ISIL (Da’esh) and Al-Qaida sanctions regime for involvement in mediating financial channels for ISIL in Central Africa, financing a 2021 bombing in Uganda, and attempting to coerce her children to join ISIL camps in the Democratic Republic of the Congo. The newly designated person is now subject to an asset freeze, prohibition on making funds and economic resources available, as well as a travel ban.
General Trade Licence for Russia Sectoral Software and Technology Sanctions Extended
The Department for Business and Trade has extended the validity of the General Trade Licence Russia Sanctions: Sectoral Software and Technology (“GTL”) until October 30, 2026. According to Notice to Exporters 2026/08, the validity of the GTL has been extended to provide additional time for licensing processes to be completed, thereby ensuring that legitimate use of sanctioned business enterprise software and technology can continue without disruption under the UK’s Russia sanctions regime. Any persons intending to use the GTL should consult a copy of the licence for full details of its permissions and usage requirements.
EU Developments
EU Council Renews Sanctions Framework Targeting Bosnia and Herzegovina
The EU Council recently renewed the framework for restrictive measures in view of the situation in Bosnia and Herzegovina under Council Decision 2011/173/CFSP for one year, until March 31, 2027. The sanctions framework targets individuals and entities whose activities undermine the sovereignty, territorial integrity, constitutional order, or international personality of Bosnia and Herzegovina, and those that seriously threaten its security or undermine the Dayton/Paris General Framework Agreement for Peace.
The restrictive measures include a travel ban, asset freezes, and a prohibition on making funds or economic resources available to listed individuals or entities.
EU Council Extends Sanctions Regime Targeting Serious Human Rights Violations in Iran
The EU Council extended restrictive measures against certain persons and entities in view of the situation in Iran under Decision 2011/235/CFSP until April 13, 2027. The sanctions regime targets individuals and entities complicit in or responsible for directing or implementing grave human rights violations. Restrictive measures may also be imposed against persons complicit in or responsible for directing or implementing grave violations of the right to due process, torture, cruel, inhuman and degrading treatment, or the indiscriminate, excessive and increasing application of the death penalty in contravention of Iran’s international human rights obligations.
As part of the review, the EU Council updated the sanctions list, removing one individual and amending the entries for four individuals and two entities.
EU Council Updates Iran Sanctions Framework
On March 30, the EU Council adopted several legal instruments to update restrictive measures against Iran. The changes include: (i) amendments to Annex II of Decision 2010/413/CFSP, (ii) amendments to Article 1(1)(e) of Decision 2010/413/CFSP to refer to the EU Dual-Use Control List in Annex I of Regulation (EU) 2021/821, (iii) amendments of Regulation (EU) 267/2012, and (iv) updates to the sanctions list set out in Annex IX to Regulation (EU) 267/2012.
Asia-Pacific Developments
China Imposes Sanctions on Japanese Lawmaker Keiji Furuya Over Taiwan Visits
On March 30, 2026, China’s Ministry of Foreign Affairs (MFA) announced sanctions against Keiji Furuya, a member of Japan’s House of Representatives, over his repeated visits to Taiwan and alleged “collusion with Taiwan independence forces.” The MFA said Furuya’s actions violated China’s sovereignty, constituted gross interference in internal affairs, and crossed a “red line” on the Taiwan question. The measures, imposed under China’s Anti-Foreign Sanctions Law, include “freezing Keiji Furuya’s assets in China, banning Chinese entities and individuals from transactions or cooperation with him, and prohibiting his entry into mainland China, Hong Kong, and Macau.” Keiji Furuya dismissed the sanctions’ impact, noting he has no assets in China and has not visited the mainland in decades. Tokyo reportedly condemned the move as “absolutely unacceptable,” with Deputy Chief Cabinet Secretary Masanao Ozaki accusing Beijing of using the pretext of Furuya’s conduct to intimidate dissenting voices.
APAC Economies Tap Russian Oil to Ease Strait of Hormuz Disruption
On April 1, 2026, media reports said that several Asian economies facing energy shortages are taking advantage of US sanctions waivers to buy Russian oil and petroleum products. These purchases are helping offset supply losses caused by the Middle East war, which has nearly shut down the Strait of Hormuz. The Philippines has received its first cargo of Eastern Siberia-Pacific Ocean (ESPO) crude in nearly six years, and South Korea has imported its first Russian naphtha shipment of 2026. Sri Lanka and other countries are in discussions with Moscow for additional shipments. Japan is also considering Russian supplies despite potential diplomatic consequences, as it needs oil and petrochemical feedstocks. Before the waivers, Russian crude exports to Asia were mostly limited to Indian refiners and independent processors in China. India alone is expected to import about 60 million barrels in March 2026, while Russian oil now makes up a larger share of China’s overall crude imports.
India Resumes Iranian Oil Trade Amid APAC Energy Supply Pressures
On April 4, 2026, India reportedly confirmed it has resumed imports of Iranian oil and LNG after a seven-year hiatus, raising hopes among traders for restored bilateral trade and renewed interest in the Chabahar port. The announcement comes as several US sanctions waivers near expiry: Russian oil for India on April 5, a general waiver on April 11, Iranian oil on April 19, and India’s Chabahar stake on April 26. The Ministry of External Affairs said it “remains engaged” with Washington, while the Ministry of Petroleum and Natural Gas emphasized that purchases were commercially driven. With oil prices above USD 110 per barrel and supply disruptions from Middle East conflicts continuing, focus now shifts to whether India will maintain Iranian imports should the US reimpose sanctions later this month.
