Overview
US Developments
Senate Passes Lindsey O. Graham Sanctioning Russia and Iran Act of 2026
On August 7, the US Senate passed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 by a bipartisan vote of 86-11. The bill, previously known as the Sanctioning Russia Act of 2026, now moves to the House of Representatives, which is in recess until September.
Originally introduced in April 2025, the legislation gained momentum after President Donald Trump signaled support last November, subject to him gaining new tariff authorities and retaining flexibility over the imposition of sanctions. We covered several of the most notable revisions included in the July 16, 2026 version of the bill in a prior update. The version passed by the Senate grants the President waiver authority in relation to the Russia-related sanctions, and authorizes the President to impose tariffs of up to 100 percent on the largest purchasers of Russian oil and natural gas, as well as countries facilitating Russian oil sanctions evasion. In addition to the inclusion of these key administration priorities, lawmakers amended the bill to extend the Iran Sanctions Act of 1996 through 2031 after President Trump’s July 30 call for Congress to add Iran-related tariffs to the legislation.
Although the bill passed the Senate with broad bipartisan support, some lawmakers have expressed concerns about its expanded tariff authorities. We previously reported that Senator Ron Wyden (D-OR) and Representative Richard Neal (D-MA) opposed the measure, arguing that it grants the president excessive unilateral tariff authority. A subsequent amendment offered by Senators Rand Paul (R-KY) and Wyden to remove the tariff provision failed by a vote of 64-32. The bill now heads to the House, where it faces uncertain prospects for passage, with concern driven by the new sanctions waiver authority and tariff authorities.
US Imposes Sanctions on Iran-linked Financial Networks, Exchange Houses, and Crypto Exchanges
On August 7, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned seven entities and five individuals for allegedly “enabling Iran’s ‘rahbar’ banking system to move hundreds of millions of dollars.” Among the designations are two UAE-based exchange houses allegedly involved in supporting Shahr Bank’s role in helping the Iranian regime retrieve revenue from overseas oil sales. The Treasury Department said multiple shell and front companies “work with and enable other actors throughout Iran’s shadow banking apparatus,” including entities based in Hong Kong, Singapore, and Dubai.
In a separate action on the same day, OFAC sanctioned a multinational cryptocurrency exchange network and related entities for allegedly facilitating illicit financial activity and supporting Iran’s Islamic Revolutionary Guard Corps (“IRGC”). OFAC also designated a digital asset exchange pursuant to E.O. 13902 for operating in Iran’s financial sector.
These actions were taken pursuant to Executive Order (“E.O.”) 13902, which targets persons operating in Iran’s financial and petroleum sectors, and E.O. 13224, which targets persons who commit or support terrorism.
US Issues Cuba-Related Designations and FAQ
On August 6, the State Department designated five Cuba-related entities and six individuals allegedly related to Cuba’s armed forces and military-industrial sector. The action was taken pursuant to E.O. 14404, which authorizes the imposition of sanctions on individuals and entities connected to Cuba’s government. According to the State Department, the entities and individuals facilitated the Cuban government’s foreign military cooperation and the procurement of military equipment, including for Cuba’s Ministry of the Revolutionary Armed Forces and security services.
Alongside the designations, OFAC issued Frequently Asked Question (“FAQ”) 1264, which states that it does not intend to target non-US persons under E.O. 14404 when providing food; agricultural commodities; medicine; or medical devices and related parts or software updates to Cuba for humanitarian purposes. This policy applies even when transactions involve E.O. 14404-designated persons or entities in which such designated persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
OFAC Extends the Delay of PdVSA Bond-Related Authorizations
On August 3, OFAC issued Venezuela-related General License (“GL”) 5Y, which authorizes certain transactions related to, the provision of financing for, and other dealings in the Petróleos de Venezuela, S.A. 2020 8.5% Bond that are otherwise prohibited by EO 13835, as amended, on or after September 17, 2026. GL 5Y is the most recent extension in a long-running delay in the effective date of GL 5’s authorization. Unlike the recent 60-day extensions of GL 5, GL 5Y only extends the delay of the authorization by approximately six weeks, which suggests that OFAC may be prepared to allow the authorization to come into effect in the near future.
UK Developments
UK Announces Further Russia Sanctions Targeting Banks, Shadow Fleet and Military Supply Chains
The UK Government has announced a further package of sanctions under the Russia (Sanctions) (EU Exit) Regulations 2019, designating one individual, 12 entities and six vessels in a continued effort to disrupt Russia’s war economy. According to a UK Government press release, the measures target six Russian banks, six recently acquired shadow fleet tankers used to circumvent Western sanctions, and four Russian companies involved in importing tantalum and niobium, rare metals critical to Russia’s military-industrial base. The designations also seek to disrupt the financial institutions and procurement networks that enable Russia to sustain military production and generate revenue despite existing sanctions.
The latest package forms part of the UK’s continuing strategy to increase economic pressure on the Kremlin by targeting key sectors underpinning Russia’s war effort, including finance, maritime transport and military supply chains. It also reflects the UK’s continued focus on countering sanctions evasion, particularly through the shadow fleet and the acquisition of critical materials used in the manufacture of military equipment.
OFSI Expands Russian Oil Exempt Projects General Licence
OFSI has amended General Licence INT/2025/5635700 (Russian Oil Exempt Projects) to include the Kurdistan Export Pipeline as an exempt project until October 14, 2027 (the “GL”). The GL permits specified business operations involving subsidiaries of certain UK-designated Russian energy companies where they relate to strategically important international energy projects, including the making and receipt of payments and other activities necessary to support those projects, subject to the licence’s conditions. The Kurdistan Export Pipeline now joins a number of existing exempt projects covered by the GL, reflecting the UK’s continued approach of safeguarding critical international energy infrastructure while maintaining broader sanctions against Russia’s energy sector. Businesses intending to rely on the GL should review the amended version to ensure compliance with its updated permissions and conditions.
EU Developments
EU Council Updates Russia Asset Freeze Sanctions Listing
The EU Council recently designated five individuals under the Russia asset freeze regime for materially supporting Russia’s military and industrial complex. The newly listed individuals hold senior positions in Russian companies involved in the development, production, or supply of military technology and equipment, including ballistic missile systems, military communication systems, software for unmanned aerial vehicles, and space-related military technologies. Among those listed are Ramil Nailevich Badgutdinov, General Director of JSC Serpukhov Plant “Metallist”, whose company is involved in the manufacture of navigation systems for the Iskander-M ballistic missile, and Aleksandr Yurevich Dyukarev, General Director of JSC “Krasnoyarsk Machine-Building Plant”, which produces the RS-28 “Sarmat” ballistic missile.
The designations follow the EU Council’s call in its June Conclusions to step up pressure on Russia through further sanctions in response to Russia’s continued war of aggression against Ukraine and its intensified attacks against civilians and civilian infrastructure. As a result of their designation, the individuals are subject to asset freezes, a prohibition on making funds or economic resources available, and an EU travel ban.
Asia-Pacific Developments
China Hits US With Sanctions and Drone Export Curbs Ahead of Xi Visit
On August 5, 2026, Beijing announced countermeasures against US entities, tightened US-bound export controls on drones and related technologies, and launched a national-security investigation into imported foreign-software office equipment. In a press conference, China’s Ministry of Commerce said the action responded to what it called repeated US restrictions involving telecommunications operators, testing laboratories, drones, consumer routers, submarine cables, advanced robotics and power inverters. It specifically cited the US decision on July 31—following a July 30 bilateral economic video call—to add more than 40 Chinese entities to the Uyghur Forced Labor Prevention Act Entity List. Beijing described its measures as restrained but warned of further action if Washington imposes new China-related restrictions.
Australian Sanctions Reportedly Fail to Curb Israeli Settler Funding
On August 7, 2026, Independent Australia reported that Israeli government support for the settler movement had increased despite three rounds of Australian sanctions since July 2024 targeting Hilltop Youth, associated individuals, outposts and other entities, including Finance Minister Bezalel Smotrich and National Security Minister Itamar Ben-Gvir. Several media outlets reported that Israel allocated about AUD 41 million for young settlers in West Bank outposts, including stipends and other assistance, and that Ben-Gvir’s ministry granted an estimated USD 1.3 million to Havat Gilad, a sanctioned settler organization. Although Hilltop Youth’s decentralized structure complicates enforcement, direct government funding for a named sanctioned entity raises questions about the effectiveness of existing measures.
