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 to Begin “Rolling Back” Select Sanctions on Venezuela
On Saturday, Treasury Secretary Scott Bessent told Reuters that certain US sanctions on Venezuela could be lifted as soon as this week to facilitate oil sales. Secretary Bessent said that Treasury is “de-sanctioning the oil that is going to be sold,” but did not specify which additional sanctions could be lifted. In addition, oil traders Vitol and Trafigura have reportedly secured “preliminary special licenses” to negotiate and export Venezuelan crude oil. These reports follow a Department of Energy announcement that the US is “selectively rolling back sanctions” on Venezuela to enable the transport and sale of its crude and certain derivative products.
While the specific measures have not been confirmed, the announcements mark a notable shift in US sanctions policy. The Department of Energy’s announcement indicates that that sanctions relief may extend beyond crude oil and related products to the export of “select oil field equipment, parts, and services,” including technology, expertise, and investment from American and “other international energy partners” to support Venezuela’s oil sector. Although the Trump administration is moving quickly to clear legal barriers to Venezuela’s oil market, there is reportedly hesitation from some oil majors to invest in Venezuela. During a meeting with oil industry executives on Friday, the Trump administration’s pitch to invest in Venezuela was reportedly met with concern about security, stability, and other risks.
Meanwhile, Congress has continued to question the Trump administration’s ultimate plans for Venezuela after former President Nicolás Maduro and his wife were captured and removed to the US for trial on drug- and weapons-related charges. Recently, five Senate Republicans joined Senate Democrats in advancing a measure that could restrict President Trump’s military powers in Venezuela. Ranking Member of the Senate Banking, Housing, and Urban Affairs Committee, Sen. Elizabeth Warren (D-MA), also called on the Chairman of the Committee, Sen. Tim Scott (R-SC), to hold oversight hearings on the national security and economic policy implications of the Trump administration’s actions, including the status and impact of existing sanctions.
Trump Gives Approval for Russia Sanctions Bill
On January 7, 2026, Sen. Lindsey Graham (R-SC), a co-sponsor of sweeping legislation that would impose sanctions and tariffs on Russia, the Sanctioning Russia Act of 2025, stated that President Trump has “greenlit” the legislation, potentially setting up a vote on the measure as early as this week.
As we reported previously, the Sanctioning Russia Act received a renewed push in Congress in late November following President Trump’s indication that he would support the legislation, provided he retains ultimate decision-making flexibility with respect to the sanctions and tariffs contained therein. While the push seemed to slow as the Trump administration continued its negotiations with Russia, the security landscape, as well as oil market conditions, have since shifted.
Sen. Graham stated that the Sanctioning Russia Act will allow President Trump to “punish” countries who buy Russian oil, primarily through secondary sanctions and tariffs. It will also provide President Trump with the “leverage” against countries such as China, India, and Brazil, to “incentivize them to stop buying cheap Russian oil.” Administration officials may view such measures serving the dual purpose of pressuring Russia, which recently struck Western Ukraine with a nuclear-capable missile, to concede on some of its hardline stances in peace negotiations, while also altering the market demand in favor of Venezuelan oil that President Trump anticipates selling.
If the Sanctioning Russia Act is put to a vote, it will likely pass. The bill enjoys significant bipartisan support, and lawmakers have been waiting for the opportunity to send a strong message to the Kremlin. It will be important to monitor any changes in the legislation, particularly those that provide President Trump with the decision-making flexibility that he requested, as Congress progresses toward a potential vote.
UK Developments
UK Government Publishes Report on Legality of Sanctions and Potential Seizure of Russian Assets
The UK Government’s House of Commons Library has published a research report that examines the international law context surrounding unilateral sanctions and the ongoing discussion of proposals to seize Russian assets to provide financial support to Ukraine. According to the report, while sanctions can be a lawful exercise of state sovereignty, their legality outside the UN Security Council framework remains contested and highly fact-specific. The report outlines how sanctions may engage obligations under non-intervention principles, sovereign immunity, WTO law, investment protections and customary international law, while noting the absence of a single, settled international legal framework governing sanctions. Additionally, the report places particular emphasis on the doctrine of countermeasures under customary international law, which some states and institutions have cited to justify more intrusive measures, including asset seizure. It notes unresolved questions, including whether states not directly injured by a breach may lawfully take countermeasures in the general interest, an issue brought into focus by Russia’s invasion of Ukraine. While bodies such as the Council of Europe have publicly supported asset seizure as a countermeasure, the briefing also records expert concerns that stretching these doctrines too far could undermine the coherence and legitimacy of international law. The report underlines the complex issues and attendant risks associated with the proposed seizure of Russian assets.
Asia-Pacific Developments
China Rejects US Sanctions Push, Defends Trade with Russia Amid Criticism
China has strongly cautioned against any efforts to undermine its economic and trade ties with Russia following reports that Trump endorsed a bipartisan sanctions bill targeting Moscow. Mao Ning, spokesperson for China’s Ministry of Foreign Affairs (MFA), reaffirmed Beijing’s opposition to unilateral sanctions and stressed that its trade with Russia is legal, mutually beneficial, and should remain free from external interference. The proposed US legislation, championed by Senator Lindsey Graham, seeks to penalize countries purchasing discounted Russian oil, aiming to pressure nations like China, India, and Brazil amid the ongoing Russia-Ukraine conflict.
China Sanctions Two Taiwan Officials for Independence Push, Adds Prosecutor as Accomplice
China announced sanctions against two senior officials from Taiwan’s Democratic Progressive Party, labeling them as “diehard Taiwan independence” separatists for promoting pro-independence agendas. Liu Shyh-fang, head of Taiwan’s interior affairs department, and Cheng Ying-yao, who oversees education, were accused of obstructing cross-Strait exchanges and fostering separatist sentiment, including introducing pro-independence textbooks. Both officials, along with their families, are now barred from entering mainland China, Hong Kong, and Macao, and their affiliated organizations are prohibited from cooperating with mainland entities. Additionally, Taiwan prosecutor Chen Shu-yi was designated as an accomplice for allegedly fabricating charges and persecuting individuals supporting cross-Strait ties, actions described as creating a “green terror.” Mainland authorities have so far listed 14 individuals as separatists and 12 as accomplices, stressing that these measures aim to safeguard national sovereignty and protect the interests of Taiwan compatriots, not target the general population.
North Korea Rejects Multilateral Sanctions Monitoring Effort
North Korea has strongly criticized the Multilateral Sanctions Monitoring Team, which includes 11 nations such as the US and South Korea, accusing it of being an “illegal” entity outside the United Nations framework. According to KCNA, Pyongyang’s mission to the UN condemned the group’s activities as lacking legitimacy and claimed the US intends to hold a briefing on the matter at UN headquarters. The team was established after Russia blocked the renewal of a UN expert panel in 2024, which had overseen sanctions compliance for years, while China abstained from that vote. North Korea also dismissed recent allegations linking its entities to cyberattacks as fabricated, following an October 2025 report by the monitoring team highlighting such connections.
