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
Congress Renews Call for Russia Sanctions as Trump Plans Summit with Putin
Senate Majority Leader John Thune (R-SD) said last week that Members of Congress are “talking about a time and date” for a vote on the Sanctioning Russia Act of 2025 (S. 1241) and that, in his opinion, “it’s time to move” on it. Multiple Senators including Senator Jeanne Shaheen (D-NH), the Ranking Member of the Senate Foreign Relations Committee, and Senator Dick Durbin (D-IL), the Senate Democratic Whip, voiced their support for passing the legislation, which already has strong bipartisan support across both Chambers.
Thune said that he expects the bill to be brought up in the next 30 days. Depending on when the legislation is brought forward, Congress may be voting on the Act at the same time as President Trump’s planned meeting with Russian President Vladimir Putin in Budapest, Hungary. After a call with Putin on October 16, Trump said negotiations to end the war in Ukraine will happen after a delegation led by Secretary of State Marco Rubio meets with their Russian counterparts this week.
If the bill passes before the meeting with Putin, Trump may use it as part of his efforts to end Russian energy purchases across Europe, India, and other countries as leverage in the negotiations. However, the White House has argued in the past that the Act would restrict Trump’s flexibility in his negotiations with Russia. In particular, the administration has said that the Act would limit the ability of the President to offer Russia relief from sanctions in exchange for a favorable end to the war. Although Trump has also voiced support for imposing sanctions on Russia in the past, it is unclear whether he would sign the Act if it were to pass Congress during his administration’s negotiations with Russia.
OFAC Targets Affiliates of Haitian Gang
On October 17, OFAC sanctioned two individuals for their support of or affiliation with Viv Ansanm, a coalition of gangs that was designated as a Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT) on May 2, 2025, for contributing to destabilizing activities in Haiti, including coordinated attacks on critical infrastructure. One of the designated individuals, Dimitri Herard, is a former Haitian police officer who OFAC alleges was connected to, and later imprisoned for, the assassination of former President Jovenel Moïse in 2021. OFAC alleges that the other designated individual, Kempes Sanon, is the leader of the Bel Air gang, a constituent gang in the Viv Ansanm alliance, that has been involved in indiscriminate civilian killings and extortion, among other crimes.
UK Developments
UK to Move to a Single Sanctions List from January 2026
The UK Government has announced that from January 28, 2026, the UK Sanctions List will become the single authoritative source for all UK sanctions designations. Currently, UK designations are detailed in two lists, the UK Sanctions List, published by the Foreign, Commonwealth and Development Office (FCDO) and the Consolidated List of Asset Freeze Targets, published for HM Treasury by the Office of Financial Sanctions Implementation (OFSI). The OFSI Consolidated List of Asset Freeze Targets will close at 09:00 GMT on January 28, 2026. This change, jointly announced by the FCDO, HM Treasury and OFSI, responds to industry feedback that a single list will simplify compliance and remove duplication when screening UK designated persons. Businesses that currently rely on both lists are advised to switch to the UK Sanctions List as their primary data source well in advance of the transition and review their internal systems accordingly. Updated UK Government guidance has been published to support compliance preparations.
OTSI Uses Case Study to Highlight Best Practice in Detecting Trade Sanctions Breaches
The Office of Trade Sanctions Implementation (“OTSI”) has published a detailed case study to illustrate how robust due diligence can prevent breaches of UK trade sanctions. The case study concerns a UK branch of a multinational bank that identified several suspicious payments linked to the movement of Russian-origin goods to a third country. These goods were subject to prohibitions under the Russia (Sanctions) (EU Exit) Regulations 2019, which make it an offence for a UK person to facilitate trade involving restricted goods from Russia.
In this case, payments for the prohibited goods were routed through the bank’s UK branch, which acted as an intermediary in the transaction. The branch’s internal account screening systems flagged the activity, triggering enhanced due diligence checks. Following its investigation, the bank correctly declined to process the payments and voluntarily reported the matter to OTSI using its online reporting tool. OTSI reviewed the information provided, including invoices and contractual documents, and confirmed that no breach had occurred, as the payments were stopped before completion.
OTSI’s key takeaways for industry from this case study include understanding how UK trade prohibitions apply to financial services, performing enhanced due diligence on high-risk clients and jurisdictions, maintaining robust screening systems capable of halting suspect transactions, and using OTSI’s reporting tool to disclose potential breaches. Businesses are encouraged to adopt a risk-based approach to sanctions compliance and to view trade sanctions awareness as an essential element of responsible corporate governance.
OFSI Publishes Annual Sanctions Review
OFSI has published its Annual Sanctions Review for 2024-2025, highlighting continued progress in enforcement and industry engagement. The report shows that assets frozen under UK sanctions rose from £24.4 billion to £37 billion, with £28.7 billion linked to Russia-related measures since 2022. OFSI recorded 394 suspected breach cases and issued 57 enforcement actions, including penalties against Integral Concierge Services Limited and Herbert Smith Freehills. The number of designations on the UK list reached 4,733, with 2,113 related to Russia. The review underscores OFSI’s focus on strengthening compliance, modernising its licensing systems, and maintaining enforcement as a central feature of the UK’s economic deterrence strategy.
UK Government Targets Russian Oil Majors and Defence Sector in Latest Round of Russia Sanctions
The UK Government has designated 34 entities, five individuals, and specified 51 ships under the Russia (Sanctions) (EU Exit) Regulations 2019, following the unilateral decision by the UK Government to further target Russian oil revenues and military supply chains. Notably, the UK government has imposed Russia’s two largest oil producers, Rosneft and Lukoil. According to a UK Government press release, these sanctions target two of the world’s biggest energy companies and their global enablers, including four oil terminals in China, 44 tankers in the “shadow fleet” transporting Russian oil, and Indian incorporated company, Nayara Energy Limited. The measures also impose sanctions on businesses that supply electronics critical for Russian drones and missiles used on the battlefield in Ukraine, including businesses operating in China, Singapore, Thailand, and Turkey. Businesses should update screening systems immediately to reflect the expanded list, paying particular attention to counterparties in the energy and electronics sectors, where overlap with newly listed entities is most likely.
While precise details remain to be announced, the UK government also has signalled its intention to ban imports of oil products refined in third countries from Russian-origin crude oil, which would represent a significant expansion of existing UK sanctions on Russian oil and oil products.
The UK Government has also issued two new general licences to allow the wind-down of existing transactions in response to the imposition of the latest wave of sanctions on Russia affecting the energy industry (the “GLs”). The GLs cover the wind-down of existing operations with Russian oil majors (GL INT/2025/7539056), and with any of the newly sanctioned energy companies with ties to the Russian energy industry (GL INT/2025/7538856). These GLs took effect from October 15, 2025, and expire at 23.59 on November 28, 2025, and November 13, 2025, respectively. Additionally, on October 15, 2025, existing General Licences INT/2025/5886860 and INT/2025/5635700 were amended to include PJSC Lukoil Oil Company, PJSC Rosneft Oil Company, and their subsidiaries within their scope following their UK designations.
This latest action marks one of the most significant expansions of the UK’s Russia sanctions to date, underscoring the UK Government’s continued focus on disrupting Russia’s oil revenues. Companies operating in the global energy supply chain should assess both direct and indirect links to newly sanctioned entities, ensure compliance procedures are up to date, and prepare for increased scrutiny of Russian oil-related transactions.
UK Government Targets Major Online Fraud Network in Latest Round of Global Human Rights Sanctions
The UK Government has acted in coordination with the United States to designate six individuals and six entities involved in the operation of illegal scam centres that defraud victims across the world out of substantial sums of money and torture their trafficked workers. The designations have been made under the Global Human Rights sanctions regime. According to a UK Government press release, the leader of the network, Chen Zhi, and his web of enablers have incorporated their businesses in the British Virgin Islands and invested in the London property market to defraud victims on an industrial scale, including in the UK. The designated persons are now subject to a UK asset freeze, and, in the case of individuals, a UK travel ban.
UK Extends Russia Sectoral Software General Trade Licence to April 2026
The Export Control Joint Unit (ECJU) has extended the validity of the General Trade Licence (Russia Sanctions – Sectoral Software and Technology), which authorises certain transfers of business software and technology to Russia that would otherwise be prohibited under Chapter 4N of the Russia (Sanctions) (EU Exit) Regulations 2019. The new licence, which replaces the previous version due to expire on October 20, 2025, will now remain in effect until April 17, 2026, and contains identical provisions to the earlier iteration of the licence.
To qualify, transfers must be made to multinational clients headquartered outside Russia, relate to contracts agreed before April 23, 2025, and be for non-predominant use by Russian subsidiaries. Businesses using the licence must comply with registration and record-keeping requirements. The extension provides limited operational continuity for multinational firms with pre-existing contractual obligations involving Russian affiliates, while ensuring adherence to UK sanctions restrictions on technology and software transfers.
EU Developments
The European Commission recently published updated FAQs clarifying restrictive measures under Council Regulation 833/2014, focusing on the import ban on refined petroleum products derived from Russian crude oil and the export-related restrictions on dual-use goods and advanced technologies.
As part of the 18th sanctions package against Russia, the EU introduced a ban on the purchase, import, or transfer of refined petroleum products produced from Russian crude oil into the EU. As a result, starting January 21, 2026, importers must provide evidence at the time of importation demonstrating the origin of the crude oil used in the production of refined petroleum products. The updated FAQs outline acceptable forms of evidence for these purposes, as well as the need for operators to exercise enhanced due diligence for imports from countries with high Russian crude intake such as Türkiye, India, and China. The FAQs also list third countries considered net exporters of crude oil in 2024, which benefit from a presumption that their petroleum products are domestically sourced unless rebutted by credible indications of Russian crude use.
In parallel, the Commission updated its FAQs on export restrictions for dual-use and advanced technology items against Russia to support competent authorities and stakeholders in implementing the restrictions under Council Regulation 833/2014. The FAQs clarify the scope of prohibited sensitive items and the specific situations in which derogations may apply. They also provide guidance to help businesses understand how the export restrictions operate in practice, along with a section outlining cooperation with partner countries that have aligned their export control measures with the EU sanctions framework.
Asia-Pacific Developments
China Sanctions US Subsidiaries of South Korean Shipbuilder Hanwha Ocean
In response to the United States’ implementation of final measures under its Section 301 investigation targeting China’s maritime, logistics, and shipbuilding sectors, China’s Ministry of Commerce (MOFCOM) announced, on October 14, 2025, counter sanctions against five US subsidiaries of South Korean shipbuilder Hanwha Ocean as approved by China’s National Anti Foreign Sanctions Coordination Mechanism. MOFCOM stated that these subsidiaries, Hanwha Shipping LLC, Hanwha Philly Shipyard Inc., Hanwha Ocean USA International LLC, Hanwha Shipping Holdings LLC, and HS USA Holdings Corp., had assisted and supported the US government’s investigation and related actions, thereby harming China’s sovereignty and security.
All organizations and individuals in China are prohibited from engaging in transactions, cooperation, or other activities with these entities, pursuant to China’s Anti Foreign Sanctions Law and its implementing provisions. On October 17, a spokesperson for the US State Department denounced China’s sanctions, describing it as an “irresponsible attempt” to disrupt private business operations and undermine South Korea–US efforts to revitalize America’s shipbuilding and manufacturing sectors.
Australian Authorities Charge Man Over Alleged Sanctions-Breaching Remittances
On October 15, 2025, the Australian Federal Police, in coordination with the Australian Sanctions Office and Australian Transaction Reports and Analysis Centre (AUSTRAC), announced charges against a 34-year-old Western Sydney man for allegedly remitting approximately AUD 650,000 to Iranian banks subject to Australian sanctions. The individual, a director of a remittance company, is accused of processing 543 transactions over a 12-month period, facing a maximum penalty of 10 years’ imprisonment and substantial fines. Following the investigation, AUSTRAC also suspended the company’s remittance registration for one year. The Australian Sanctions Office warned members of the financial industry about the serious consequences of contravening national sanctions laws.
New Zealand Reimposes UN Sanctions on Iran Over Nuclear Non-Compliance
New Zealand announced the reimposition of United Nations-mandated sanctions on Iran, citing Tehran’s failure to comply with its nuclear obligations under the Joint Comprehensive Plan of Action (JCPOA). The United Nations Sanctions (Iran) Regulations 2025, effective October 18, introduce measures including asset freezes and travel bans on designated individuals, import and export restrictions on nuclear and military goods, and a requirement for citizens to exercise vigilance in dealings with Iran. The government also confirmed a compulsory registration scheme for businesses engaging with Iran, set to commence on February 1, 2026. Foreign Minister Winston Peters emphasized that these steps reflect New Zealand’s commitment to global non-proliferation efforts and urged Iran to resume full cooperation with the International Atomic Energy Agency (IAEA).
