Overview
US Developments
State Department Sanctions Six Targets in Cuban Financial, Metals and Mining, and Energy Sectors
On September 3, the State Department designated five entities and one individual related to Cuba’s financial services, metals and mining, and energy sectors. These actions were pursuant to Executive Order (“E.O.”) 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.”
The designated entities include Banco Exterior de Cuba, a state-owned financial institution; two subsidiaries of the state-owned petroleum company, Union Cuba Petroleo (“CUPET”); Empresa de Servicios Comandante René Ramos Latour, a state-owned mining support services company; and Empresa Importadora y Abastecedora del Níquel, a state-owned nickel industry support services company. Additionally, the State Department designated Fidel Ernesto Castro Calis, who is the grandson of Raúl Castro.
Alongside the sanctions, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Cuba General License (“GL”) 4A under E.O. 14404. GL 4A authorizes transactions that are ordinarily incident and necessary to the official activities of third-country diplomatic and consular missions in Cuba. GL 4A broadens the authorization previously granted by GL 4 by removing a prior restriction on certain financial transfers to blocked persons.
OFAC Sanctions Turkish Bank as Part of Operation Economic Outcast
On September 4, OFAC announced sanctions against Türkiye-based financial institution Golden Global Yatirim Bankasi Anonim Sirketi (“Golden Global Bank”) and its subsidiaries for allegedly facilitating tens of millions of dollars’ worth of transactions for Iran’s Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”). According to OFAC, Golden Global Bank was established for the purpose of providing correspondent banking services to Iranian financial institutions in order to enable China’s purchases of Iranian oil.
These sanctions are part of the Trump Administration’s new “Operation Economic Outcast,” which is a broad economic pressure campaign targeted at Iran. We covered the initiative and its implications in a recent blog post.
OFAC Generally Authorizes Venezuelan Coal Activities
On September 2, OFAC expanded the scope of three Venezuelan GLs to include authorizations for transactions ordinarily incident and necessary to certain activities relating to Venezuelan-origin coal, including those involving the Venezuelan state-owned coal company Carbones del Zulia (“Carbozulia”). The prior versions of these GLs only authorized activities related to Venezuelan-origin minerals. In particular, OFAC issued the following amended GLs:
- GL 51D, which authorizes transactions ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin coal or minerals;
- GL 54C, which authorizes transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, mining, extraction, processing, refining, or production of coal or minerals in Venezuela; and
- GL 55A, which authorizes transactions that are related to the negotiation of and entry into contingent contracts for new investment in the coal or minerals sectors of Venezuela.
OFAC Issues Reminder to File the 2026 Annual Report of Blocked Property
On September 2, OFAC issued a reminder that U.S. persons holding blocked property as of June 30, 2026, must submit an Annual Report of Blocked Property (“ARBP”) by September 30, 2026. Failure to file a complete report by the deadline may constitute a violation of OFAC’s Reporting, Procedures, and Penalties Regulations and could result in an enforcement referral. Persons filing the 2026 ARBP must use spreadsheet form TD-F 90-22.50 and submit the completed form through the OFAC Reporting System (“ORS”), which OFAC adopted as its primary reporting mechanism two years ago. First-time users of ORS will need to contact OFAC to request registration instructions. For additional information, please review OFAC’s Guidance on Filing the 2026 Annual Report of Blocked Property.
UK Developments
UK Issues Movement Direction to Russian Cargo Vessel SINEGORSK
The UK Government has published details of the use of its transport sanctions powers against the Russian-flagged, registered and operated cargo vessel, SINEGORSK. According to the UK Government notice, on January 27, 2026, the vessel informed HM Coastguard that it intended to anchor in sheltered UK waters to repair a small hull defect during adverse weather. After SINEGORSK anchored at Blue Bay Anchorage within UK waters, the Centre for Transport Sanctions investigated and determined that the vessel fell within the scope of the Russia (Sanctions) (EU Exit) Regulations 2019 because it was Russian-flagged and registered and operated by a Russian-incorporated company.
On January 28, 2026, the Secretary of State for Transport exercised the discretionary power under regulation 57C of the Russia Regulations to issue a movement direction, which was served by HM Coastguard. SINEGORSK complied with the direction, leaving UK internal waters and subsequently the UK’s territorial sea. The action illustrates the practical application of the UK’s shipping sanctions, which are intended to restrict Russia’s ability to use its maritime sector to support or finance the war in Ukraine and include powers to deny in-scope vessels access to UK ports and issue movement and detention directions.
OTSI Publishes First Annual Review Covering 2025–26
The Office of Trade Sanctions Implementation (OTSI) has published its 2025–26 Annual Review, alongside an accompanying blog reflecting on its first full year of activity across compliance, licensing and enforcement (the “Review”). According to the Review, OTSI received 178 reports or referrals of potential trade sanctions breaches, with 111 (62%) originating from sectors subject to mandatory reporting obligations and 23 referrals from other UK government departments. OTSI closed 104 enforcement cases, including 41 where no breach was identified and 40 that were referred to HMRC, including for potential criminal enforcement or because the conduct predated OTSI’s enforcement powers. Around 6% of cases opened were initiated proactively, with OTSI indicating that it intends to significantly increase proactive and intelligence-led investigations as its intelligence capabilities develop.
The Review identifies implementation and enforcement of the Russia sanctions regime as a central focus and notes that a number of active investigations are expected to reach decision points during 2026–27. It also highlights the continued expansion of OTSI’s remit, including the introduction of Sanctions End-Use Controls in May 2026 to address circumvention and the expansion of its licensing responsibilities in April to cover exports of sanctioned goods and related ancillary services. Alongside enforcement, OTSI continues to emphasise compliance support through guidance, stakeholder engagement and outreach, including forthcoming sanctions workshops aimed particularly at SMEs navigating trade sanctions requirements.
UK to Double Maximum OFSI Penalty for Financial Sanctions Breaches
The UK Chancellor has announced that the maximum monetary penalty available to OFSI for financial sanctions breaches will be increased from 50% to 100% of the estimated value of the funds or economic resources involved in a breach. Under section 146 of the Policing and Crime Act 2017, OFSI can currently impose a penalty of up to the greater of £1 million or 50% of the estimated value of the breach; the announced change would increase the percentage-based limb to 100%, significantly increasing potential exposure for high-value breaches. According to a UK Government press release, HM Treasury stated that the measure is intended to strengthen the deterrent effect of the UK sanctions regime and drive stronger enforcement. The announcement signals a further tightening of the UK’s financial sanctions enforcement framework and reinforces the importance for businesses of maintaining effective sanctions compliance, screening and escalation controls.
NCA Issues Industry-wide Alert on A7 Russia Sanctions Evasion Network
The National Crime Agency (“NCA”) and National Economic Crime Centre have issued an industry-wide “flash alert” on the A7 sanctions evasion network, developed with OFSI, the FCDO and financial sector partners through the Joint Money Laundering Intelligence Taskforce. A7, established in 2024 by Ilan Shor and backed by sanctioned Russian state bank PSB and VEB.RF, is described as a cross-border payment mechanism used to circumvent sanctions, and claims to have settled more than $86 billion in its first year. The alert identifies methods used by the network to move value internationally, including overseas liquidity pools, globally registered shell companies or “sub-agents” operating local bank accounts, false invoices, VPNs used to disguise the location of operators, and promissory notes (“veksels”) that enable payments without correspondent bank transfers leaving Russia. OFSI has identified transactions between A7-linked shell companies and UK-incorporated beneficiaries, and the alert provides seven red-flag indicators for firms to assess against their existing AML and sanctions controls. The alert is particularly significant as it has been distributed across the regulated sector, underscoring expectations that firms incorporate emerging sanctions-evasion typologies into transaction monitoring and due diligence.
EU Developments
EU Considers Additional Russia Sanctions Listings Following Attempted Leipzig Drone Attack
On September 2, the German government announced that it had concluded Russia was responsible for the attempted drone attack at Leipzig/Halle Airport in August. German Interior Minister Alexander Dobrindt described the incident as a hybrid attack forming part of a broader pattern of Russian hybrid activities targeting European infrastructure and security.
The attempted attack was discussed at the informal meeting of Foreign Affairs Ministers held in Wicklow, where several Member States reportedly called for increased pressure on Russia through additional restrictive measures. Speaking at the press conference following the meeting, High Representative of the EU Kaja Kallas confirmed that work is ongoing on a package of up to 1,600 sanctions listings targeting Russia’s military-industrial complex. The package is being prepared with a view to adoption at the upcoming Foreign Affairs Council in October. Kallas further noted that at least one Member State had submitted additional listing proposals. Separately, German Foreign Minister Johann Wadephul stated that the EU would continue work in the coming weeks on further listings targeting Russian individuals.
In parallel, European Commission President Ursula von der Leyen stressed that hybrid attacks would not go without a clear response and referred to forthcoming discussions among EU foreign ministers on additional sanctions against Russia.
CJEU Judgment on the Standard of Proof for Establishing “Control” under Russia Asset Freeze Sanctions
The Court of Justice of the European Union (CJEU) delivered its judgment in Case C‑147/25 (Inter Rao Lietuva), following a request for preliminary ruling from the Supreme Administrative Court of Lithuania regarding Article 2(1) of Council Regulation (EU) 269/2014. The case concerned the inclusion of a Lithuanian electricity supplier on a national list of persons whose funds and economic resources were to be frozen on account of its alleged links with a person subject to EU sanctions.
The Court held that national authorities may compile and publish such lists in order to implement the asset-freezing obligation under Article 2(1). However, the national authority must establish that the funds and economic resources of the person concerned belong to, or are owned, held or controlled by, a person, entity or body designated under Annex I to Council Regulation 269/2014. The mere existence of a “link” between the person subject to the national measure and an EU-designated person is not sufficient to justify inclusion on a national list of persons whose assets are to be frozen.
The Court further held that the reasons for the national measure must be supported by objective and sufficiently solid evidence. The national competent authority may establish control by direct evidence or by a sufficiently specific, precise and consistent body of indicia. In that regard, the Court found that the general nature of Russia’s political regime, including its autocratic and oligarchic character, does not constitute sufficiently solid evidence capable of establishing that the President of the Russian Federation exercises control over Inter Rao Lietuva. Such circumstances may be taken into account as part of the factual context, but cannot take the place of evidence demonstrating the existence of control for the purposes of Article 2(1).
Asia-Pacific Developments
Chinese Court Freezes $300M in Nexperia Assets Amid Ownership Battle With Wingtech
The Dongguan Intermediate People’s Court has frozen up to 2.14 billion yuan ($300 million) in Chinese assets belonging to Dutch chipmaker Nexperia following a lawsuit by its parent company, Wingtech Technology. Wingtech sued Nexperia and three executives in May and is seeking 8 billion yuan in damages after being stripped of control of Nexperia by Dutch authorities over national‑security concerns. The dispute, which previously saw China impose export controls on Nexperia’s Chinese operations that disrupted shipments, gives Wingtech leverage to regain voting control, though it does not change the company’s management or resolve the broader ownership fight.
Apex Logistics Cooperates With US Probe Into Illegal Chip Exports to China
Singapore-based logistics firm Apex Logistics is cooperating with a US government investigation into whether it illegally transported restricted AI chips to China in 2024. The company has since been cooperating with the probe and plans to “continue to work with them until the matter is resolved.” Apex’s parent company, Kuehne+Nagel, affirmed that the freight forwarder maintains its commitment to export regulations.
China Demands US Lift “Illegal” Iran-Related Sanctions on Its Companies
On September 3, 2026, China’s Ministry of Commerce has urged the US to immediately lift unilateral sanctions imposed on Chinese companies and citizens over alleged ties to Iran, strongly opposing the measures as illegal actions lacking UN Security Council authorization. The spokesperson warned that these sanctions disrupt global energy security, asserting that Beijing will firmly safeguard the legitimate rights and interests of its businesses and individuals.
