Overview
The Sanctions Update, compiled by attorneys from Steptoe’s award-winning International Regulatory Compliance team and the Stepwise: Risk Outlook editorial team, publishes every Monday. Guided by the knowledge of Steptoe’s industry-leading International Trade and Regulatory Compliance team, the Sanctions Update compiles and contextualizes weekly developments in international regulatory enforcement and compliance, as well as offers insights on geopolitical context, business impacts, and forthcoming risks.
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The Lede
The Trump Administration is Continuing its Crackdown on Transnational Scam and Fraud Networks
On June 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued sanctions against 9 individuals and 26 entities reportedly linked to the Prince Group. The US government alleges the organization to be a leading transnational criminal organization based in Cambodia. The sanctions, which were imposed pursuant to Executive Order 13581, target the Prince Group’s leadership and entities linked to them across Asia. Treasury also amended a rule from October 2025 against the Huione Group, alleged to be one of the Prince Group’s critical entities for money laundering, to cover any successor entities.
According to Treasury, cyber-enabled scam and fraud crimes cost Americans more than $10 billion dollars in 2024 and have grown over the past several years. Many of these scam operations are run by transnational criminal organizations based in Southeast Asia. While these organizations target victims of their fraud operations through various methods, they also use forced labor to man their operations by trafficking victims under the promise of legitimate work.
OFAC’s addition of new Prince Group-linked individuals and entities to the SDN list is part of a government-wide initiative across the Trump administration to target scam center groups that has been ramping up over the past year. In October 2025, Washington, in coordination with the United Kingdom, released its first tranche of sanctions against the Prince Group, sanctioning 146 entities. In January 2026, Chen Zhi was arrested by Cambodia and extradited to China following a joint US-China transnational crime investigation. Beijing had reportedly been investigating the Prince Group since 2020. In March, the White House issued Executive Order 14390 on combating cybercrime, fraud, and other predatory schemes, and in June the FBI announced Operation Riptide, a “coordinated law enforcement campaign targeting criminal actors and the key services they rely on” under the direction given by Executive Order 14390.
In conjunction with the sanctions, the US has brought a number of enforcement actions against the Prince Group. After the arrest of Chen Zhi in January, the head of the Huione Group Li Xiong was likewise arrested in Cambodia in April and extradited to Beijing.
Large seizures of cryptocurrency have also been a major element of the US’ campaign against the Prince Group. The joint US-UK action in October 2025 seized more than $14 billion worth of bitcoin, the largest known seizure of bitcoin in history. Alongside the most recent sanctions announcement, the US Department of Justice (DOJ) seized a cloud computing account used by the Huione Group’s subsidiaries, which DOJ referred to as “a part of a technological backbone” that supported the Prince Group’s activities.
Washington has worked with several international partners in its efforts to dismantle the Prince Group. The US, UK, and South Korea have all sanctioned the Prince Group, and the US has coordinated with both UK and Chinese authorities on actions against the Prince Group. Singapore and Hong Kong have also taken steps to sanction entities linked to the Prince Group. Vietnamese police caught two groups trying to set up online scam operations in the country’s north in June. Sri Lankan authorities have made more than 1,000 arrests of foreign nationals this year in raids on alleged scam centers. A raid in Colombo in June resulted in the arrests of 18 Chinese nationals and one national of Laos.
Most importantly, Cambodia, where the Prince Group is primarily based, has greatly increased its focus on combating large-scale criminal organizations based in the country, such as allowing the extradition of Prince Group leaders to China and liquidating a bank founded by Chen Zhi. Cambodia has also begun reforming its legal environment to promote fairness, transparency and efficiency in the commercial sector and to boost the country’s overall attractiveness for businesses.
Given the Trump administration’s prioritization of actions against the Prince Group and against the overall illicit scam economy, it is likely that Washington will continue to focus on combatting and dismantling groups linked to the cyber scam sphere and seizing assets that are derived from the proceeds of the alleged criminal activity. Both the FBI’s Operation Riptide and Executive Order 14390 demonstrate continued political will in this area. Washington has cooperated with international partners on these efforts, which will likely continue, and Washington may look to expand international cooperation if these groups successfully relocate their operations to other countries in the region. However, it is also possible that the administration could step up pressure on other countries and entities to take more decisive actions against transnational criminal organizations conducting scam operations as groups relocate.
US Developments
Renewed Hostilities Threaten US-Iran MOU and Negotiations
On Sunday, the US and Iran agreed to halt a series of tit-for-tat strikes that began late last week and resume talks on the Memorandum of Understanding (MOU) in Qatar on Tuesday. The renewed hostilities between the United States and Iran had threatened to sidetrack the negotiations to end the conflict. The attacks reportedly began after Iran fired on a container ship as it passed through the Strait of Hormuz and included strikes on Iranian military targets around the Strait and American assets in Bahrain and Kuwait.
Earlier in the week, on June 22, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) X, which implemented Point 10 of the MOU by generally authorizing transactions ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil, petrochemical products, or petroleum products of Iranian origin. GL X is the first implementation of a significant, but potentially temporary, shift in US sanctions policy toward Iran. We covered the legal and policy impact of the MOU and GL X in last week’s update and a recent blog post.
US Continues to Impose Sanctions on Overseas Scam Operations
On June 23, 2026, OFAC sanctioned nine individuals and 26 entities allegedly connected with the Prince Group, an organization previously designated as a Specially Designated National (SDN) and a Transnational Criminal Organization (TCO) on October 14, 2025. In a statement accompanying the designations, Secretary of the Treasury Scott Bessent said that “[t]he Trump Administration is united in its efforts to dismantle these overseas criminal enterprises, and Treasury will continue using its tools to disrupt the networks behind this egregious fraud and protect Americans.”
Separately, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed amending its October 2025 Rule, which designated the Huione Group, allegedly a supporter of Prince Group, a financial institution of “primary money laundering concern.” The proposed rule would amend the definition of Huione Group to include H-Pay Service PLC (“H-Pay”) and any successor entity, which, if promulgated, would subject H-Pay to the “special measures” imposed on the Huione Group by the October 2025 Rule, which would effectively sever H-Pay from the US financial system.
The Trump administration continues to target alleged Southeast Asia-based scam centers and their affiliates. OFAC previously imposed sanctions on individuals and entities linked to alleged scam centers on April 23, 2026, as well as May 5, May 29, September 8, October 14, and November 12, 2025.
State Department Applies More Sanctions Pressure on Cuba
On June 23, 2026, the Department of State announced sanctions against five entities and one individual to “further the Trump Administration’s comprehensive push to end the Cuban regime’s malign activities, both in Cuba and across [the western] hemisphere.”
Specifically, the State Department targeted three entities affiliated with Grupo de Administración Empresarial S.A. (GAESA), allegedly a “Cuban military-controlled umbrella enterprise,” which was previously designated on May 7, 2026; two entities allegedly involved in Cuba’s metals and mining sector; and one adult family member of Alejandro Castro Espin, who was designated on June 4, 2026. The designations were made pursuant to Executive Order (EO) 14404, which was issued on May 1, 2026, and which we covered in the May 4, 2026 edition of the Sanctions Update.
These designations follow related actions taken by the Trump administration to exert pressure on the Cuban regime on June 11, June 4, May 18, and May 7, 2026.
OFAC Issues New Sudan-Related Sanctions
On June 26, 2026, OFAC imposed sanctions against eight individuals and entities allegedly linked to procurement and recruitment networks that fuel the ongoing civil war in Sudan. According to OFAC, these networks have enabled both the Sudanese Armed Forces (SAF) and Rapid Support Forces (RSF) to expand the scale and intensity of their conflict.
Specifically, OFAC designated multiple entities affiliated with the Defense Industries System (DIS), Sudan’s largest defense enterprise, which allegedly supports arms and materiel procurement for the SAF and which was previously designated by OFAC on June 1, 2023. OFAC also imposed sanctions against three individuals alleged to be affiliated with a transnational network recruiting former Colombian military personnel to fight in Sudan for the RSF, marking the third tranche of such designations (following related actions in December 2025 and April 2026).
On the same day, the Department of State announced that it was imposing a second round of sanctions on Sudan pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act. Among other things, these sanctions were said to include “opposing loans or financial or technical assistance to Sudan from international financial institutions, further export restrictions by the Commerce Department, and a bar on Sudanese state-owned air carriers from operating in the United States.”
Treasury Sanctions Rwandan Gold Refinery
On June 25, 2026, OFAC sanctioned multiple individuals and entities alleged to be part of a network coordinating with the March 23 Movement (M23), a US and UN-designated entity, to smuggle minerals from eastern Democratic Republic of the Congo (DRC) to Rwanda.
According to OFAC, this action supports the US-brokered Washington Accords, an agreement signed by the DRC and Rwanda on December 4, 2025, intended to facilitate peace following the escalation of violence in eastern DRC in January 2025, which resulted in M23 capturing Goma, the capital of North Kivu province.
OFAC Sanctions ISIS Facilitators
On June 22, 2026, OFAC sanctioned three individuals and six entities in multiple jurisdictions for allegedly facilitating transactions on behalf of the Islamic State of Iraq and Syria (ISIS). Specifically, OFAC said that the designations target individuals and entities that enable ISIS to move funds among its regional affiliates, including through cryptocurrency.
In a statement accompanying the designations, Secretary Bessent said that the “United States will leverage every tool at its disposal to crush ISIS’s remaining capabilities and protect American lives.”
OFAC Amends Lukoil-related GL
On June 25, 2026, OFAC issued an amended Russia-related general license (GL) 131G, “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.”
We covered GL 131 in previous Sanctions Updates on November 17 and December 8, 2025. Broadly, GL 131 authorizes certain transactions related to the negotiation of and entry into contracts with PJSC Lukoil (Lukoil) or any of its affiliates for the sale, disposition, or transfer of Lukoil International GmbH (LIG) or any of its majority-owned entities, subject to certain restrictions.
GL 131G extends the term of the GL by around 30 days, from June 27, 2026, to July 25, 2026.
Alongside GL 131G, OFAC issued two amended Russia-related FAQs, which reflect the change to the license: FAQ 1224 and FAQ 1225.
OFAC Removes Multiple Russian Persons from SDN List
OFAC has continued to remove multiple individuals and entities from the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) that were previously designated under Russia-related sanctions authorities.
- On June 23, 2026, OFAC removed three individuals previously sanctioned pursuant to EO 14024, namely Anton Alekseevich Krugovov, Tamara Aleksandrovna Topchi, and Natalya Vladislavovna Puzyrnikova.
- On June 24, 2026, OFAC removed seven individuals, two entities, and two vessels previously sanctioned pursuant to EO 14024.
Treasury did not provide a comment on why these individuals and entities were removed.
UK Developments
OFSI Amends Prince Group Insolvency General Licence
OFSI has amended General Licence INT/2026/9491628, which permits certain insolvency-related payments and activities involving the sanctioned Prince Group and its subsidiaries (the “Prince Group GL”). The principal amendment introduces a revised definition of "Permitted Insolvency Activities", clarifying that payments and other actions connected with insolvency proceedings are authorised where they are carried out under the direction of, or with the consent of, an insolvency practitioner, provided they do not make funds or economic resources available to any designated person other than the Prince Group designated persons or their subsidiaries. The amended definition also confirms that the revised permissions apply only while the insolvency practitioner continues to act in that capacity.
The amendments also make consequential changes throughout the Prince Group GL by expanding the scope of authorised persons able to rely on the licence, including insolvency practitioners, designated Prince Group entities and subsidiaries, and updating the associated notification and record-keeping requirements. The Prince Group GL otherwise continues to facilitate the orderly administration of insolvency proceedings involving the Prince Group while maintaining safeguards to prevent funds or economic resources from being made available contrary to the Global Human Rights Sanctions Regulations 2020. Parties intending to rely on the Prince Group GL should review the amended version carefully to ensure compliance with the updated permissions and conditions.
OFSI and OFAC Publish Joint UK–US Sanctions Guidance
OFSI and OFAC have published joint guidance providing a comparative overview of the UK and U.S. sanctions regimes. Produced under the UK–US Enhanced Partnership following an in-person meeting between the two authorities in London in January 2026, the guidance is intended to help businesses understand the key similarities and differences between the two frameworks. It compares core aspects of each regime, including sanctions lists, licensing processes, reporting obligations, record-keeping requirements and broader compliance expectations.
Alongside the guidance, OFSI has published a blog highlighting the continued success of the UK–US Enhanced Partnership, which has now entered its fifth year. The blog explains that the initiative is intended to maximise the effectiveness of sanctions, minimise unintended consequences and make sanctions easier for businesses to understand and implement through closer cooperation between the two authorities. The publication of the comparative guidance underscores the increasing alignment between OFSI and OFAC and provides a practical resource for organisations managing cross-border sanctions compliance programmes.
OFSI Clarifies Amended Lukoil International General Licence via New FAQ
OFSI has published new FAQ 196 following its recent amendment to General Licence INT/2025/8031092, which permits the continuation of business involving Lukoil International GmbH and its subsidiaries (the “Lukoil GL”). The amended licence removed the previous requirement for funds made available, directly or indirectly, to or for the benefit of Lukoil International GmbH or its subsidiaries to be paid into a frozen account. The new FAQ clarifies the practical effect of this change and provides additional guidance for businesses relying on the Lukoil GL. Importantly, OFSI confirms that the amendment does not permit funds to be made available to or for the benefit of PJSC Lukoil, the UK designated Russian parent company. The FAQ therefore distinguishes between the treatment of Lukoil International entities operating under the licence and the continuing asset freeze applicable to PJSC Lukoil. Businesses intending to rely on the Lukoil GL should review both the amended licence and FAQ 196 carefully to ensure they understand the revised permissions and continue to comply with the Lukoil GL’s conditions.
EU Developments
EU Council Renews Economic Sanctions Against Russia
On June 25, the EU Council renewed the restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine for another year, until July 31, 2027. The decision follows the agreement reached by EU leaders at the European Council summit on June 18-19 to prolong the economic sanctions against Russia for an additional twelve months.
The shift from the previous six-month renewal cycle to a twelve-month period reduces the frequency with which unanimous approval by all 27 Member States is required to maintain the sanctions, thereby limiting recurring opportunities for individual Member States, such as Hungary and Slovakia in previous renewal rounds, to exert leverage or delay the renewal of the measures.
The sanctions regime, first introduced in 2014, covers key sectors of the Russian economy through sectoral restrictive measures targeting trade, financial services, energy, and dual-use goods and advanced technologies. The restrictive measures have been significantly expanded through successive sanctions packages, adopted in response to Russia’s war of aggression against Ukraine.
EU Council Reviews Sanctions Listing Under South Sudan Regime
The EU Council recently concluded its periodic review of the list of persons subject to restrictive measures under the South Sudan sanctions regime and determined that the designation of one individual should be maintained. Specifically, the Council confirmed that Michael Makuei Lueth, former Minister for Information and Broadcasting and currently Minister of Justice and Constitutional Affairs, remains subject to restrictive measures, while updating the statement of reasons underpinning his designation. The revised statement confirms Makuei Lueth’s ongoing obstruction of the political process in South Sudan, including interference with the 2015 Agreement on the Resolution of the Conflict in South Sudan (ARCSS) and the 2018 Revitalized ARCSS (R‑ARCSS), as well as more recent conduct restricting political and democratic space in 2025.
The restrictive measures under Decision (CFSP) 2015/740 include an asset freeze, a prohibition on making funds or economic resources available, and a travel ban within the EU.
EU Council Renews Sanctions Against Haiti
The EU Council extended the restrictive measures against Haiti under Council Decision (CFSP) 2022/2319 until July 29, 2027. The sanctions regime currently targets nine individuals and one entity responsible for threatening the peace, security or stability of Haiti, or for undermining democracy or the rule of law in Haiti. Designated individuals and entities are subject to asset freezes and a prohibition on making funds or economic resources available. In addition, designated individuals are also subject to a travel ban within the EU.
Asia-Pacific Developments
China Retaliates Against US Blacklists with Procurement Ban and Export Controls on Defense-Linked Firms
On June 22, 2026, China announced a series of sanctions-related measures targeting US companies. The Ministry of Finance barred government procurement entities from purchasing products manufactured by 46 designated US firms, including Raytheon Missiles & Defense, while exempting US-invested companies operating in China. Separately, the Ministry of Commerce added 10 US entities, including Red Cat Holdings, Inc., Teal Drones, Inc., IMSAR, Jaia Robotics, Inc., Ball Aerospace & Technologies Corp., Oshkosh Defense, MP Materials Corp., and USA Rare Earth, Inc., to China’s export control list, prohibiting exports of Chinese dual-use items to those firms. China reportedly said the measures were a response to the US Department of Defense’s recent expansion of its Chinese Military Companies List, adding major firms such as BYD and Baidu.
Russia Urges South Korea to End North Korea Sanctions and Halt Pressure Campaigns
Russia sharply criticized South Korea’s regional security policy and sanctions stance, according to statements from the Russian Foreign Ministry and reporting by NK News. On June 25, 2026, Russian Deputy Foreign Minister Andrei Rudenko told South Korean Ambassador Lee Seok-bae that Seoul was aligning with Western “anti-Russian” actions and urged it to abandon pressure and sanctions against North Korea, arguing that joint military exercises with the United States near the DPRK were increasing tensions on the Korean Peninsula. Russian Foreign Ministry spokesperson Maria Zakharova echoed the criticism, warning that recent South Korea-US naval and air drills conducted near North Korean waters could undermine regional security. The remarks came after South Korea joined G7 and European leaders in condemning Russia–North Korea military cooperation and calling for North Korean denuclearization.
