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
US Issues Russian Oil Waiver to India, Then Expands Relief Globally
On March 12, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 134, authorizing the sale, delivery, or offloading of Russian-origin crude oil and petroleum products loaded on vessels on or before March 12, with the waiver running through April 11. This marked a significant broadening of Russia-related General License 133, issued on March 5, issued, which reopened a narrow but consequential channel for Indian refiners to buy Russian-origin crude oil and petroleum products that had already been loaded onto vessels by 12:01 a.m. eastern time on March 5. The shift moves the Trump administration’s decision from a narrow India exception into a broader, time-limited sanctions concession aimed at stabilizing global oil markets after the Iran war and the disruption of shipping through the Strait of Hormuz pushed crude prices above $100 a barrel.
The difference between the two licenses is significant. GL 133 was limited to deliveries at Indian ports and to purchasers organized under Indian law. GL 134 removes India-specific conditions and authorizes transactions ordinarily incident and necessary to the movement of covered Russian cargoes regardless of destination, so long as the oil or petroleum products were loaded by the March 12 cutoff and provided that other sanctions restrictions do not apply. It also covers supporting services needed to complete those voyages, including docking, anchoring, crewing, bunkering, insurance, vessel management, classification, and salvage, and applies even where the cargo was loaded on certain blocked vessels or produced by sanctioned Russian entities. Treasury Secretary Scott Bessent described the broader waiver as “narrowly tailored” and “short-term,” while Energy Secretary Chris Wright had earlier defended the India waiver as a way to tamp down fears of shortage and price spikes rather than respond to an actual lack of oil.
India nevertheless remains at the center of the story. Before the first waiver was issued, India obtained about 40% of its crude imports through the Strait of Hormuz and had inventories covering only about 25 days of demand. Indian refiners had already begun cutting Russian purchases under pressure from Washington, as reducing those purchases helped New Delhi clinch an interim trade deal with the United States lowering blanket tariffs from 50% to 18%. Once Middle Eastern supply disruptions intensified, Indian state refiners moved quickly back into the Russian market, snapping up at least 30 million barrels of prompt cargoes. Even after the broader March 12 waiver, the practical effect still appears heavily India-weighted, with most covered cargoes already placed with Asian buyers, particularly India. Whether the sanctions relief will have a material impact on prices remains to be seen: The State Bank of India also remained unwilling to process payments for Russian oil even after the US reprieve, showing that legal relief is moving faster than the financing infrastructure needed to support it.
The market effect is nonetheless real, reducing uncertainty around the movement of covered cargoes, benefitting Russian oil revenues. The broader March 12 waiver could affect around 100 million barrels of Russian crude, according to Russia’s presidential envoy Kirill Dmitriev, although much of that oil appears to have already been in transit. The result is that the waiver does more than relieve a short-term logistical crunch: it improves market conditions for Russian barrels and risks boosting Moscow’s near-term revenue even as the West continues its efforts to constrain them. With the price shattering the G7 $60 cap on Urals crude, Russia could generate an additional $10 billion for its war efforts, according to Ukrainian President Volodymyr Zelenskyy.
The license reflects the Trump administration’s responsiveness to global market stability. Over the past week, President Trump said the United States was lifting some oil-related sanctions “[until] the Strait is up,” explicitly linking sanctions flexibility to the reopening of Hormuz. GL 134, issued seven days after the India waiver, makes clear that GL 133 was not merely a one-off exception but the first step in a broader, if still temporary, relaxation of Russian oil sanctions. The move may be linked to White House concern that rising oil and gasoline prices would hurt US consumers and businesses ahead of the November midterm elections. In that sense, the administration’s sanctions posture is now being shaped as much by inflation and energy security as by the goal of denying Russia revenue.
GL 134’s broader flexibility has sharply intensified a split with Europe. Earlier in the week, the European Commission urged Washington to strictly enforce the G7 price cap on Russian oil. After GL 134, criticism hardened: European Commission President Ursula von der Leyen said now was not the time to relax sanctions; French President Emmanuel Macron and Norway’s prime minister voiced similar objections; German Chancellor Friedrich Merz said the decision was “wrong” because there was a price problem, not a quantity problem; and the UK said it would not loosen sanctions at all. Moscow, by contrast, welcomed the move, with Kremlin spokesman Dmitry Peskov saying Russia and the United States shared an interest in stabilizing global energy markets. Thailand said it was ready to discuss buying Russian crude, and Japan said it would consider whether to purchase Russian oil. The result is a sanctions policy that remains formally intact but subordinated, at least in moments of acute market stress, to the competing objectives of energy security, inflation control, geopolitical crisis management, and domestic political conditions.
US Developments
Treasury Amends Venezuela-Related General Licenses
On March 13, 2026, OFAC issued three amended Venezuela-related GLs:
- GL 46B, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;”
- GL 48A, “Authorizing the Supply of Certain Items and Services to Venezuela;” and
- GL 49A, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela.”
Each of the GLs amends its prior version by expanding the scope of the authorization to include transactions or contracts related to “petrochemical products” and new electricity generation, transmission, storage, or distribution activities in Venezuela. The GLs define “petrochemical products” to include fertilizer products and fertilizer precursor chemicals, including those listed by HS code in newly created Annexes to each GL. As part of these changes, OFAC also issued two amended FAQs: FAQ 1226 and FAQ 1227.
For more information on the purpose and scope of the original GL 46, see our previous Sanctions Update on February 2, 2026. For more information on original GLs 48 and 49, see our previous Sanctions Update on February 18, 2026.
OFAC Targets Facilitators of North Korean IT Worker Fraud
On March 12, OFAC sanctioned six individuals and two entities for their alleged roles in facilitating North Korean government-orchestrated information technology (IT) worker schemes that defraud US businesses and generate revenue for Pyongyang’s weapons of mass destruction programs.
In an accompanying statement, Secretary Bessent stated that, “[u]nder President Trump’s leadership, Treasury will continue to follow the money in order to protect US businesses” from North Korea’s “deceptive schemes carried out by its overseas IT operatives.” Treasury’s press release also noted that these sanctions are part of a whole-of-government effort to counter North Korea’s revenue generation schemes, specifically their IT worker schemes.
OFAC’s designations follow similar actions taken on November 4, September 25, August 27, July 24, and July 8, 2025.
Treasury Designates Alleged Sham Charity Network Linked to Hamas
On March 12, OFAC designated four alleged sham charities it says directly fund Hamas’s military wing and terrorist activities. This includes three Türkiye-based nonprofit organizations that allegedly enable Hamas to generate external revenue, as well as an Indonesia-based charity OFAC claims coordinates with Hamas to fund and distribute material exclusively to its fighters.
Secretary of the Treasury Scott Bessent said that sham charities continue to be used by Hamas to support its terrorist operations, and that Treasury will continue to target these networks, wherever they operate. Treasury took similar measures against Hamas’s alleged network of sham charities on January 21, 2026, and June 10, 2025.
OFAC Removes Multiple Russian Persons from SDN List
On March 13, OFAC removed the following two individuals and four entities from the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) that were previously sanctioned pursuant to Executive Order 13694, as amended, for their involvement with malicious cyber-enabled activities.
The two individuals and three of the entities were previously sanctioned by OFAC on September 23, 2020. Nikita Gennadievitch Kovalevskij was sanctioned for owning or controlling Optima Freight OY, a Finland-based freight forwarding company that allegedly acquired underwater equipment for Divetechnoservices, a sanctioned, Russian Federal Security Services (FSB)-aligned entity. The three entities, GCH Finland OY, Unicum Trade OY, and ACEX OY, were all sanctioned for being owned or controlled by Kovalevskij, who served as their Managing Director. Boris Aleksandrovich Gaykovich was sanctioned for having acted for or on behalf of Okeanos, a Russia-based underwater technology company with a history of cooperating with the FSB in underwater operations.
Finally, the other entity, Quantlog OY, was sanctioned on March 31, 2022, for allegedly being a front company registered by Kovalevskij in 2020 to evade sanctions and continue illicit procurement activity.
Treasury did not provide a comment on why these individuals and entities were removed.
UK Developments
UK Government Publishes Strategic Approach to Sanctions Enforcement
The UK Government has published a document outlining its strategic approach to enforcing breaches of UK sanctions. The publication follows the recent cross-government review of sanctions implementation and enforcement, which recommended developing a clearer enforcement strategy to help industry better understand how sanctions breaches are addressed and the potential consequences of non-compliance. The document brings together information on both civil and criminal enforcement across government departments, regulators and enforcement agencies involved in implementing UK sanctions. The guidance sets out the UK Government’s overarching enforcement principles, clarifies the roles and responsibilities of relevant authorities, and highlights the range of enforcement tools available, including civil penalties and criminal prosecution. It also outlines how mitigating and aggravating factors may be considered in enforcement decisions and emphasises the importance of strong compliance frameworks within industry. Overall, the publication aims to improve industry understanding of the UK’s sanctions enforcement framework and reinforce the serious consequences that may arise from sanctions breaches, particularly where there are deliberate attempts to evade restrictions.
Guidance on Countering Russian Sanctions Evasion Updated
The Department for Business and Trade has updated its guidance on countering Russian sanctions evasion and circumvention. The updated guidance contains a revised list of goods at higher risk of circumvention, as well as updating the guidance’s list of third country exporters.
Guidance on OFSI’s Approach to Assessing “Reasonableness” in Financial Sanctions Licensing
OFSI has published a new blog post outlining its updated approach to the assessment of reasonableness in the context of financial sanctions licensing. The blog post sets out a number of changes to the process for the assessment of reasonableness. Specifically, OFSI will now require an independent Costs Draftsperson’s Report to be submitted as part of legal services licence applications in certain circumstances. Additionally, applicants for licences under the maintenance of frozen funds and economic resources licensing ground are encouraged to submit an independent expert report when authorisation is being sought for high value, novel, or complex payments such as in the case of niche assets (e.g., superyachts or racing cars). In other circumstances when an assessment of reasonableness is required, OFSI will generally consider evidence dated within the past six months to be appropriate to its assessment and will require an explanation when more aged evidence is being relied upon to support an assessment of reasonableness.
EU Developments
EU Council Extends Financial Sanctions Regime Targeting Russia
The EU Council has extended the restrictive measures targeting those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for an additional six months, now effective until September 15, 2026. Established under Decision 2014/145/CFSP and Regulation (EU) 269/2014, the sanctions regime imposes asset freezes and a prohibition on making funds or economic resources available to listed persons. The individual listings currently apply to approximately 2,600 individuals and entities designated in response to Russia’s ongoing military aggression against Ukraine.
Following the review of the sanctions regime, the EU Council decided to not renew the listings of two individuals and to remove five deceased persons from the sanctions list.
European Commission Publishes FAQs on the Provision of Payments Services
The European Commission published a new set of FAQs on sanctions against Russia, with a focus on the prohibition on providing crypto-asset services, certain payment services, or issuing electronic money to Russian nationals, individuals residing in Russia, and legal persons or entities established in Russia under Article 5b of Regulation (EU) 833/2014.
The FAQs clarify the scope of the prohibition introduced by the 19th sanctions package against Russia. It also addresses compliance responsibilities for payment service providers, the treatment of indirect service provision, and distinctions between prohibited and permitted activities under Article 5b.
EU Member State Ambassadors Approve Sanctions Targeting 19 Iranian Officials and Entities Responsible for Serious Human Rights Violations
On March 11, High Representative of the EU Kaja Kallas announced that ambassadors of EU Member States within the EU Council had endorsed new sanctions targeting 19 Iranian regime officials and entities responsible for serious human rights violations. In a message on X, Kallas noted that the EU intends to protect its interests and pursue those responsible for domestic repression.
The EU ambassadors’ decision will require final approval from the EU Council.
EU Council Updates Listing under ISIL (Da’esh) and Al-Qaeda Sanctions Framework
The EU Council has removed the terrorist organization Al-Nusrah Front for the People of the Levant from the sanctions listing under the autonomous restrictive measures regime targeting ISIL (Da’esh) and Al-Qaeda, following a February 2026 update at the UN level. Changes to Council Regulation (EC) 881/2002 reflect the UN Security Council Sanctions Committee’s decision to remove one entry from the list of persons, groups and entities to whom restrictive measures should apply.
CJEU Judgment on Interpretation of Asset Freezing of Unlisted Entities Whose Funds and Economic Resources are Owned or Controlled by a Listed Person
The Court of Justice of the European Union (CJEU) delivered its judgment in Case C‑84/24 following a request for a preliminary ruling from the Supreme Court of Lithuania concerning the interpretation of Article 2(1) and (2) of Regulation 765/2006 on restrictive measures in respect of Belarus.
The Court confirmed that Article 2(1) must be interpreted as meaning that the freezing of funds is not limited to persons, entities or bodies listed in Annex I, but also applies to the funds and economic resources of a legal person, entity or body not included on that list, provided that they are owned, held or controlled directly or indirectly by a listed person, entity or body. The Court held that such an interpretation is necessary to achieve the objective pursued by the restrictive measures and to prevent their circumvention. For the same reasons, the concepts of “held” and “controlled” must be interpreted broadly, encompassing both direct and indirect means of influencing the use of funds and economic resources of a person, entity or body linked to a listed person.
The Court further held that a shareholding of 50% by a listed person gives rise to a presumption that the listed person controls the company and its assets. As a result, the funds and economic resources of that company must be frozen. According to the Court, this presumption must be rebuttable. Member States must therefore establish procedures enabling the legal person, entity or body concerned, as well as the listed person to challenge the freezing measure and have it lifted if it is demonstrated that the listed person does not in fact hold or control those funds or economic resources, taking into account the governance structure, articles of association, and the functioning in practice of the legal person, entity or body concerned.
Asia-Pacific Developments
Bithumb Faces Proposed Six-Month Partial Suspension as South Korea FIU Targets AML Breaches
On March 9, 2026, South Korea’s Financial Intelligence Unit (FIU) reportedly issued a preliminary notice proposing a six-month partial business suspension for Bithumb, the country’s second-largest cryptocurrency exchange, over alleged anti-money laundering (AML) and Know Your Customer (KYC) failures. According to media reports, regulators accused Bithumb of continuing transactions with unregistered overseas virtual asset operators and inadequate customer verification processes, in violation of the Act on Reporting and Using Specified Financial Transaction Information. The sanctions, which also include disciplinary action against the CEO, would restrict virtual asset transfers only for newly registered users, leaving existing customers’ deposits, withdrawals, and trading unaffected. The final penalty will be determined by an FIU sanctions review committee later this month, with potential adjustments during deliberations.
The Insider Uncovers 6,000 Firms Supplying Russian Defense Sector, Majority Based in China
On March 11, 2026, investigative outlet The Insider identified over 6,000 foreign companies trading with sanctioned Russian firms and defense industry suppliers between 2024 and 2025, despite international restrictions. More than 4,000 of these exporters are based in mainland China and Hong Kong, with others located in Turkey, the UAE, and India. Chinese shipments included turbojet engines suitable for large military drones, titanium forging equipment for armor manufacturing, and electronic components. Turkey, while smaller in exporter numbers, supplied high‑end Western‑made machinery such as CNC milling centers and circuit board testing systems, often resold to Russian defense contractors like Kalashnikov Concern, which “produces small arms and ZALA drones,” and Votkinsk Plant, which produces “Iskander missiles.” The report warns that targeted sanctions against individual resellers have limited impact due to shell companies quickly replacing each other. Instead, The Insider advocates sweeping sanctions on thousands of suppliers at once to disrupt supply chains, pressure Chinese and Turkish banks, and significantly hinder Kremlin military production.
Japan Weighs Russian Oil Purchases After US Grants Temporary Sanctions Waiver Amid Iran War
On March 13, 2026, Japan’s Ministry of Economy, Trade and Industry (METI) reportedly said it will weigh whether to purchase Russian crude following a 30‑day US sanctions waiver issued amid the Iran war. The waiver, announced by Treasury Secretary Scott Bessent, permits countries to buy sanctioned Russian oil stranded at sea to help stabilize global energy markets disrupted by the US-Israeli conflict with Iran. Another METI official stressed that any decision would balance Japan’s national interests with Group of Seven coordination and global diplomatic considerations. Japan relies heavily on Middle Eastern crude — 94% of imports in 2025, with 93% transiting the Strait of Hormuz — now effectively blocked by Iran. To mitigate supply shocks, Tokyo will release about “80 million barrels from its strategic reserves, equivalent to 45 days of supply,” and has asked refiners to use this crude to secure domestic needs. Industry Minister Ryosei Akazawa said refiners are also seeking alternative supplies from the US, Central Asia, and South America, underscoring Tokyo’s cautious approach to Russian imports under the temporary waiver.
