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 Eases Venezuela Oil Sanctions as Pressure on Oil Markets Mount
On March 18, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 52 (“GL 52”), authorizing all transactions by Petróleos de Venezuela S.A. (PdVSA), the state-owned oil and gas company of Venezuela, and its majority-owned subsidiaries previously prohibited under EO 13884. This measure is part of a series of actions by the Trump administration to stabilize oil and gas prices, which have soared amid the US-Israel-Iran conflict. Repeated attacks on critical energy infrastructure in the Middle East and the effective closure of the Strait of Hormuz have severely disrupted global oil supply. With no clear path to de-escalation, governments are left scrambling to secure alternative energy supplies to cushion the global economy from prolonged shocks.
GL52 provides authorization for “established US entities” to participate in the full lifecycle of oil and gas operations in Venezuela, incentivizing investment in the country’s energy sector and supporting US oil and gas companies, all while increasing global oil supply. However, it is layered with financial and geopolitical limitations. While oil trade is permitted, direct payments to PvDSA and other sanctioned entities and individuals remain prohibited; payments must be directed to the US Treasury’s “Foreign Government Deposit Funds,” or another Treasury-controlled account. Payments also cannot be made in debt swaps, gold, or digital currencies. Moreover, the license applies only to “established US entities” formed on or before January 29, 2025, and prohibits transactions involving individuals or entities from Russia, China, Iran, North Korea, and Cuba. These restrictions ensure cash flow is exclusively handled by the US and reconstruction efforts remain limited to US firms.
GL52 marks the most significant easing of Venezuela-related sanctions in years, moving beyond trade to allow full-scale restoration of the country’s energy sector. It builds on measures enacted since the removal of former Venezuelan President Nicolás Maduro in January. This includes EO 14373, which declared a national emergency and established the “Foreign Government Deposit Funds” to manage Venezuelan oil revenue in accounts held by the US Treasury. OFAC has also issued several related licenses: authorizing six major US energy companies to engage in Venezuela-origin oil transactions; expanding channels for contracts related to new Venezuelan oil, gas, petrochemical, and electricity operations; and permitting the export of US-origin goods to Venezuela, including diluents and technology for oil and gas exploration.
For Venezuela, the license could provide a significant economic boost. Since Maduro’s ousting, the country has ramped up oil exports close to peak capacity, and President Trump has called for $100 billion in investment from energy companies to revitalize Venezuela’s oil industry. However, investors remained deterred by the country’s weak legal structures and poor governance. Decades of corruption, mismanagement, and US sanctions have left the country with outdated infrastructure and chronic underinvestment, keeping its oil production far below potential. GL52 may encourage cautious investors to help rebuild the sector’s infrastructure and commercial frameworks.
While this measure reflects a gradual recalibration of US sanctions policy toward Venezuela’s energy sector, it is more immediately driven by the Trump administration’s concerns about soaring energy market pressures. Attacks on critical energy infrastructure in the Middle East and the closure of the Strait of Hormuz have caused oil prices to skyrocket, with Brent crude spiking to $119 per barrel on Thursday. Governments are being pushed to make hard choices, including imposing fuel export bans and price caps, relaxing refining standards, and even curbing demand through work-from-home orders. To stabilize oil prices, the International Energy Agency agreed to release 400 million barrels from its emergency reserves, marking its largest-ever stock release. Yet as the conflict enters its fourth week with little change, Iran’s warning earlier this month that prices could spiral to $200 per barrel—which could constitute the highest-ever benchmark price per barrel for crude, adjusting for inflation—appears less far-fetched.
In the span of three weeks, Washington has issued several related measures to stabilize global oil supply. These include a 30-day waiver issued on March 5 allowing India to buy Russian oil already at sea; a broader 30-day waiver a week later permitting all countries to purchase Russian oil already at sea—bar Iran, North Korea, Cuba, and covered regions of Ukraine; and a 60-day waiver of the Jones Act on March 18, allowing foreign vessels to move goods between US ports to boost shipping capacity and lower oil transport costs. Moreover, OFAC on Friday issued a 30-day sanctions waiver for the purchase of Iranian oil currently at sea, marking the third sanctions waiver by the US on oil purchases from a rival state since the conflict began. Taken together, these moves signal Washington’s priorities: first preventing oil price shocks and inflation, then maintaining baseline geopolitical pressure on rival states. However, these waivers could also complicate efforts to clamp down on shadow fleets and deprive Russia and Iran of oil revenue. If the Strait of Hormuz remains blocked and prices keep rising, reliance on Russian, Iranian, and Venezuelan oil may may persist, providing a lifeline to the global economy but possibly undermining long-term geopolitical pressure strategies.
US Developments
OFAC Authorizes Sale of Iranian Oil at Sea
On March 20, 2026, OFAC issued a new general license (GL) U, “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026.” GL U permits transactions otherwise prohibited under a number of US sanctions programs, including the Iranian Transactions and Sanctions Regulations (ITSR), that are ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Iranian origin loaded onto any vessel, including certain blocked vessels, on or before 12:01 a.m. Eastern Daylight Time (EDT), March 20, 2026. The authorization under GL U extends until April 19, 2026.
Notably, GL U explicitly authorizes transactions that involve the importation into the United States of crude oil and petroleum products of Iranian oil, where such importation is ordinarily incident and necessary to the sale, delivery, or offloading of such crude oil or petroleum products authorized by this general license.
GL U largely mirrors Russia-related GL 134 that OFAC issued on March 12, 2026, authorizing similar transactions for Russian-origin oil (though that GL does not explicitly authorize importation into the United States). We discussed GL 134 in more detail in our prior Sanctions Update from March 16, 2026. Both GL U and GL 134 are intended to stabilize energy markets after the conflict with Iran has caused significant disruptions in the flow of oil, resulting in energy rationing around the globe. During an interview with Fox News on March 19, 2026, Secretary of the Treasury Scott Bessent noted that the sanctions relief would increase the physical supply of oil to offset what is currently prevented from transiting through the Strait of Hormuz as a result of the conflict in Iran.
GL U does not authorize any transaction involving a person in or organized under the laws of North Korea, Cuba, the Crimea, Donetsk, and Luhansk regions of Ukraine, or a transaction involving any entity that it owned or controlled by or in a joint venture with any such person. On March 19, 2026, OFAC amended GL 134 to include a similar provision. The new GL 134A includes the same restriction with the addition of persons in or organized under the laws of Iran.
OFAC Designates Hizballah Money Laundering Network
On March 20, 2026, OFAC designated a network of 16 individuals and entities allegedly led by Hizballah financier Alaa Hassan Hamieh in efforts to launder and raise funds for Hizballah’s finance team. Treasury said that the sanctioned individuals and entities, which are located in Lebanon, Syria, Poland, Slovenia, Qatar, and Canada, are estimated to have collectively enabled diversion of over $100 million to Hizballah, a Specially Designated Global Terrorist (SDGT) and Foreign Terrorist Organization (FTO).
OFAC’s designations follow similarly targeted actions against fundraisers and enablers of Iranian terrorist proxies on March 12 and February 10, 2026.
Treasury Removes Numerous Persons from SDN List
On March 18, 2026, OFAC removed the following Russian, Turkish, and Emirati individuals and entities from the SDN List that were previously sanctioned pursuant to EO 14024:
- Evgeniya Tyurikova, who was previously sanctioned on February 24, 2023, for allegedly being a senior official at US-designated Sberbank;
- Boris Vorontsov, who was previously sanctioned on November 2, 2023, for allegedly being an official at a Russian state-owned corporation;
- Berk Turken and two of his Türkiye-based firms, Turken Digital and BSB Group, which were previously sanctioned on November 2, 2023, for allegedly enabling Russian intelligence services to procure technology for sanctioned entities, including through transactions with US-designated TBS and Andrey Vladimirovich Timoshin; and
- Futuris FZE, which was previously sanctioned on December 12, 2023, for allegedly shipping technologies to Russia, including fuses, metal cutting equipment, and electrical equipment, and for having been used by US-designated AK Microtech to circumvent sanctions and purchase microelectronics equipment on its behalf.
On March 20, 2026, OFAC removed the following persons and entities from the SDN List that were previously sanctioned under either EO 14024 or the Foreign Narcotics Kingpin Sanctions Regulations (“SDNTK”), codified at 31 C.F.R. Part 598.
- Imre Laszlocki, who was previously sanctioned on April 12, 2023, for allegedly being a ranking official on the management board of US-designated IIB Capital;
- Gilad Piflaks, who was previously sanctioned on February 1, 2023, for allegedly being part of the network of US-designated Igor Zimenkov and the child of US-designated Maks Piflaks;
- Yurii Korzhavin and Lidiya Korzhavina, who were previously sanctioned on May 1, 2024, for allegedly being shareholders of US-designated Elfor TL;
- Reliable Freight Services FZCO, which was previously sanctioned on December 12, 2023, for allegedly having shipped items such as x-ray systems, batteries, and aircraft parts and components to Russia; and
- Cesar Gastelum Serrano and his brothers, Alfred Gastelum Serrano and Guadalupe Candelario Gastelum Serrano, who were previously designated on December 23, 2014, for their roles in allegedly trafficking cocaine for the Sinaloa Cartel, an SDGT and FTO.
Treasury did not provide a comment on why these persons and entities were removed from the SDN List. For the Russia-related de-listings, these follow similarly focused actions taken by OFAC on March 13, March 6, and February 27, 2026. Although the recent de-listings remove only a small minority of SDNs sanctioned under EO 14024, these recent actions suggest that OFAC has adopted a faster pace of removals for certain sanctioned persons.
Brokerage Firm Settles with OFAC for Apparent Violations of Multiple Sanctions Programs
On March 17, 2026, OFAC announced that a US-based brokerage firm that operates online securities trading platforms, TradeStation Securities, Inc. (“TradeStation”), had entered into a settlement agreement with OFAC for $1,110,661 for their potential civil liability for 481 apparent violations of multiple sanctions programs, including those related to Iran, Syria, and Russia. OFAC said that TradeStation’s apparent violations were voluntarily self-disclosed and non-egregious.
According to OFAC, from June 21, 2021, to June 15, 2022, TradeStation provided investment services to customers in Iran, Syria, and the Crimea region of Ukraine (“Crimea”) due to a series of compliance control failures that allowed those customers to execute securities-related transactions. Specifically, TradeStation failed to consistently employ effective geo-blocking technology to deny users in sanctioned jurisdictions access to TradeStation’s systems.
OFAC said that this case highlights the importance for financial institutions and other firms to deploy testing mechanisms to ensure that compliance tools are adequately implemented and functioning as intended. OFAC further said that even the “most well-designed” sanctions compliance programs can be rendered “wholly ineffectual” by human and technical error, and that broker-dealers, specifically, who use real-time order placement and trade execution platforms, should consider “appropriate investments” to ensure modernization of their compliance solutions.
UK Developments
OFSI Issues New General Licence Relating to Kazakh Oil
OFSI has issued General Licence INT/2026/9247168 (GL), which allows persons required to comply with UK sanctions, PJSC Transneft and its subsidiaries to engage in any activity in relation to the supply, purchase, transportation or delivery of crude oil within commodity code 2709 that originated in Kazakhstan, provided that the oil is not owned by a person connected with Russia and is only being loaded in, departing from, or transiting through Russia. Relevant UK financial institutions are also authorised to process payments in accordance with such transactions. Any persons intending to use the GL should review and comply with its limitations and usage requirements.
EU Developments
EU Council Updates Sanctions Listing Targeting Actions Undermining the Territorial Integrity, Sovereignty, and Independence of Ukraine
The EU Council announced new listings regarding the sanctions framework in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine. Nine individuals linked to the Bucha massacre during February and March 2022 were added to the sanctions list. The newly sanctioned individuals include high-ranking Russian military commanders, such as Colonel General Aleksandr Chayko, who was the lead commander in Ukraine when Russian troops entered Bucha.
The EU sanctions regime currently applies to approximately 2,600 persons and entities targeted in response to Russia’s ongoing aggression against Ukraine. The restrictive measures include asset freezes, travel bans, and prohibitions on making funds or economic resources available to the listed individuals and entities.
EU Council Adds Four Individuals to Sanctions List Targeting Russia’s Hybrid Threats
The EU Council adopted restrictive measures against four additional individuals responsible for Russia’s continued hybrid activities, in particular Foreign Information Manipulation and Interference (FIMI) targeting the EU and its Member States and partners. Among those sanctioned are Russian propagandists and media figures who have played a key role in propagating disinformation aimed at justifying Russia’s war of aggression against Ukraine.
With this update, EU sanctions in response to Russia’s destabilizing actions now apply to a total of 69 individuals and 17 entities.
EU Council Amends Sanctions Listing Targeting Cyber-attacks against the EU and its Member States
The EU Council designated three entities and two individuals under its horizontal sanctions framework addressing cyber-attacks. Established in 2019 following the Council’s conclusions on the framework for a joint diplomatic response to malicious cyber activities (the so-called Cyber Diplomacy Toolbox), the sanctions framework provides for targeted restrictive measures to deter and respond to cyber-attacks that pose an external threat to the European Union or its Member States.
The newly listed entities include two Chinese companies involved in large-scale hacking campaigns targeting EU infrastructure and devices, as well as an Iranian company responsible for data breaches, disinformation operations during the 2024 Paris Olympics, and the compromise of communications services affecting EU citizens. With these additions, the sanctions framework targeting cyber-attacks now extends to a total of 19 individuals and 7 entities.
EU Council Sanctions 19 Iranian Officials and Entities Responsible for Serious Human Rights Violations
On March 16, the EU Council adopted restrictive measures against an additional 16 individuals and three entities responsible for serious human rights violations in Iran. This move follows High Representative of the EU Kaja Kallas’ announcement of updated sanctions against Iran, as reported in our March 16 Sanctions Update.
Among the new listings are Iran’s Deputy Minister of the Interior for Security and Law Enforcement Affairs, and various commanders of local branches of the Islamic Revolutionary Guard Corps (IRGC) directly involved in the violent repression of the street protests that began in December 2025. In addition, the EU Council has listed members of the judiciary who participated in prosecutions against civil and social activists, journalists, and political activists critical of the Islamic Republic. The listings also include the head of the Organization for Prisons and Security and Educational Measures of the Islamic Republic of Iran, under whose tenure serious human rights violations have been documented throughout Iranian prisons.
Restrictive measures under the EU sanctions regime for serious human rights abuses and violations in Iran now apply to a total of 263 individuals and 53 entities.
Asia-Pacific Developments
Beijing Signals Rubio Sanctions Unlikely to Obstruct Official Diplomatic Travel
Chinese authorities confirmed that Beijing is in communication with Washington regarding a potential US‑China leaders’ summit, while indicating that China’s existing sanctions on US Secretary of State Marco Rubio may not impede his entry into China should he accompany President Donald Trump. Speaking at a regular press briefing, a Chinese Foreign Ministry spokesperson stated that the sanctions imposed on Rubio in 2020 were linked to his statements and actions during his tenure as a US senator, suggesting they would not necessarily apply in the context of official diplomatic travel. The comments followed US media reports that President Trump had raised the possibility of delaying a planned visit to China amid broader geopolitical discussions, including maritime security in the Strait of Hormuz, with both sides confirming ongoing diplomatic engagement ahead of the proposed summit.
Asian Russian Fuel Oil Imports Rise Following Temporary US Sanctions Waiver
Asian imports of Russian fuel oil are set to reach record levels in March 2026, following a temporary easing of US sanctions that allows the sale of Russian crude oil and petroleum products stranded at sea prior to March 12, according to shipping data cited by market analysts. More than three million tonnes of Russian fuel oil are expected to arrive in Asia this month, with Southeast Asia and China identified as the primary destinations, as buyers seek alternative supplies amid disruptions to Middle Eastern energy flows through the Strait of Hormuz. Against this backdrop, South Korea has also indicated it is discussing with domestic companies the possibility of resuming imports of Russian crude oil, citing energy security concerns and referring to recent adjustments in sanctions enforcement, after having halted such imports in December 2022 following Russia’s invasion of Ukraine.
Indian Refiners Assess Iranian Crude Access Under Temporary US Sanctions Waiver
Indian refiners are considering a resumption of Iranian crude oil purchases following the issuance of a temporary US sanctions waiver allowing the sale of Iranian oil already at sea, according to market sources. The 30‑day authorization applies to cargoes loaded on or before March 20 and discharged by April 19, and represents the third such waiver since the onset of the US‑Iran conflict. Refining companies in India have indicated that any purchases would be subject to government guidance and clarity on payment and compliance mechanisms, while refiners elsewhere in Asia are also assessing whether Iranian supplies can be accessed under the limited sanctions relief. The potential return of Iranian oil follows similar short‑term adjustments to sanctions enforcement affecting Russian energy flows, as Asian buyers seek to manage supply disruptions linked to instability in West Asia and constraints on shipping through the Strait of Hormuz.
