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 Lifts Sanctions on Belarusian Entities in Exchange for Release of Prisoners
On March 26, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) eased restrictions on several Belarus-linked firms, marking the latest sign of rapprochement in US-Belarus relations. OFAC issued Belarus General License 14 (GL 14), authorizing all transactions with the Belarusian Bank of Development and Reconstruction Belinvestbank Joint Stock Company. OFAC also rescinded Directive 1 under EO 14038, which prohibited transactions with the Ministry of Finance and the Development Bank of the Republic of Belarus. Lastly, OFAC removed multiple Belarusian entities from its Specially Designated Nationals List (SDN List), including potash companies Belaruskali, Belarusian Potash Company, and Agrorozkvit.
The issuance of GL 14 comes several days after US Special Envoy John Coale announced that sanctions relief would be granted in exchange for the release of political prisoners. On March 19, Minsk released 250 prisoners, including members of Belarusian human rights group Viasna and journalists who had criticized the government for its brutal crackdown on protests following the heavily disputed 2020 election. The release signifies continued efforts from the Trump administration to improve relations with Belarus and could be a prelude to additional sanctions relief in the future. However, it is unlikely that the thawing of US-Belarus relations will coax Minsk into distancing itself from Russia, a close partner whom Belarus President Aleksandr Lukashenko has grown increasingly reliant on to remain in power.
Belarus has long been isolated by US and European sanctions due to the government’s repression and imprisonment of dissidents protesting the falsification of the 2020 presidential election and its support of Russia’s war in Ukraine. The second Trump administration has sought rapprochement, gradually peeling back sanctions in exchange for the release of more prisoners, many of whom are considered political prisoners. In September 2025, OFAC issued GL 11, authorizing all transactions involving Belavia Belarusian Airlines and leading to the release of 52 prisoners. Two months later, OFAC issued GL 12, lifting sanctions targeting Lukashenko’s presidential aircraft. In December, OFAC issued GL 13, authorizing transactions with the three potash companies previously mentioned. Following GL 13, Belarus released 123 prisoners, including several prominent figures such as Nobel Peace Prize winner Ales Bialiatski and 2020 protest leader Maria Kalesnikava, an unexpected development given the potential political risks of freeing dissidents who were well-respected by the public.
The expanding scale of sanctions relief and the increased willingness from Minsk to release more prisoners, even at risk of emboldening the opposition, signifies a shift in US-Belarus relations. But the magnitude of that shift should not be overstated, as the apparent rapprochement occurs with Moscow’s permission. Belarus continues to allow Russian forces to use its territory as a logistics hub and staging ground for operations in Ukraine. Meanwhile, Lukashenko is dependent on Putin for political survival, especially in the aftermath of the 2020 election and protest movement. Despite strong ties to Moscow, the Trump administration aims to entice Belarus with reentry into global markets (albeit restrained, as EU sanctions remain in place) to reduce Russian influence. Furthermore, the rollback of sanctions on potash companies comes as fertilizer prices surge amid global supply chain disruptions. Large volumes of fertilizer inputs are transported through the Strait of Hormuz, and the Iran war has restricted American farmers’ access to fertilizers produced in the Gulf. However, it is unclear whether the removal of sanctions on Belarus will offset the impacts of the war on the affordability of fertilizer and availability of its inputs.
Should US-Belarus relations improve further, additional sanctions relief is expected. Coale stated the US’ goal is to free the remaining 900 prisoners by the end of the year, which would result in the removal of 80% of US sanctions. Lukashenko expressed openness to a “big deal” with the US, demonstrating a willingness to continue releasing prisoners. However, even a substantial rollback of sanctions is unlikely to meaningfully undermine Russian influence. The Belarusian economy remains deeply integrated with Russia’s energy and financial sectors, and Belarus relies heavily on Russia for security. Lukashenko’s dependence on Putin to prevent internal political opposition from threatening his regime subordinates Minsk to Moscow’s foreign policy agenda. Another consideration is the 20% of sanctions that would presumably remain if the Trump administration secures the release of all prisoners due to Belarus enabling Russia’s war efforts. If that were the case, it is highly unlikely that total sanctions relief will be offered unless Minsk ceases or substantially reduces its involvement in the conflict, an unacceptable proposition for both Lukashenko and his patrons in the Kremlin.
US Developments
OFAC Issues New General Licenses for Venezuela’s Minerals Sector
On March 27, 2026, OFAC issued two General Licenses (GLs) and amended a third GL to expand the general authorization to engage in transactions in Venezuela’s mineral sector beyond gold otherwise prohibited by the Venezuelan Sanctions Regulations (VSR).
- On March 6, 2026, OFAC issued GL 51, which generally authorized transactions, including those involving the Government of Venezuela (GoV), CVG Compania General de Mineria de Venezuela CA (Minerven), or any entity in which Minerven owns, directly or indirectly, a 50 percent or greater interest (collectively, “Minerven Entities”), ordinarily incident and necessary to the exportation, sale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin gold for importation into the United States, the refining of such gold in the United States, and the resale or exportation of such gold from the United States, by an established US entity. On March 27, OFAC issued amended GL 51A, which primarily expanded the scope of GL 51 to include all Venezuelan-origin minerals.
- Similarly, GL 54, “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela,” generally authorizes transactions that are ordinarily incident and necessary to the provision from the United States or by a US person of goods, technology, software, or services for the exploration, development, mining, extraction, processing, refining, or production of minerals, including gold, in Venezuela.
- OFAC also issued GL 55, “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Minerals Sector,” which generally authorizes transactions related to the negotiation of and entry into certain contingent contracts for new investment in the minerals sector of Venezuela, including the gold sector.
Like recent GLs related to Venezuela’s petroleum industry, the mineral sector GLs are also subject to various limitations and requirements, several of which (e.g., contracts must be governed by US law, monetary payments must generally be made to the Foreign Government Deposit Funds, transactions with persons located in Russia, North Korea, Iran, or Cuba are not authorized) mirror the restrictions in the petroleum sector GLs.
Senators Introduce Bill Sanctioning Hungarian Officials for Obstructing Assistance to Ukraine
On March 26, 2026, Sen. Jeanne Shaheen (D-NH), the Ranking Member of the Senate Foreign Relations Committee, as well as Sen. Thom Tillis (R-NC), introduced the Barring Leverage and Obstruction that Contributes to Kremlin Profits Undermining Transatlantic Interests and NATO Act (S. 4275) (the “BLOCK PUTIN Act”).
The BLOCK PUTIN Act would require the President to impose blocking sanctions and visa bans on senior officials of the Government of Hungary that, on or after the date of enactment, either:
- Direct, approve, or take steps to block, delay, or otherwise obstruct additional financial or security assistance to Ukraine through bilateral, European Union (EU), North Atlantic Treaty Organization (NATO), or other multilateral mechanisms; or
- Approve or continue to facilitate oil or natural gas imports from Russia.
The BLOCK PUTIN Act exempts senior officials of the Government of Hungary if the Government of Hungary has formally adopted and begun implementation of a public, time-bound plan to end Hungary’s dependence on imports of Russian oil and natural gas, that includes a binding commitment to achieve substantial diversification of oil and natural gas imports before 2028. In order to qualify for the exemption, the Government of Hungary must have also ceased, for a continuous period of not less than 180 days, any official action enumerated in (1).
The introduction of the BLOCK PUTIN Act comes as Hungary has reportedly threatened to cut off gas supplies to Ukraine until Russian oil deliveries resume through the Druzhba pipeline.
Treasury Removes More Persons from SDN List
On March 27, 2026, OFAC removed the following persons and entities from the SDN List:
- Andriy Portnov, the former Deputy Head of Ukrainian Presidential Administration under former President Yanukovych who was sanctioned on December 9, 2021, pursuant to EO 13818, for allegedly using his influence to buy access and decisions in Ukraine’s courts;
- Andriy Portnov Fund, which was also sanctioned on December 9, 2021, for being owned or controlled by Portnov;
- Vladimir Dmitriev, who was sanctioned on May 8, 2022, pursuant to EO 14024, for allegedly being a member of Gazprombank’s Board of Directors; and
- Frederic Pierre Villa, a Swiss-Italian citizen who was sanctioned on February 24, 2023, pursuant to EO 14024, for allegedly being on the Board of Directors of Stratton Investment Group LTD, which was itself designated for being owned by Taerio Limited, a United Arab Emirates (UAE)-based entity OFAC alleges was involved in covert procurement schemes for Russian intelligence services and the Russian military.
Treasury did not provide a comment on why these persons and entities were removed from the SDN List. These de-listings follow a number of other removals by OFAC recently on March 20, March 18, March 13, March 6, and February 27, 2026.
UK Developments
New Guidance Issued on the Use of Exceptions and Licences to Comply with UK Sanctions
Joint guidance has been issued by the Foreign, Commonwealth and Development Office, OFSI, OTSI and the Export Control Joint Unit on how to check if certain transactions, goods and services are exempt from UK sanctions measures, as well as how to use or apply for sanctions licences. The guidance provides an overview of exceptions to financial, trade and transport sanctions. Additionally, the guidance addresses the process for obtaining sanctions licences, including the potential for overlap between financial and trade sanctions giving rise to a need for more than one licence to engage in certain business activities.
UK Makes New Designations Under Global Human Rights Sanctions Regime
The UK government has made ten new designations under its global human rights sanctions regime. The new designations target four entities and six individuals involved in operating what is described as the largest fraud compound in Cambodia. The newly designated persons are now subject to asset freeze and making available sanctions and, in the case of the individuals targeted, a travel ban. The designations represent an effort by the UK to disrupt a fast-growing network of “scam centres” in Southeast Asia that target victims globally, using schemes ranging from fake investment pitches to fabricated romantic relationships.
UK Authorizes Military to Board Russian Shadow Fleet Tankers
The UK Prime Minister, Keir Starmer, has authorized the UK military to board and detain Russian shadow fleet vessels in British waters in an effort to disrupt the ability of these vessels to support the generation of revenue by Russia from fossil fuels contrary to UK sanctions. It has been reported that the UK may bring criminal proceedings against the owners, operators and crew of detained vessels for breaches of UK sanctions against Russia. The UK action is part of a broader escalation of efforts by other European countries to detain shadow fleet vessels.
OFSI Extends Bond Amendment and Restructuring General Licence
OFSI has extended the expiry date for General Licence INT/2023/2824812 (“GL”) until March 26, 2028. The GL authorizes non-designated issuers with bondholders who are designated persons under the UK’s Russia sanctions regime to give effect to the terms of any bond restructuring or amendment agreed between the issuer and its bondholders, provided no funds or economic resources are made available to the designated bondholder. The GL also authorizes UK persons to take any steps necessary to give effect to such a bond restructuring or amendment. Any persons intending to use the GL should review and comply with its limitations and usage requirements.
UK Makes New Designations Under ISIL (Da’esh) and Al-Qaida Sanctions Regime
The UK government has made two new designations under the ISIL (Da’esh) and Al-Qaida Sanctions Regime. The new designations target two individuals for their involvement in managing Islamic State’s revenue streams who were listed by the UN Security Council Sanctions Committee pursuant to Resolutions 1267 (1999), 1989 (2011) & 2253 (2015) on March 26, 2026.
Supreme Court Rules on Bank’s Obligation to Pay Under Letters of Credit Suspended by Russia Sanctions
The Supreme Court has dismissed appeals by Irish aircraft lessors concerning whether UK sanctions prohibited a bank from making payments to them under letters of credit (“LOCs”) issued as security for aircraft leases to Russian airlines. The Supreme Court’s judgment held that the bank was prohibited under Regulation 28(3)(c) of the Russia (Sanctions) (EU Exit) Regulations 2019 from making the payments until the appropriate sanctions licences were obtained. The bank also contended in a cross-appeal that if Regulation 28(3)(c) did not prohibit the payments, its reasonable belief that Regulation 28(3)(c) applied meant that Section 44 of the Sanctions and Anti-Money Laundering Act 2018 offered it protection from liability in civil proceedings. While the cross-appeal did not require determination, the issue was addressed because of its wider practical significance, with the Supreme Court holding that Section 44 provides protection against claims for pre-existing debts, interest and costs if a person has acted with the requisite reasonable belief. However, Section 44 does not prohibit civil proceedings, rather it provides a defence to such proceedings.
EU Developments
CJEU Judgment on the Interpretation of the “Leading Businesspersons” Criterion under Council Regulation (EU) 269/2014
The Court of Justice of the European Union (CJEU) delivered its judgment in the Joined Cases C-696/23 P Pumpyanskiy, C-704/23 P Khudaverdyan, C-711/23 P Rashnikov, C-35/24 P Mazepin and C-111/24 P Khan, following appeals brought by five Russian businesspersons against General Court judgments upholding EU restrictive measures adopted under Article 3(1)(g) of Council Regulation (EU) 269/2014. The (g) criterion of Article 3(1) provides for the freezing of funds and economic resources belonging to “leading businesspersons” involved in economic sectors providing a substantial source of revenue to the Government of Russia.
The Court clarified that the expression “providing a substantial source of revenue to the Government of Russia” must be interpreted as meaning that it is the economic sectors, rather than the leading businesspersons themselves, that must provide a substantial source of revenue to the Russian Government. Additionally, the Court determined that the “influence” of a leading businessperson must be assessed in light of the economic context in which that person operates, irrespective of any specific link to the Government of Russia.
The Court further held that the legality of a listing criterion serving as the basis for the imposition of restrictive measures may be affected only if that criterion is manifestly inappropriate in relation to the objective pursued. In the present cases, the Court found that there is an objective link between, on the one hand, leading businesspersons involved in sectors providing a substantial source of revenue to Russia and, on the other, the objective consisting in increasing the pressure on that country and the costs of its actions to undermine the territorial integrity, sovereignty and independence of Ukraine.
Lastly, regarding proportionality, the Court confirmed that it is sufficient to verify that the restrictive measures are not manifestly inappropriate for achieving the legitimate objective pursued and that they do not manifestly exceed what is necessary to achieve that objective. The Court found that those conditions were satisfied in the present cases and accordingly dismissed all the appeals.
Asia-Pacific Developments
China Rejects Leading AI Conference Over Sanctions-Based Restrictions
China’s main organization for science and technology professionals has announced it will disengage from a leading global artificial intelligence conference after organizers imposed rules barring submissions from institutions under US sanctions. The policy change by the body behind the Conference on Neural Information Processing Systems (NeurIPS), introduced to comply with US law, drew criticism in China, where the event is seen as a key venue for publishing AI research, sharing breakthroughs and competing for global talent. In response, the China Association for Science and Technology said it would halt funding for members to attend the conference, redirect support to domestic or other overseas forums, and stop treating accepted papers as qualifying outputs for its funding schemes, while still recognizing their academic value through domestic review.
Rail Reopening Accelerates Cross‑Border Trade and Sanctions Risks
The reopening of passenger rail service between North Korea and China after a six‑year hiatus has quickly reignited cross‑border commerce while raising concerns about renewed sanctions evasion. The route is now largely used by Chinese traders and businesspeople transporting samples of manufactured goods and construction materials to revive or expand ventures in North Korea, as ordinary North Korean citizens remain tightly restricted from travel. In the opposite direction, North Korean trading firms are reportedly using the trains to export agricultural products and other items into China, including goods banned under United Nations sanctions, taking advantage of relatively lax inspections. The rapid surge in activity highlights how the restored rail connection has become both a catalyst for bilateral trade and a channel for bypassing international restrictions.
China Continues to Dominate Iranian Oil Purchases
Despite a recent US decision to ease certain restrictions on Iranian oil exports, China continues to absorb the overwhelming majority of Iran’s crude shipments, underscoring the limited real‑world impact of the sanctions waiver. Roughly 90% of Iranian crude exports are still headed to China, with well over 100 million barrels already en route as of late March, even after Washington issued a general license allowing previously sanctioned oil cargoes loaded before March 20 to be sold more freely. US officials had argued the waiver would help release large volumes of Iranian oil into global markets and ease supply pressures, but industry data suggests China remains the dominant destination because legal, financial and compliance risks continue to deter buyers elsewhere. Restrictions in jurisdictions such as the EU and the UK, along with the legal status of Iran’s state oil sector, make broader trade impractical, meaning Beijing is likely to retain its central role in purchasing Iranian crude.
India Resumes Iranian LPG Imports After Sanctions Easing
India has purchased its first shipment of Iranian liquefied petroleum gas in several years following a temporary easing of US restrictions on Iran’s energy exports. The cargo, which had originally been headed toward China, was diverted to India amid severe domestic fuel shortages caused by disruptions to shipping routes through the Strait of Hormuz during the recent US–Israeli conflict with Iran. The tanker carrying the Iranian LPG is expected to dock at the western port of Mangalore, with the shipment to be divided among India’s three state‑run fuel retailers to help stabilize supplies of cooking gas nationwide. The deal reportedly involved payment in rupees through an intermediary trader, highlighting both India’s urgent need for alternative fuel sources and its cautious return to limited energy trade with Iran after halting purchases in 2019 under Western sanctions pressure.
