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 Sanctions the Rwandan Defence Force and Senior Officials, Exerting Pressure to Preserve Viability of Washington Accords
On March 2, 2026, the US government imposed sanctions on the Rwandan Defence Force (RDF) and four senior RDF officers for their direct operational support to the rebel group M23 and affiliates in eastern Democratic Republic of the Congo (DRC). The US cited actions undermining the Washington Accords for Peace and Prosperity, signed on December 4, 2025, and peace and security in eastern DRC, and called for the RDF’s immediate withdrawal from the eastern DRC. These sanctions take place against the backdrop of ceasefire negotiations and stepped-up US efforts to secure access to critical minerals in the eastern DRC.
The RDF was designated under Executive Order (E.O.) 13413, as amended, for being responsible for or complicit in, or having engaged in, directly or indirectly, actions or policies that threaten the peace, security, or stability of the DRC; and for having materially assisted, sponsored, or provided financial, material, logistical, or technological support for, or goods or services in support of M23. RDF Army Chief of Staff Vincent Nyakarundi, RDF Commander of the 5thInfantry Division Major General Ruki Karusisi, RDF Chief of Defence Staff Mubarakh Muganga, and RDF Special Operations Force Commander Stanislas Gashugi were designated for being leaders of the RDF.
The conflict is complex, but with some signs of potential stabilization. Following the Washington Accords, which were signed between the US and the DRC and Rwanda, the Congolese government and AFC/M23 signed a document on February 2 setting out the terms of reference for a ceasefire monitoring and verification mechanism under the Doha Framework Agreement signed in November 2025. M23 has adhered to its agreement to withdraw from Uvira, a strategic city located along the DRC-Burundi border in South Kivu (an agreement reached after intensive diplomacy when the M23’s assault on the city threatened to unravel the Washington Accords days after its signing). This enabled the Kavimvira-Gatumba border crossing between Burundi and the DRC, key for cross-border trade, to reopen on February 26.
The decision by the US to sanction the RDF is a serious escalation but not completely unexpected. US officials have been warning that Washington was considering new sanctions as fighting intensified in January and February. While no longer occupying Uvira, M23 is extending its encirclement of the city and its threat to the Burundi border. M23 and allies are also making advances in North Kivu Province towards the DRC interior. M23, despite entering into negotiations, has not abandoned its goal of seizing control over the entire DRC, not just the eastern region, to protect the interests of the ethnic Tutsi population.
The US has its own agenda in seeing stabilization in the Great Lakes region, specifically in eastern DRC. As part of the Washington Accords, the US signed a Strategic Partnership Agreement with Kinshasa in December 2025 to secure long-term access to critical minerals like cobalt, copper, and lithium, reducing reliance on Chinese supply chains. Regional instability creates obstacles to investment and development of these mineral deposits. Some of these deposits are located in M23 controlled areas, such as Rubaya coltan mine, rich with tantalum deposits, used in jet engines, missile components and electronic components.
Days before imposing US sanctions, Washington and Kinshasa signed a memorandum of understanding for an expanded security partnership under the Washington Accords, to include increasing intelligence sharing, implementing training programs, and conducting joint military exercises in the coming months. This agreement is a clear indicator that the US is doubling down to protect its shared interests with the DRC.
Rwanda has dismissed the sanctions as unjust and biased, targeting only one side of the conflict. The sanctions, however, present a serious challenge to Rwanda, as they block all property and interests in property of the sanctioned entity – in this case, Rwanda’s entire army, rather than just specific individuals. The sanctions prohibit US persons from making any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person. In any case, US security cooperation with Rwanda, including its Status of Force Agreement, may wind down or cease.
The EU provides financial support to the RDF through the bloc’s European Peace Facility to pay for the Rwanda Defence Force’s mission in Mozambique. Last March, the EU sanctioned several M23 leaders and Rwandan army officials, as well as the head of Rwanda’s mines, petroleum and gas board, and a gold company suspected of being involved in smuggling minerals out of the DRC. Brussels will be caught between policy interests of protecting European business interests in Mozambique and policy alignment with Washington on stabilizing the Great Lakes region. The sanctions will also present compliance risks for businesses operating in in Rwanda and East Africa. OFAC has issued a 30-day global license for a wind down period for any transaction involving the RDF and entities directly or indirectly owned by the entity.
US Developments
US Lifts Sanctions on Malian Officials
On February 27, 2026, OFAC announced that it was lifting sanctions on three senior Malian officials, namely Sadio Camara, Mali’s Minister of Defense; Alou Boi Diarra, Mali’s Chief of Staff of the Air Force; and Adama Bagayoko, Mali’s Air Force Deputy Chief of Staff. All three were previously sanctioned by OFAC on July 24, 2023, for facilitating the deployment and expansion of the Russian Private Military Company Wagner’s (the “Wagner Group”) activities in Mali.
Wagner Group announced in early June 2025 that it was withdrawing from Mali. Since then, the US has been on a path of reengagement with Mali’s ruling junta. Much of this has come in the form of intelligence sharing, which the US has used to help the junta repel advances made by the Al-Qaeda-aligned Jama’at Nusrat al-Islam wal-Muslimin. More recently, US officials have traveled to Mali to chart a “new course” in the two countries’ relationship that moves past previous “policy missteps.”
Although the sanctions relief by the Trump administration may reflect an improving relationship between the US and Mali, the extent of future cooperation remains unclear. The Mali junta’s attempt to consolidate power and crackdown on public expression may ultimately limit the level of cooperation between the junta and the Trump administration. The junta also continues to host the Russian paramilitary group Africa Corps, which, among other “successors” of the Wagner Group, some Members of Congress have called to sanction through a recent bill, the HARM Act 2.0 (H.R. 7415).
OFAC Sanctions Rwandan Officials for Violations of the Washington Accords
On March 2, 2026, OFAC imposed sanctions on the Rwanda Defence Force (“RDF”) and four of its senior officials. According to OFAC, the RDF is actively supporting, training, and fighting alongside the March 23 Movement (“M23”), an armed group that operates mostly in the eastern Democratic Republic of the Congo (“DRC”). This support, OFAC alleges, continued as M23 seized territory in the DRC, including provincial capitals Goma and Bukavu.
OFAC alleges this support continued as M23 captured another important city, Uvira, shortly after DRC President Felix Tshisekedi and Rwandan President Paul Kagame signed the Joint Declaration on the Washington Accords for Peace and Prosperity (the “Washington Accords”) on December 4, 2025. The Washington Accords, which are one of the hallmark “peace deals” brokered and touted by the Trump administration, are aimed at facilitating peace between the DRC and Rwanda, and includes commitments to wind down DRC support for the Democratic Forces for the Liberation of Rwanda (“FDLR”) and Rwandan support for M23.
The sanctions were welcomed by Members of Congress, including the Senate Foreign Relations Chair, Sen. Jim Risch (R-ID). However, they also come shortly after reports indicate that other Members of Congress, namely Sen. Lindsey Graham (R-SC), previously requested, on behalf of President Kagame, that the White House shelve its plans to sanction senior Rwandan and M23 officials. The White House reportedly heeded those requests until now.
OFAC Pauses Sanctions on German Affiliates of Rosneft Indefinitely
On March 5, 2026, OFAC issued an amended, Russia-related general license (GL) 129A, “Authorizing Transactions Involving Rosneft Deutschland GmbH and RN Refining & Marketing GmbH.” GL 129 authorized certain transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”) involving RN Refining & Marketing GmbH (“RN Refining & Marketing”), Rosneft Deutschland GmbH (“RN Germany”), or any entity in which RN Refining & Marketing or RN Germany owned, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. GL 129A removes the expiration date in GL 129, which was originally set for 12:01 a.m. EST on April 29, 2026. By not setting a new expiration date, GL 129A remains in force indefinitely, until OFAC either amends GL 129A or rescinds the license.
Treasury Issues New Venezuela General License and FAQs
On March 6, 2026, OFAC issued Venezuelan-related GL 51, “Authorizing Certain Activities Involving Venezuelan-Origin Gold.” GL 51 authorizes certain transactions prohibited by the Venezuela Sanctions Regulations, including those involving the Government of Venezuela, 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”), that are 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. Like similar GLs for the oil and petrochemical industries, any contract for such transactions must be governed by US law and dispute resolution must occur in the United States, and any monetary payment must be made into the Foreign Government Deposit Funds.
On March 4, 2026, OFAC published six new Venezuela-related FAQs: 1239-1244. The new FAQs clarify what activities are authorized under Venezuela-related GLs 48, 49, and 50A, definitions of terms under GL 47, and information on how to make authorized payments to the Foreign Government Deposit Funds, as specified in Executive Order (EO) 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People," can be found, among other things. On March 5, OFAC published FAQ 1238 concerning the resale of Venezuelan-origin oil to Cuba.
OFAC Issues New General License Authorizing the Delivery and Sale of Certain Russian Oil and Petroleum Products to India for 30 Days
On March 5, 2026, OFAC issued Russia-related GL 133, “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 5, 2026 to India.” The new GL authorizes certain transactions otherwise prohibited by numerous sanctions programs that are ordinarily incident and necessary to the sale, delivery, or offloading of crude oil or petroleum products of Russian origin loaded on any vessel, including vessels blocked under the covered sanctions authorities, on or before 12:01 a.m. Eastern Standard Time, March 5, 2026. Such transactions are authorized through 12:01 a.m. Eastern Daylight Time, April 4, 2026, provided that the delivery or offloading of such crude oil or petroleum products occurs at a port in India; and the purchaser of such crude oil or petroleum products is an entity organized under the laws of India.
In announcing the new GL, Secretary of the Treasury Scott Bessent said that OFAC is issuing the temporary 30-day waiver to allow Indian refiners to purchase Russian oil “[t]o enable oil to keep flowing to the global market” at a time when Iran is “attempt[ing] to take global energy hostage.” Secretary Bessent further said that “[t]his deliberately short-term measure will not provide significant financial benefit to the Russian government as it only authorizes transactions involving oil already stranded at sea” and that he anticipates India will “ramp up purchases of US oil.”
Given Secretary Bessent’s statement, it is possible that the Trump administration would either extend this GL or issue similar GLs in the future depending on the impact that the conflict with Iran has on the global energy market in the coming weeks and months.
OFAC Removes UAE-based Freight and Logistics Company from SDN List
On March 6, 2026, OFAC published the removal of Globe Trekkers LLC from the SDN List. Globe Trekkers is a freight and logistics company based in the UAE. OFAC designated Globe Trekkers on November 2, 2023 pursuant to EO 14024 for allegedly shipping high-priority goods, including processing units, to Russia. OFAC did not issue a statement regarding the removal.
UK Developments
House of Commons Library Publishes Overview of Allied Russia Sanctions
The House of Commons Library has published a research briefing providing an overview of UK, EU and US sanctions imposed on Russia since its full scale invasion of Ukraine in February 2022. The briefing notes that the extensive sanctions regimes adopted by the UK, EU, US and partners remain in place, but highlights growing commentary around potential divergence in approach, particularly under the current US administration. While the Trump administration has not lifted or relaxed core Russia sanctions, it did not join the UK, EU or G7 in introducing new Russia designations during much of 2025 and did not support the July 2025 reduction of the Oil Price Cap. The US has instead signalled a willingness to deploy secondary tariffs against countries continuing to purchase Russian oil, with India subject to additional measures. The briefing contrasts this with continued tightening by the UK and EU throughout 2025, including further measures targeting Russia’s defence, financial and energy sectors, sanctions evasion networks and the shadow fleet, as well as reductions to the Oil Price Cap. It also refers to the European Commission’s roadmap to end EU reliance on Russian oil, gas and nuclear energy by 2027. The paper notes that the UK and EU have used proceeds from immobilised Russian state assets to support Ukraine, while debate over the seizure of Russian sovereign assets continues. According to UK authorities, £28.7 billion in Russia-linked assets have been frozen domestically since 2022, contributing to wider allied estimates that sanctions have denied Russia access to at least $450 billion.
UK Issues Updated Guidance on Belarus Trade and Transport Sanctions
The UK Government has published updated statutory guidance relating to the UK’s Belarus sanctions regime, including new resources designed to assist businesses in navigating trade and transport restrictions. The updated guidance introduces two new “look up” tools that outline relevant licensing considerations and exceptions applicable to the trade and transport prohibitions under the Belarus sanctions framework. The new tools are intended to help users more easily identify whether specific activities may be permitted under available exceptions or licensing grounds. The updates form part of the UK Government’s broader effort to improve the accessibility and usability of sanctions guidance for industry, following recommendations from the cross-government sanctions review.
OFSI Investigates First Potential Breaches of UK Cyber Sanctions Regime
OFSI is reportedly investigating up to five potential breaches of the UK’s cyber sanctions regime, marking the first known enforcement activity under the framework since it was introduced more than five years ago. The investigations, revealed through a Freedom of Information request, signal a shift from primarily deterrence-based measures to active enforcement of the UK’s cyber related sanctions framework. All of the suspected breaches reportedly involve financial services firms, highlighting the sector’s exposure to cyber-related sanctions risks. The UK’s Cyber (Sanctions) (EU Exit) Regulations 2020 enable the UK Government to designate individuals and entities involved in malicious cyber activity and apply across the UK as well as to UK persons overseas.
To date, no confirmed breaches have been publicly disclosed. Non-compliance with the cyber sanctions regime can result in significant penalties, including civil monetary penalties of up to £1 million or 50 percent of the value of the breach, as well as potential criminal liability carrying unlimited fines and prison sentences of up to seven years. The reported investigations therefore serve as a reminder for firms to review their compliance frameworks, including sanctions screening processes, enhanced due diligence for potential cyber threat actors, internal reporting procedures, and risk assessments relating to ransomware payments or complex payment arrangements.
UK Parliament Scrutinises Effectiveness of UK Trade Sanctions Regime
The UK Government’s House of Commons’ Business and Trade Sub-Committee has held an oral evidence session examining the effectiveness of the UK’s trade sanctions regime, particularly those targeting Russia following its invasion of Ukraine. Witnesses included the Minister of State for Trade, officials from the Department for Business and Trade, the Foreign, Commonwealth and Development Office, and HMRC. Officials highlighted that UK sanctions have significantly reduced direct trade with Russia, with approximately 99.6% of Russian imports to the UK reportedly halted since 2022. However, the session focused heavily on sanctions circumvention risks, including diversion of controlled goods through third countries, Russian oil being refined abroad and re-imported as derivatives, and the use of “shadow fleet” shipping networks. The government confirmed that further legislative measures are being prepared, including sanctions end-use controls that would require licences for exports where there is a risk that goods could ultimately be diverted to Russia. Authorities also described ongoing efforts to engage with industry, monitor supply chains, and target jurisdictions where diversion risks are highest.
The session also examined enforcement coordination between the Office of Trade Sanctions Implementation (OTSI), HMRC and OFSI. OTSI reported receiving 185 potential breach reports, of which five cases are nearing conclusion, 117 have been closed and 57 have been referred to HMRC for further investigation. HMRC confirmed that it currently has 21 live criminal investigations relating to sanctions and export control offences. Officials also acknowledged concerns raised by MPs regarding the transparency of enforcement outcomes, particularly in relation to compound settlements, and indicated that options are being explored to increase transparency, potentially including legislative change. Overall, the session underscored both the scale of the UK sanctions regime against Russia and the ongoing challenges associated with enforcement, evasion risks and international coordination.
UK Government Signals Tighter Controls on Diversion of Dual-Use Goods
The UK Government has confirmed that it is considering further regulatory measures to strengthen controls on exports of dual-use goods amid ongoing concerns about diversion to Russia through third countries. In a written parliamentary response, Trade Minister Chris Bryant addressed a question from Labour MP Mark Sewards regarding steps being taken to enhance due diligence obligations for exporters, particularly in relation to potential diversion routes through Hong Kong. The Minister noted that since March 2022 the UK has imposed extensive trade sanctions designed to prevent Russia from acquiring dual-use goods and other high-risk technologies used in its military operations. These measures include a comprehensive prohibition on the export of dual-use items, as well as products identified on the battlefield or considered critical to Russia’s military industrial complex. According to the UK Government, these restrictions have forced Russia to rely increasingly on complex third country procurement routes to circumvent sanctions. In response, the UK Government has indicated that it continues to provide guidance and conduct outreach with UK exporters on appropriate due diligence practices when exporting sensitive goods. In addition, the Department for Business and Trade plans to introduce secondary legislation establishing new sanctions end-use controls. These powers would require exporters to obtain a licence where specific exports are identified as posing a high risk of diversion to sanctioned destinations, strengthening the UK’s ability to address indirect supply routes used to evade trade sanctions.
EU Developments
EU Council Renews Sanctions Regime Targeting the Misappropriation of Ukrainian State Funds
The EU Council has renewed the restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine for another year, until March 7, 2027. The sanctions regime provides for the freezing of funds and economic resources of certain persons identified as responsible for the misappropriation of Ukrainian State funds and persons responsible for human rights violations, with a view to consolidating and supporting the rule of law and respect for human rights in Ukraine.
In addition, the EU Council updated the entries of three individuals in Annex I to Regulation (EU) 208/2014, two of whom were former Ukrainian government officials and one a businessman with close ties to the former government, to reflect developments in ongoing criminal proceedings concerning their alleged involvement in large scale misappropriation of state assets, evasion of justice and obstruction of investigative processes.
EU Council Updates Listing Under Sudan Sanctions Framework
The EU Council has amended the listing under the sanctions framework in view of the situation in Sudan, following a recent update at the UN level. Specifically, four commanders and leaders of the Rapid Support Forces (RSF) were added to Annex I of Decision 2014/450/CFSP, reflecting the designations adopted by the UN Security Council Sanctions Committee in February 2026.
The restrictive individuals include asset freezes, travel restrictions within the EU, and a prohibition on making funds, financial assets, or economic resources available to lister persons.
Asia-Pacific Developments
Sanctions Resistance is Emphasized in China’s 15th Five‑Year Plan
China’s 15th Five‑Year Plan highlights how foreign‑policy priorities—especially Beijing’s belief that the US seeks to restrain its rise—now shape domestic planning and drive efforts to harden the country against external sanctions. The plan emphasizes reducing strategic dependence on the US and its partners by strengthening industrial self‑reliance, securing supply chains, and accelerating technological independence. It calls for upgrading China’s national security system to counter foreign sanctions, interference, and long‑arm jurisdiction, including protecting critical sectors like food, energy, infrastructure, and strategic minerals. Military‑civil fusion is openly reaffirmed to integrate civilian innovation with defense capabilities, while limited steps toward renminbi internationalization are framed as a way to reduce exposure to US financial pressure. Alongside insulating China from Western leverage, the plan also aims to heighten foreign reliance on Chinese technologies and supply chains, enhancing Beijing’s geopolitical influence.
China Condemns UK’s New Sanctions on Chinese Firms
China sharply criticized the UK’s latest Russia‑related sanctions, asserting that the measures—imposed without UN authorization or grounding in international law—unfairly target Chinese companies and represent a pattern of politically driven unilateral pressure. According to the Ministry of Commerce, London has repeatedly added Chinese entities to its sanctions list, despite China’s strict adherence to export controls on dual‑use goods and its position that legitimate commercial activity between Chinese and Russian firms should not be obstructed. Beijing urged the UK to reverse these sanctions to preserve stable bilateral ties and warned it will take necessary steps to defend the lawful interests of its companies.
Cuba Expands Chinese‑Backed Solar Program to Counter Strain Under US Sanctions
Cuba has launched a nationwide rollout of 5,000 Chinese‑donated photovoltaic systems—each with a capacity of 2 kW—as part of a broader effort to soften the effects of the country’s prolonged energy crisis, which has been worsened by longstanding US sanctions and the US’ suspension of Venezuelan oil shipments post-Maduro ouster. Cuban authorities have already assigned 2,671 of these standalone solar units to essential municipal institutions such as clinics, elder‑care facilities, funeral homes, banks, and communication centers to ensure they can continue functioning during grid outages, while the remaining 2,329 systems are being installed in remote households that previously lacked electricity access. These off‑grid systems are intended not to fully cover energy consumption but to ensure critical services—like vaccine refrigeration and emergency care—remain uninterrupted during blackouts. Project leaders emphasized that the initiative aims to strengthen local autonomy and improve living conditions in isolated communities, complementing Cuba’s broader renewable‑energy push and other international assistance efforts.
Crypto’s Expanding Role in Sanctions Evasion Across the Asia‑Pacific
The Asia‑Pacific region has emerged as a key battleground in the global struggle over crypto‑enabled sanctions evasion, with digital assets increasingly shaping how states and illicit networks navigate financial restrictions. Analysts note that blockchain‑based transactions challenge traditional sanctions tools—such as dollar clearing and correspondent banking—because decentralized networks allow peer‑to‑peer value transfers beyond conventional chokepoints. Enforcement bodies have linked major cryptocurrency thefts and laundering schemes to state‑aligned actors in the region, most prominently North Korean cyber units, which have repeatedly raided exchanges and obscured stolen funds through layered transactions, mixing protocols, cross‑chain bridges, and liquidity pools. Meanwhile, Russia’s heightened reliance on digital assets following deeper Western sanctions has drawn attention to the role of crypto in facilitating cross‑border settlements when traditional banking access is restricted.
Southeast Asia’s mixed regulatory landscape further complicates enforcement: jurisdictions like Singapore and South Korea have implemented stronger licensing and compliance regimes, yet gaps in oversight elsewhere and the ease of moving assets across borders enable continued exploitation by sanctions‑evading actors. China, despite banning domestic crypto trading, has adopted a divergent model through its e‑CNY central bank digital currency, reflecting a wider geopolitical contest between state‑controlled digital finance and decentralized systems often used to circumvent sanctions. Although blockchains are transparent, the pseudonymous nature of wallets and the proliferation of DeFi tools—such as automated market makers, privacy‑enhancing technologies, and cross‑chain infrastructure—make attribution difficult and allow sanctioned entities to obscure their activity. As a result, governments across the region are increasingly coordinating on intelligence sharing and joint investigations, recognizing that effective sanctions enforcement now hinges on technical capability, regulatory harmonization, and cross‑border cooperation rather than domestic controls alone.
Australia Warns of Heightened Sanctions Risks in Funds Linked to Iran
Australia’s Department of Foreign Affairs and Trade has issued an advisory highlighting the elevated sanctions risks associated with incoming funds that originate from, or are connected to, Iran, noting that financial institutions may see increased transfers during periods of conflict, economic volatility, or tightened sanctions. The guidance explains that while capital outflows from Iran are not inherently unlawful, such transactions frequently involve red flags—including routing through intermediary jurisdictions like the UAE, Türkiye, and Malaysia, the use of layered or opaque fund flows, incomplete source‑of‑wealth documentation, and attempts to obscure Iranian ties through altered spellings or complex ownership structures. It also warns of patterns such as repeated sub‑threshold transfers, multiple remitters sending funds to a single beneficiary, and consolidation of fragmented inflows for property or business purchases, particularly where customers have links to Iran. The advisory further flags cryptocurrency‑related risks, including rapid off‑ramping of crypto into Australian bank accounts, and stresses that these behaviors may indicate attempts to circumvent Australian or UN‑mandated sanctions regimes targeting Iranian sectors and designated individuals.
