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 Delists Prominent Venezuelan Politician Amid Push for Diplomacy and Energy Investment Expansion
Last week, the US lifted sanctions on Jorge Rodriguez, a Venezuelan political power player and brother of interim President Delcy Rodriguez, amid Washington’s latest push for diplomacy and expansion of energy investment. On October 14th, the US Treasury Department’s Office of Foreign Assets Control (OFAC) removed Rodriguez from its Specially Designated Nationals and Blocked Persons (SDN) list, ending the associated asset freeze and obstacles for US persons attempting to deal with him. Rodriguez, the President of Venezuela’s National Assembly since 2021 and former vice president under Hugo Chavez, was initially designated in 2018. Alongside members of Nicolas Maduro’s inner circle, including Delcy Rodriguez and Maduro’s wife Cilia Flores, Jorge was designated pursuant to E.O. 13692 for his contribution to Venezuela’s democratic backsliding, human rights abuses and government corruption.
The designation removal coincided with the start of the third round of US-backed negotiations between the interim government and the Venezuelan opposition. The government delegation has been led by Jorge Rodriguez, while the opposition delegation has been represented by Dinorah Figuera, President of Venezuela’s 2015 National Assembly. Focuses of the first two rounds have included earthquake recovery, the return of frozen overseas funds, and the reform of the country’s Supreme Court, historically a bulwark of support for Maduro. The rounds have been followed by steps to ease political repression, including the release of some political prisoners and reforms to repressive laws.
Little information has thus far emerged about the current round, but the US said that delegations would focus on finalizing Supreme Court selection processes and developing participation guarantees for individuals and political parties in future elections. The ultimate stated goal of these negotiating rounds is indeed the establishment of credible elections, although the timeline for polls remains cloudy. At the UN General Assembly last month, President Rodriguez pledged that Venezuela would hold elections, but did not provide a timeline and over the summer, President Trump told reporters that Venezuela was “not really ready” for elections. Both President Trump and Rodriguez’s government have appeared to prioritize a gradual approach that preserves continuity. By contrast, prominent Venezuelan opposition figure Maria Corina Machado, who has the highest public approval of any Venezuelan political figure, but who the Trump administration has characterized as destabilizing, has called for elections to take place by July 2027. Machado is currently in Panama, and risks arrest if she returns; despite Venezuela’s recent reforms, exiled opposition leader Javier Oropeza was recently arrested upon return to the country, underscoring enduring political risks.
Even as movement on the political front has been stop-and-start, progress in the economic portfolio has been relatively rapid. Rodriguez has shepherded major reforms through the legislature as part of this effort, including the January 2026 reforms that permitted private and foreign investment in the state-dominated oil sector, and a similar law for the mining sector. In late August, the White House announced a joint venture with North American Blue Energy Partners (NABEP), which outlines up to $100 billion in potential investments to develop 17 oil fields containing approximately 65 billion barrels of proven reserves. Western oil majors have increasingly entered the market as well; Halliburton, for example, in late September signed a series of memoranda of understanding with Venezuelan entities for natural gas development and infrastructure, reentering the market for the first time since exiting in 2020 due to US sanctions risk. Washington has also made moves to support international development of Venezuela’s gold mining industry, which has long been dominated by criminal organization, including by pledging security assistance to new US and foreign entrants.
At the same time, sanctions easing on Venezuela is far from comprehensive: 2017 sanctions broadly remain in place, as do 2019 blocking sanctions that prevent dealings with the Venezuelan government. Most sanctions relief thus far has come in the form of General Licenses, which OFAC retains authority to revoke or modify at any time. Significant regulatory uncertainty remains.
Nonetheless, Rodriguez’s delisting signals ongoing US efforts to pursue stability in Venezuela amid further opening of Venezuela’s energy sector and progress towards an eventual, but not immediate, political transition. The removal of sanctions on Rodriguez underscores the continuity of Washington’s once unlikely partnership with Delcy Rodriguez and other members of Maduro’s inner circle. Rodriguez’s government has become the Trump administration’s partner of choice as Washington seeks to preserve stability, shepherd the opening of Venezuela’s economy to Western investment, and bring Caracas in political alignment with Washington as it pursues greater influence in Latin America. The delisting could be a vote of confidence in President Rodriguez’s government as political transition talks continue, as well as an effort to preserve the collaborative bilateral relationship as energy investment ramps up. Accelerating international investment in Venezuela’s economy presents immense opportunities for early movers, but carries significant regulatory and operational risks given the shifting political environment. Some analysts worry that an eventual democratically elected Venezuelan government may renege on oil deals with the US, which conflict with the 1999 constitution, and that the Trump administration may be incentivized to preserve a Rodriguez government.
US Developments
President Waives Sanctions and Tariffs Under the Sanctioning Russia Act
On October 16, President Donald Trump issued an Executive Order (“E.O.”) implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, while waiving the application of nearly all sanctions, restrictions, and tariffs provided for under the Act. President Trump certified to Congress that the waivers are in the national interest of the United States, as required by section 115 of the Act.
The E.O. nominally imposes a 500 percent tariff on goods from Russia and 100 percent tariffs on goods from certain major purchasers of Russian oil and natural gas and countries that facilitate Russian oil sanctions evasion. However, the E.O. simultaneously waives those tariffs, as well as the Act’s sanctions concerning Russian officials and supporters, financial institutions, state-owned entities, and restrictions on fund transfers, securities trading, investment in and exports by Russia’s energy sector, the purchase of sovereign debt, financial messaging services, and importation of uranium. The E.O. states that the waivers will remain in effect until the President or designated agency officials determine that further action is appropriate. The E.O. does not affect Russia-related sanctions imposed under preexisting Executive Orders.
The decision drew criticism from members of both parties. Republican Senators Darline Graham (R-SC), Thom Tillis (R-NC), and John Cornyn (R-TX) expressed opposition to the waivers, while Democratic Representative Don Beyer (D-VA) argued that the decision was inconsistent with the law’s purpose and called on Congress to limit the President’s waiver authority. The White House opposed earlier versions of the Act that lacked the broad waiver authority that was ultimately enacted. The President’s E.O. follows the Trump administration’s decision on October 9 to authorize the sale and import of Russian diesel fuel, which we covered in last week’s update.
Treasury Targets Iran-Linked Banks and Warns of Charity Abuse
On October 15, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned 16 individuals and 10 entities for allegedly enabling sanctions evasion and sustaining Iran’s military and proxy forces.
The designated parties included Iran-based banks Jazireh International Bank Company and Chabahar International Bank Overseas Company, which OFAC said operated offshore in free trade zones, as well as Iran-based exchange houses and individuals allegedly involved in foreign exchange operations.
Also among the designated parties was Iraq-based International Development Bank for Investment and Finance (“IDB”), which allegedly provided financial facilitation services and access to U.S. dollars for Iran. OFAC issued General License (“GL”) FF, authorizing transactions that are ordinarily incident and necessary to the wind-down of dealings with IDB and its affiliates through 12:01 a.m. Eastern Daylight Time, October 30, 2026.
Treasury’s action was taken pursuant to E.O. 13902, which targets certain sectors of the Iranian economy, including Iran’s financial and petroleum sectors.
In a separate action, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions about potential Iranian regime abuse of religious charity networks, including diversion of religious tithes or “khums.” According to FinCEN, the Iranian regime abuses religiously affiliated institutions and charitable organizations to finance elites, fund repression within Iran, and support violence abroad.
State Department Sanctions Cuban State-Owned Banco Internacional de Comercio, S.A.
On October 15, the Department of State sanctioned Banco Internacional de Comercio, S.A. (“BICSA”), a Cuban state-owned bank. According to the State Department, BICSA has provided services to Karafarin Bank, an Iranian financial institution sanctioned by the United States since 2020. The State Department designated BICSA for operating in the financial services sector of the Cuban economy.
The action was pursuant to E.O. 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.” The action was announced alongside a broader U.S. effort targeting Iranian financial actors and reflects the Trump Administration’s focus on alleged financial links between Cuba and Iran.
OFAC Extends Lukoil General Licenses
On October 15, OFAC issued Russia-related GL 128D and GL 130B concerning certain activities involving Lukoil International GmbH (“LIG”) and certain related entities. GL 128D, which replaces and supersedes GL 128C, extends the authorization for certain transactions involving specified Lukoil-owned retail automobile service stations outside Russia, while GL 130B, which replaces and supersedes GL 130A, extends the authorization for transactions involving certain Bulgaria-based Lukoil entities and certain related entities. Both licenses extend the relevant authorizations from October 29, 2026, to April 24, 2027.
Treasury Targets Cartel del Noreste’s Commercial Network and Horse Racing Operations
On October 13, OFAC designated four individuals and 11 entities allegedly linked to Cartel del Noreste (“CDN”), a Mexico-based cartel designated as both a Foreign Terrorist Organization and a Specially Designated Global Terrorist (“SDGT”). According to the Treasury Department, the action is OFAC’s largest sanctions action to date targeting CDN.
The designations were imposed pursuant to E.O. 14059, which targets the international proliferation of illicit drugs and their means of production, and E.O. 13224, as amended, which targets terrorists and their supporters. Treasury stated that the action was undertaken in coordination with multiple U.S. law enforcement agencies and Mexico’s Financial Intelligence Unit.
OFAC Extends Venezuela Earthquake Relief Authorization
On October 16, OFAC issued Venezuela-related GL 60A, “Authorizing Transactions Related to Earthquake Relief Efforts in Venezuela.” GL 60A replaces and supersedes GL 60, extending the authorization period from its original end date of October 23, 2026, to April 21, 2027. Venezuela-related FAQ 1263 was amended to reflect the extended authorization end date.
UK Developments
UK Imposes Sanctions on Two Iranian Nationals over Alleged Hostile Activities
The UK Government has announced the designation of two Iranian nationals under the Iran sanctions regime. According to a UK Government press release, the individuals have been designated for their alleged involvement in facilitating or conducting hostile activities on behalf of the Iranian regime, including threats and planned attacks overseas. The individuals are Ruhollah Bazghandi, Head of Counterespionage Operations within the Islamic Revolutionary Guard Corps (IRGC), and Shahram Ali Reza Tamarzadeh Jakki, an alleged facilitator of the Zindashti criminal network implicated in plots targeting Iranian dissidents. Both individuals are now subject to asset freezes, travel bans and director disqualification sanctions. The Foreign Secretary also announced that the Iranian Ambassador would be summoned to reiterate the UK’s opposition to Iranian state-backed threats and interference. The designations form part of the UK’s broader efforts to counter hostile Iranian activity, including its recent use of state threats powers against the IRGC and further sanctions targeting individuals and networks allegedly involved in activities threatening UK and international security.
UK Calls for Tighter International Sanctions on Russia’s Shadow Fleet
UK Finance Minister, John Healey called for stronger international sanctions targeting Russia-linked shipping services during the International Monetary Fund’s annual meetings in Bangkok. Healey urged other countries to maintain economic pressure on Russia, particularly by tightening restrictions on maritime services that enable Russia’s shadow fleet to operate and circumvent existing sanctions. His comments follow several recent UK sanctions packages targeting Russian oil tankers, shipping networks and related service providers, reflecting the UK Government’s continued focus on restricting the energy revenues used to finance Russia’s war in Ukraine. The call comes amid potential divergence in international sanctions policy, with reports that the US administration is considering easing restrictions on certain shadow fleet vessels transporting oil and petroleum products from Russia, Iran and Venezuela to address elevated global freight rates. The developments highlight the UK’s continued commitment to strengthening maritime sanctions enforcement, while underscoring the potential compliance challenges for shipping companies, insurers and financial institutions arising from differences in sanctions policy between jurisdictions.
OFSI Issues General Licence Permitting Ground Rent and Service Charge Payments by Designated Persons
OFSI has issued the Ground Rent and Service Charge Payments General Licence (INT/2026/10050568), authorising UK designated persons, or those acting on their behalf, to make certain property-related payments that would otherwise be restricted under UK financial sanctions. The licence permits payments for ground rent, service charges and certain late payment fees relating to eligible leases of relevant properties in England and Wales, provided payments are made to a UK bank account held by a landlord, managing agent or person acting on a landlord's behalf. It also authorises landlords and managing agents to receive such payments, transfer funds to superior landlords where applicable, and retain overpayments as credit against future liabilities. Importantly, the licence does not authorise payments to UK designated persons. The General Licence took effect on October 12, 2026, and expires at 23:59 on October 11, 2027. The measure provides a mechanism for UK designated persons to meet ongoing property-related obligations while maintaining applicable financial sanctions restrictions. UK designated persons, landlords, managing agents and financial institutions seeking to rely on the licence should ensure that payments fall within its scope and that all applicable conditions, reporting obligations and record-keeping requirements are satisfied.
Expansion to the Scope of the Global Human Rights Sanctions Regime
The UK Government has revoked and re-enacted its Global Human Rights Sanctions regime, expanding the purpose and designation criteria under the new regime. The reformulated sanctions regime is intended to give the UK Government greater power to target those involved in serious violations and abuses of human rights, violations of international humanitarian law, as well as obstruction of the delivery or distribution of humanitarian assistance. Consequently, under the new Global Human Rights and International Humanitarian Law Sanctions Regulations 2026, the range of conduct for which a person can be designated has been broadened, most significantly to include serious violations of international humanitarian law. A new power to designate by description has also been introduced. The new regime came into effect on October 15, 2026.
In part, this action relates to the package of sanctions measures announced by the UK Government in September 2026 in relation to settlement activity in the West Bank. At that time, the Foreign, Commonwealth and Development Office announced the UK Government’s intention to defend the two-state solution by, among other things, strengthening the UK’s global human rights focussed sanctions regime to target those who commit serious violations of international humanitarian law around the world, including in Palestine.
EU Developments
EU Council Designates 77 Individuals Under Russia Sanctions Regime for Involvement in State Duma Elections
On October 12, the EU Council adopted restrictive measures against 77 individuals involved in the illegal Russian State Duma elections held in September 2026 in occupied territories of Ukraine.
The new listings include 74 candidates who stood for election in the so-called “Donetsk People's Republic”, the so-called “Luhansk People's Republic”, the Zaporizhzhia and Kherson regions, and the so-called “Republic of Crimea and the City of Sevastopol”. Those listed include former acting Prime Minister of Ukraine Serhiy Arbuzov, journalist and Channel One war correspondent Irina Kuksenkova, and the so-called “Mayor of Yalta” Yanina Pavlenko. The EU Council also imposed restrictive measures on three members of the Central Election Commission of the Russian Federation for organizing the elections.
According to the Council, by participating in or facilitating the illegal elections for the Russian State Duma, the listed individuals actively contributed to efforts to legitimize Russia's war of aggression against Ukraine and to sustain Russia's illegal occupation of Ukrainian territory.
EU Council Targets under the Asset Freeze Sanctions Regime Individuals and Entities Involved in the Circumvention of EU Sanctions
On October 15, the EU Council updated the Russia asset freeze sanctions regime under Council Decision 2014/145/CFSP and Council Regulation (EU) 269/2014 by listing three individuals and nine entities involved in the circumvention of EU sanctions. The new designations target individuals facilitating the import of goods subject to EU restrictive measures into Russia, as well as entities involved in sanctions-evasion schemes related to oil trade and financial transactions.
Among those designated are the Russian cargo delivery company Movers Group LLC and its General Director, Dmitry Chudovsky, for facilitating the parallel import of restricted goods into Russia. The Russian customs broker and full-cycle logistics operator DT Inier LLC and its majority shareholder, Ivanna Savchuk, were also designated for operating customs, logistics, and procurement networks used to circumvent EU trade restrictions. Additionally, the Russian financial services company United Stream LLC and its founder and director, Svetlana Gumenyuk, were designated for facilitating the processing of transactions and the covert importation of goods from the EU into Russia.
The EU Council also designated several companies based in third countries. These include Turkish companies Begler Tekstil Insaat Elektronik ve Dis Ticaret Ltd. Sti. and Medse Group LLC, which were identified as being involved in the foreign trade and procurement of products subject to EU restrictive measures for export to Russia. The Council further listed HURUS TRADE FZE, a trading intermediary established in the United Arab Emirates (UAE) that supplies Russian-origin crude oil to India, and DIS Logistics DMCC, a company based in the UAE that manages vessels linked to the Russian shadow-fleet ecosystem.
Additional listings include Vigor Marine Services LLP, a shipping company based in India, and Shiva Shipping Ltd, a company established in Mahe Island, Seychelles, both of which were identified by the Council as managing or owning vessels involved in the transport of Russian-origin crude oil or petroleum products and practicing irregular and high-risk shipping practices.
EU Council Renews Chemical Weapons Sanctions Regime for Five Years
The EU Council recently renewed the restrictive measures against the proliferation and use of chemical weapons under Council Decision (CFSP) 2018/1544 until October 30, 2031. The renewal marks the first time that an EU sanctions regime is renewed for a period of five years. Currently, the individual restrictive measures apply to 31 individuals and six entities.
Designated individuals and entities are subject to an asset freeze and a prohibition on making funds or economic resources available. In addition, listed individuals are subject to an EU travel ban.
EU Council Adds Three Individuals and Four Entities to Sanctions List Targeting the Democratic People’s Republic of Korea
The EU Council amended its autonomous sanctions regime against the Democratic People’s Republic of Korea (DPRK) to designate three individuals and four entities for supporting, promoting or facilitating activities related to the DPRK’s nuclear, ballistic missile, and other weapons of mass destruction programs, as well as for violating UN Security Council sanctions. The new listings target activities linked to the growing military, economic, and industrial cooperation between the DPRK and Russia, including the deployment of DPRK workers to Russia, bilateral commercial and industrial cooperation projects, and the DPRK-Russia “arms-for-oil” trade.
Among those designated are Ri Song Jin, a researcher at the DPRK National Aerospace Technology Administration and an official of the DPRK Missile General Bureau, whom the EU Council stated was deployed to Russia as a technician supporting Russia’s use of DPRK missiles. Samolet Group, a Russian real estate development company, and its CEO, Anna Akinshina, were listed for employing DPRK workers in construction projects in Vladivostok in breach of UN sanctions. The EU Council also targeted Vladimir Sokolov, founder and president of Russian holding company Black Horse, together with Black Horse and its subsidiary Golden Autumn Agroholding, for facilitating commercial and industrial cooperation with the DPRK. In addition, Paekyangsan Shipping Co Ltd. was designated for operating the DPRK-flagged vessel Paek Yang San 1, which was involved in shipments of refined petroleum products from Russia to the DPRK in violation of UN Security Council sanctions.
As a result of the designations, the listed individuals and entities are now subject to asset freezes and a prohibition on the provision of funds or economic resources. Listed individuals are also subject to an EU travel ban.
EU Council Removes Mikail Gutseriev and Viktar Shautsou from Belarus Sanctions List
On October 13, the EU Council updated the sanctions regime targeting Belarus under Council Decision 2012/642/CFSP and Council Regulation (EC) 765/2006 to remove two businessmen from the sanctions list. Specifically, Mikhail Gutseriev, a prominent Russian businessman with interests in Belarus’ energy, potash, and hospitality sectors, was delisted. The EU Council had previously designated Gutseriev on the grounds that he benefited from and supported the Lukashenka regime. Gutseriev remains listed under the EU’s Russia asset freeze sanctions regime.
In addition, the EU Council removed Belarusian businessman Viktar Shautsou from the Belarus sanctions list. Shautsou had previously been designated on the grounds that he benefited from and supported the Lukashenka regime, including through his involvement in Reshenie Bank and business interests connected to the Dudutki museum complex.
Asia-Pacific Developments
China Proposes New Export Restrictions on AI, Biotechnology and Solar Power Technologies
On October 16, 2026, China unveiled a draft proposal to tighten export controls on 40 advanced technologies across AI, biotechnology, and photovoltaic solar power, including 14 technologies subject to outright export bans and 26 subject to additional restrictions. Beijing cited national security concerns, particularly the potential misuse of advanced AI technologies to threaten critical infrastructure, military facilities, and government systems, as justification for the measures.
China Sanctions Paraguayan and Belizean Ministers Over Ties with Taiwan
On October 12, 2026, China imposed sanctions on Paraguay’s Communications Minister Gustavo Villate and Belize’s Foreign Minister Francis Fonseca over their countries’ continued diplomatic relations with Taiwan, accusing them of interfering in China’s internal affairs, spreading misinformation about Chinese cyberattacks, and making anti-China statements. The sanctions, which include entry bans covering mainland China, Hong Kong, and Macau, as well as restrictions on transactions and cooperation with Chinese entities, are largely symbolic given the officials’ limited engagement with China.
