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 Oil Deal and General Licenses Pave the Way for Multinationals to Expand Venezuela Operations
In recent weeks, OFAC has issued a series of Venezuela-related General Licenses (GLs) and amendments that have expanded opportunities for new oil and gas-related investment in Venezuela. OFAC amended multiple oil-sector General Licenses removing the requirement for parties using those licenses to include a choice of law provision in contracts with the Government of Venezuela. Previously, certain GLs required that the terms of contracts entered into under those GLs be construed in accordance with the laws of a state or other jurisdiction within the US. The GLs issued over the course of 2026 have cleared the path for the Trump administration’s joint venture with North American Blue Energy Partners (NABEP), which gives the US control of over 65 billion barrels of Venezuela’s proven oil reserves. Concurrently, US oil majors and international firms are moving to launch or expand operations in Venezuela’s oil sector to capitalize on the newly accessible and abundant crude reserves.
On August 28, the White House announced the joint venture with NABEP, which it described as “the biggest oil deal in world history.” The White House explicitly stated that the agreement is strictly with NABEP, not with the interim Venezuelan government. However, the interim Venezuelan authorities did grant NABEP 100-year concessions for the 65 billion barrels across 17 oil fields. NABEP granted the Pentagon’s Office of Strategic Capital a 35% equity stake and gave the US State Department the right to purchase 20% of the off-take from NABEP fields at the cost of production. The State Department also has right of first refusal for the remaining 80% of the oil produced. The US-NABEP venture is governed by US law and is estimated to be the world's second-largest corporate holder of proven oil reserves, holding around one-fifth of Venezuela’s 303 billion barrels of proven crude reserves.
The Trump administration has sought to open the door for more companies to capitalize on developing Venezuela’s natural resources. US oil majors initially hesitated to move back into the country following the US capture of Nicolas Maduro in January, but last week some US firms signaled plans to invest in Venezuela. International energy firms have also recently signed major deals in Caracas. India’s ONGC and Colombia’s GeoPark are on track to make deals as well.
In addition to oil, the US is supporting the expansion of Venezuela’s gold mining sector, a lucrative industry holding the fifth-largest reserves but long dominated by criminal organizations (see Sam Bloebaum’s deep dive). US Interior Secretary Doug Burgum visited Venezuela in March alongside US mining sector officials from more than two dozen companies. Burgum pledged security assurances for mining companies interested in investing in Venezuela, saying that Venezuela’s government would “ensure their security.” OFAC has issued GLs authorizing certain mining activities in the mineral sector, including certain transactions with the Venezuelan state-owned gold mining company Minerven. International firms from Canada, Switzerland and Qatar have indicated plans to move into Venezuela’s gold mining sector; however, armed groups like the Colombian ELN and ex-FARC dissident factions that currently control the mines pose a major risk that has kept more companies from rushing into the sector.
Part of the US strategy in facilitating new investments in Venezuela is an effort to displace China’s inroads in South America. Many of the oil fields that will be run by the US joint venture with NABEP were formerly Chinese-owned. Before the US capture of Maduro, China purchased the majority of Venezuela’s oil, accounting for more than half of Venezuela’s government revenue. Venezuela, the largest recipient of Chinese state-backed lending in Latin America, still owes China approximately $10 billion in oil-backed loans, which China is now increasingly unlikely to recoup. China has also invested heavily in mineral extraction across Latin America, and Chinese firms have a strong foothold in Venezuela’s telecommunications sector. Recent OFAC actions now aim to clear the way for US companies to invest in Venezuelan telecoms while explicitly blocking Chinese firms.
The US-backed development of Venezuela’s oil, gold, and telecoms sectors presents major opportunities for firms, but potential downside risks are numerous. The Trump administration is seeking to insulate investments from the interim Venezuelan government, whose future is uncertain. The government of Delcy Rodriguez is in talks with the opposition, ostensibly taking steps toward holding elections. However, a democratically elected Venezuelan government may be unwilling to uphold the concession of Venezuela’s oil rights, which conflicts with the 1999 constitution, and the US may be incentivized to preserve Rodriguez’s hold on power. It is also unclear whether a future administration in the US would be willing to preserve the Trump administration’s arrangement. The oil deal with NABEP was in part an attempt to clear the path for other US oil titans to reenter Venezuela, and Trump has continued to push major firms to reinvest, but some US firms see the state-backed competitor as a risk. Discussions are ongoing as US firms, some of which are still owed billions of dollars after previously exiting Venezuela, continue to weigh the risks of reentering against opportunities to negotiate favorable contract terms in the current political environment.
US Developments
State Department Sanctions Six Targets in Cuban Financial, Metals and Mining, and Energy Sectors
On September 3, the State Department designated five entities and one individual related to Cuba’s financial services, metals and mining, and energy sectors. These actions were pursuant to Executive Order (“E.O.”) 14404, “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy.”
The designated entities include Banco Exterior de Cuba, a state-owned financial institution; two subsidiaries of the state-owned petroleum company, Union Cuba Petroleo (“CUPET”); Empresa de Servicios Comandante René Ramos Latour, a state-owned mining support services company; and Empresa Importadora y Abastecedora del Níquel, a state-owned nickel industry support services company. Additionally, the State Department designated Fidel Ernesto Castro Calis, who is the grandson of Raúl Castro.
Alongside the sanctions, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Cuba General License (“GL”) 4A under E.O. 14404. GL 4A authorizes transactions that are ordinarily incident and necessary to the official activities of third-country diplomatic and consular missions in Cuba. GL 4A broadens the authorization previously granted by GL 4 by removing a prior restriction on certain financial transfers to blocked persons.
OFAC Sanctions Turkish Bank as Part of Operation Economic Outcast
On September 4, OFAC announced sanctions against Türkiye-based financial institution Golden Global Yatirim Bankasi Anonim Sirketi (“Golden Global Bank”) and its subsidiaries for allegedly facilitating tens of millions of dollars’ worth of transactions for Iran’s Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”). According to OFAC, Golden Global Bank was established for the purpose of providing correspondent banking services to Iranian financial institutions in order to enable China’s purchases of Iranian oil.
These sanctions are part of the Trump Administration’s new “Operation Economic Outcast,” which is a broad economic pressure campaign targeted at Iran. We covered the initiative and its implications in a recent blog post.
OFAC Generally Authorizes Venezuelan Coal Activities
On September 2, OFAC expanded the scope of three Venezuelan GLs to include authorizations for transactions ordinarily incident and necessary to certain activities relating to Venezuelan-origin coal, including those involving the Venezuelan state-owned coal company Carbones del Zulia (“Carbozulia”). The prior versions of these GLs only authorized activities related to Venezuelan-origin minerals. In particular, OFAC issued the following amended GLs:
- GL 51D, which authorizes transactions ordinarily incident and necessary to the exportation, reexportation, sale, resale, supply, storage, purchase, delivery, or transportation of Venezuelan-origin coal or minerals;
- GL 54C, which authorizes transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the exploration, development, mining, extraction, processing, refining, or production of coal or minerals in Venezuela; and
- GL 55A, which authorizes transactions that are related to the negotiation of and entry into contingent contracts for new investment in the coal or minerals sectors of Venezuela.
OFAC Issues Reminder to File the 2026 Annual Report of Blocked Property
On September 2, OFAC issued a reminder that U.S. persons holding blocked property as of June 30, 2026, must submit an Annual Report of Blocked Property (“ARBP”) by September 30, 2026. Failure to file a complete report by the deadline may constitute a violation of OFAC’s Reporting, Procedures, and Penalties Regulations and could result in an enforcement referral. Persons filing the 2026 ARBP must use spreadsheet form TD-F 90-22.50 and submit the completed form through the OFAC Reporting System (“ORS”), which OFAC adopted as its primary reporting mechanism two years ago. First-time users of ORS will need to contact OFAC to request registration instructions. For additional information, please review OFAC’s Guidance on Filing the 2026 Annual Report of Blocked Property.
US Announces New Sanctions Under “Operation Economic Outcast” Targeting Iran and Expanding Secondary Sanctions Risks
Following President Donald Trump’s announcement that the US will conduct the “most crushing economic operation ever taken against any country” against Iran, the Department of the Treasury launched “Operation Economic Outcast,” a broad economic pressure campaign targeting Iran and its supporters. According to the Treasury Department, “[e]very country will be given a defined timeline to shut down the Iran-related activity” that Treasury has identified and “[i]f they fail to act, Treasury will act.” The Treasury Department’s announcement comes amid ongoing negotiations between Iran and Oman on the joint management of the Strait of Hormuz.
As part of the operation, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) authorized secondary sanctions targeting the Iranian digital assets, technology, gold, aviation, and shipping sectors by issuing new determinations pursuant to Executive Order (“E.O.”) 13902. E.O. 13902 targets specified sectors of the Iranian economy and those conducting significant transactions involving those sectors. The determinations authorize the imposition of sanctions pursuant to E.O. 13902 on any person, regardless of location, that operates in these sectors or knowingly engages in a significant transaction involving significant goods or services used in these sectors. The measures expand sanctions exposure for non-US persons and strengthen OFAC’s authority to address third-country support for Iran’s economy.
OFAC also announced the indefinite suspension of five Iran-related general licenses (“GLs”) that had previously authorized certain cross-cultural, educational, and personal activities involving Iran. These include the sending of personal remittances to or from Iran, services related to conferences in the United States or third countries involving Iranian participants, and academic exchanges, educational services, and certain research activities involving US and Iranian educational institutions. We discuss the suspension in more detail in our recent blog post. Notably, OFAC issued new Iran GL BB, which authorizes transactions ordinarily incident and necessary to the wind down of any transaction previously authorized under the five suspended GLs through 12:01 am EDT on September 8, 2026.
Additionally, OFAC designated nearly 60 entities, individuals, and vessels allegedly involved in supporting Iran's defense activities, military procurement efforts, cyber operations, and petroleum and petrochemical revenue generation. OFAC also issued Iran GL AA, which authorizes transactions ordinarily incident and necessary to the wind down of any transaction or the maintenance of operations, contracts, and other agreements in effect as of August 24, 2026 involving La Nivernaise De Raffinage SAS (“LNR”), a newly designated France-based cooking oil refinery, and any entity in which it owns, directly or indirectly, a 50 percent or greater interest, through 12:01 am EDT on October 23, 2026.
OFAC issued an updated alert warning that US and non-US persons face significant sanctions risks if they make payments to, receive services from, or otherwise engage with the Iranian government or designated entities seeking to control passage through the Strait of Hormuz. The alert specifically identifies the Persian Gulf Strait Authority, Persian Gulf Marine Insurance Company, and HormuzSafe Marine Services Authority, which OFAC designated for supporting the IRGC or operating in Iran’s financial sector. OFAC also warned of secondary sanctions risks for foreign parties and urged maritime service providers to conduct enhanced due diligence on vessels transiting the Strait.
The August 24 measures come just weeks after the United States and Iran agreed to a June 2026 Memorandum of Understanding that contemplated a potential pathway toward broader sanctions relief, and a week after the MOU formally lapsed. While the long-term direction of US policy toward Iran remains uncertain, Operation Economic Outcast underscores that US and non-US companies should continue to treat Iran sanctions compliance as a rapidly evolving risk area.
US Revokes Egyptian Bank’s UAE Branches Access to Correspondent Banking
On August 28, under “Operation Economic Outcast,” the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) proposed a rule that would revoke Banque Misr UAE’s correspondent banking access to US financial institutions. Banque Misr UAE reportedly consists of the Emirati branches of Banque Misr, Egypt’s second-largest state-owned bank. According to FinCEN, Banque Misr UAE serves as a “critical access node” through which the Iranian government accesses US dollars. The Central Bank of Egypt told reporters that the US measures only affected Banque Misr’s UAE branches and did not apply to any other Egyptian branches.
On the same day, OFAC designated a Hong Kong-based entity that allegedly facilitated sanctioned Iranian persons’ access to the international financial system, along with an Iranian national.
US Grants Additional Sanctions and Export Controls Relief to Syria
On August 24, the Department of State rescinded Syria’s designation as a State Sponsor of Terrorism and removed Hay’at Tahrir al-Sham (“HTS”), a political and paramilitary group currently in control of Syria’s government, from the list of Specially Designated Global Terrorists (“SDGT”), and from the List of Specially Designated Nationals and Blocked Persons (“SDN List”). The changes build on previous US actions, including the July 2025 removal of HTS from the Foreign Terrorist Organization (“FTO”) list. The State, Treasury, and Commerce Departments issued an updated Tri-Seal Advisory reflecting these developments.
As a result of the latest actions, HTS is no longer subject to US terrorism sanctions under E.O. 13224, and US persons generally no longer need OFAC authorization to engage in transactions involving HTS, provided those activities do not involve other sanctioned parties or prohibited conduct. Following HTS’s delisting, OFAC revoked Syria GL 25, which had authorized certain transactions involving the Syrian government, and updated related guidance and FAQs.
The rescission of Syria’s designation has important export-control implications because State Sponsor of Terrorism status has served as a basis for certain export restrictions affecting Syria. However, significant US export controls remain in place until the Export Administration Regulations and International Traffic in Arms Regulations are amended. A license or applicable exception is still required for exports or reexports of items subject to US jurisdiction to Syria, except for food and medicine designated EAR99. Thus, Syria remains a jurisdiction requiring an elevated export controls compliance posture. We discuss the implications of the August 24 actions, including export controls, anti-boycott, and sovereign immunity considerations related to Syria’s delisting in more detail in our recent blog post.
Finally, OFAC also designated two former HTS affiliates who it alleges continue to support al-Qa’ida-linked entities through financial and logistical support. The US government stated that these targeted sanctions demonstrate its continued focus on holding terrorist actors accountable while easing restrictions designed to support Syria’s broader political and economic stabilization.
US Sanctions Target Alleged Terrorist Support Networks
On August 26, OFAC designated three organizations and two individuals for allegedly supporting terrorist activity and extremist networks. The action targeted Autistici Inventati, an Italy-based entity, for allegedly providing digital infrastructure, hosting services, encrypted communications, and other technological support to violent far-left extremist groups, including the Kurdistan Workers’ Party, which is designated as an FTO. Simultaneously, OFAC issued Counter Terrorism GL 36, which authorizes transactions ordinarily incident and necessary to the wind down of dealings involving Autistici Inventati and any entity in which it owns, directly or indirectly, a 50% or greater interest through 12:01 am EDT on September 25, 2026.
Additionally, OFAC sanctioned Palestine Action, a United Kingdom (“UK”)-based organization proscribed as a terrorist group by the UK government in July 2025. OFAC designated Palestine Action alleging that the organization supported acts of terrorism, including acts that have physically injured UK law enforcement personnel, as well as acts intended to intimidate lawful commercial enterprises and coerce the UK Government.
OFAC also sanctioned Masar Badil, a transnational organization that OFAC alleges operates as a front for the Samidoun Palestinian Prisoner Solidarity Network. Samidoun was jointly sanctioned by the United States and Canada on October 15, 2024 for being a front organization that is owned, controlled, or directed by the Popular Front for the Liberation of Palestine, itself a designated FTO since 1997. Alongside this action, OFAC also sanctioned two members of Masar Badil for their alleged involvement in supporting the organization.
OFAC Amends Multiple Venezuela-related GLs
On August 27, OFAC issued eight amended Venezuela-related GLs:
- GL 46D, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;”
- GL 47B, “Authorizing the Sale of US-Origin Diluents to Venezuela;”
- GL 48C, “Authorizing the Supply of Certain Items and Services to Venezuela;”
- GL 50C, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities;”
- GL 51C, “Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold;”
- GL 52B, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.;”
- GL 54B, “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela;”
- GL 61A, “Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications.”
A party seeking to enter into a contract authorized by these Venezuela GLs with the Government of Venezuela (GOV) or certain other blocked persons (e.g., Petróleos de Venezuela, S.A. in GL 52B or CVG Compañía General de Minería de Venezuela CA in GL 51C) is no longer required to include a choice of law provision in the contract. OFAC amended these GLs to remove the requirement that the terms of such contracts be “construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States.” OFAC stated that it had amended these GLs in response to investment-related reforms made by the GOV since January 2026. These GLs still require dispute resolution proceedings to occur in the United States, United Kingdom, France, or Singapore.
OFAC Extends Authorization for Certain Diamond Imports
On August 26, OFAC issued Russia-related GL 104B, “Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068.” GL 104B extends authorization for the import of non-industrial diamonds that were substantially transformed outside Russia. GL 104B replaces GL 104A, which was scheduled to expire September 1, 2026, and extends the authorization through 12:01 am EDT on September 1, 2027.
UK Developments
UK Issues Movement Direction to Russian Cargo Vessel SINEGORSK
The UK Government has published details of the use of its transport sanctions powers against the Russian-flagged, registered and operated cargo vessel, SINEGORSK. According to the UK Government notice, on January 27, 2026, the vessel informed HM Coastguard that it intended to anchor in sheltered UK waters to repair a small hull defect during adverse weather. After SINEGORSK anchored at Blue Bay Anchorage within UK waters, the Centre for Transport Sanctions investigated and determined that the vessel fell within the scope of the Russia (Sanctions) (EU Exit) Regulations 2019 because it was Russian-flagged and registered and operated by a Russian-incorporated company.
On January 28, 2026, the Secretary of State for Transport exercised the discretionary power under regulation 57C of the Russia Regulations to issue a movement direction, which was served by HM Coastguard. SINEGORSK complied with the direction, leaving UK internal waters and subsequently the UK’s territorial sea. The action illustrates the practical application of the UK’s shipping sanctions, which are intended to restrict Russia's ability to use its maritime sector to support or finance the war in Ukraine and include powers to deny in-scope vessels access to UK ports and issue movement and detention directions.
OTSI Publishes First Annual Review Covering 2025–26
The Office of Trade Sanctions Implementation (OTSI) has published its 2025–26 Annual Review, alongside an accompanying blog reflecting on its first full year of activity across compliance, licensing and enforcement (the “Review”). According to the Review, OTSI received 178 reports or referrals of potential trade sanctions breaches, with 111 (62%) originating from sectors subject to mandatory reporting obligations and 23 referrals from other UK government departments. OTSI closed 104 enforcement cases, including 41 where no breach was identified and 40 that were referred to HMRC, including for potential criminal enforcement or because the conduct predated OTSI’s enforcement powers. Around 6% of cases opened were initiated proactively, with OTSI indicating that it intends to significantly increase proactive and intelligence-led investigations as its intelligence capabilities develop.
The Review identifies implementation and enforcement of the Russia sanctions regime as a central focus and notes that a number of active investigations are expected to reach decision points during 2026–27. It also highlights the continued expansion of OTSI’s remit, including the introduction of Sanctions End-Use Controls in May 2026 to address circumvention and the expansion of its licensing responsibilities in April to cover exports of sanctioned goods and related ancillary services. Alongside enforcement, OTSI continues to emphasise compliance support through guidance, stakeholder engagement and outreach, including forthcoming sanctions workshops aimed particularly at SMEs navigating trade sanctions requirements.
UK to Double Maximum OFSI Penalty for Financial Sanctions Breaches
The UK Chancellor has announced that the maximum monetary penalty available to OFSI for financial sanctions breaches will be increased from 50% to 100% of the estimated value of the funds or economic resources involved in a breach. Under section 146 of the Policing and Crime Act 2017, OFSI can currently impose a penalty of up to the greater of £1 million or 50% of the estimated value of the breach; the announced change would increase the percentage-based limb to 100%, significantly increasing potential exposure for high-value breaches. According to a UK Government press release, HM Treasury stated that the measure is intended to strengthen the deterrent effect of the UK sanctions regime and drive stronger enforcement. The announcement signals a further tightening of the UK’s financial sanctions enforcement framework and reinforces the importance for businesses of maintaining effective sanctions compliance, screening and escalation controls.
NCA Issues Industry-wide Alert on A7 Russia Sanctions Evasion Network
The National Crime Agency (“NCA”) and National Economic Crime Centre have issued an industry-wide “flash alert” on the A7 sanctions evasion network, developed with OFSI, the FCDO and financial sector partners through the Joint Money Laundering Intelligence Taskforce. A7, established in 2024 by Ilan Shor and backed by sanctioned Russian state bank PSB and VEB.RF, is described as a cross-border payment mechanism used to circumvent sanctions, and claims to have settled more than $86 billion in its first year. The alert identifies methods used by the network to move value internationally, including overseas liquidity pools, globally registered shell companies or “sub-agents” operating local bank accounts, false invoices, VPNs used to disguise the location of operators, and promissory notes (“veksels”) that enable payments without correspondent bank transfers leaving Russia. OFSI has identified transactions between A7-linked shell companies and UK-incorporated beneficiaries, and the alert provides seven red-flag indicators for firms to assess against their existing AML and sanctions controls. The alert is particularly significant as it has been distributed across the regulated sector, underscoring expectations that firms incorporate emerging sanctions-evasion typologies into transaction monitoring and due diligence.
EU Developments
EU Considers Additional Russia Sanctions Listings Following Attempted Leipzig Drone Attack
On September 2, the German government announced that it had concluded Russia was responsible for the attempted drone attack at Leipzig/Halle Airport in August. German Interior Minister Alexander Dobrindt described the incident as a hybrid attack forming part of a broader pattern of Russian hybrid activities targeting European infrastructure and security.
The attempted attack was discussed at the informal meeting of Foreign Affairs Ministers held in Wicklow, where several Member States reportedly called for increased pressure on Russia through additional restrictive measures. Speaking at the press conference following the meeting, High Representative of the EU Kaja Kallas confirmed that work is ongoing on a package of up to 1,600 sanctions listings targeting Russia's military-industrial complex. The package is being prepared with a view to adoption at the upcoming Foreign Affairs Council in October. Kallas further noted that at least one Member State had submitted additional listing proposals. Separately, German Foreign Minister Johann Wadephul stated that the EU would continue work in the coming weeks on further listings targeting Russian individuals.
In parallel, European Commission President Ursula von der Leyen stressed that hybrid attacks would not go without a clear response and referred to forthcoming discussions among EU foreign ministers on additional sanctions against Russia.
CJEU Judgment on the Standard of Proof for Establishing “Control” under Russia Asset Freeze Sanctions
The Court of Justice of the European Union (CJEU) delivered its judgment in Case C‑147/25 (Inter Rao Lietuva), following a request for preliminary ruling from the Supreme Administrative Court of Lithuania regarding Article 2(1) of Council Regulation (EU) 269/2014. The case concerned the inclusion of a Lithuanian electricity supplier on a national list of persons whose funds and economic resources were to be frozen on account of its alleged links with a person subject to EU sanctions.
The Court held that national authorities may compile and publish such lists in order to implement the asset-freezing obligation under Article 2(1). However, the national authority must establish that the funds and economic resources of the person concerned belong to, or are owned, held or controlled by, a person, entity or body designated under Annex I to Council Regulation 269/2014. The mere existence of a “link” between the person subject to the national measure and an EU-designated person is not sufficient to justify inclusion on a national list of persons whose assets are to be frozen.
The Court further held that the reasons for the national measure must be supported by objective and sufficiently solid evidence. The national competent authority may establish control by direct evidence or by a sufficiently specific, precise and consistent body of indicia. In that regard, the Court found that the general nature of Russia’s political regime, including its autocratic and oligarchic character, does not constitute sufficiently solid evidence capable of establishing that the President of the Russian Federation exercises control over Inter Rao Lietuva. Such circumstances may be taken into account as part of the factual context, but cannot take the place of evidence demonstrating the existence of control for the purposes of Article 2(1).
European Commission Publishes Updates to its FAQs on Sanctions Against Russia
On August 24, the European Commission published a series of updates to its FAQs on sanctions against Russia. The revised FAQs include guidance on the import ban on liquefied natural gas (LNG) under Article 3ra of Council Regulation (EU) 833/2014, clarifying the temporary exemption established under the 21st sanctions package against Russia.
The Commission also updated its guidance on the transaction ban concerning infrastructure in Russia under Article 5ae of Council Regulation (EU) 833/2014. The update includes a new question on the application of the transaction ban to listed refineries in Russia and third countries that process or refine Russian crude oil, process or blend petroleum products from Russia, or facilitate the circumvention of EU sanctions. According to the Commission, the transaction ban will apply to Georgia’s Kulevi Oil Refinery from January 25, 2027, allowing the refinery time to diversify away from Russian crude oil.
Lastly, the Commission amended its guidance on the oil price cap under Article 3n of Council Regulation (EU) 833/2014 to reflect the suspension of the price cap adjustment introduced by the 21st sanctions package. The updated guidance also provides clarification on the projects that are exempt from the maritime services and transportation ban, including the transport by vessel of crude oil originating from the Sakhalin‑2 project in Russia to Japan, as well as related technical assistance, brokering services, financing, and financial assistance.
EU Council Updates Sanctions Listings Targeting ISIL (Da’esh) and Al-Qaeda
The EU Council updated the entries of 13 individuals and eight entities under the autonomous restrictive measures regime targeting ISIL (Da’esh) and Al-Qaeda, following an update at the UN level. Changes to Council Regulation (EC) 881/2002 follow the August 18 decision of the UN Security Council Sanctions Committee to update the identifying data for 21 entries on the sanctions list.
Individuals and entities listed under the sanctions framework are subject to an asset freeze and a prohibition on making funds or economic resources available to them.
Asia-Pacific Developments
Chinese Court Freezes $300M in Nexperia Assets Amid Ownership Battle With Wingtech
The Dongguan Intermediate People’s Court has frozen up to 2.14 billion yuan ($300 million) in Chinese assets belonging to Dutch chipmaker Nexperia following a lawsuit by its parent company, Wingtech Technology. Wingtech sued Nexperia and three executives in May and is seeking 8 billion yuan in damages after being stripped of control of Nexperia by Dutch authorities over national‑security concerns. The dispute, which previously saw China impose export controls on Nexperia's Chinese operations that disrupted shipments, gives Wingtech leverage to regain voting control, though it does not change the company’s management or resolve the broader ownership fight.
Apex Logistics Cooperates With US Probe Into Illegal Chip Exports to China
Singapore-based logistics firm Apex Logistics is cooperating with a US government investigation into whether it illegally transported restricted AI chips to China in 2024. The company has since been cooperating with the probe and plans to “continue to work with them until the matter is resolved.” Apex’s parent company, Kuehne+Nagel, affirmed that the freight forwarder maintains its commitment to export regulations.
China Demands US Lift “Illegal” Iran-Related Sanctions on Its Companies
On September 3, 2026, China’s Ministry of Commerce has urged the US to immediately lift unilateral sanctions imposed on Chinese companies and citizens over alleged ties to Iran, strongly opposing the measures as illegal actions lacking UN Security Council authorization. The spokesperson warned that these sanctions disrupt global energy security, asserting that Beijing will firmly safeguard the legitimate rights and interests of its businesses and individuals.
Beijing Warns of Retaliation as US Expands Iran Sanctions
On August 25, 2026, China rejected Washington’s renewed pressure campaign against Iran, arguing that its commercial engagement with Tehran is lawful and should not be obstructed. In a regular press conference, Foreign Ministry spokesman Lin Jian denounced unilateral sanctions lacking UN Security Council approval, saying that “economic warfare” and maximum-pressure policies “only serve to fuel tensions and lead to risk spillover, which will disrupt the global economic and financial order, and harm the legitimate rights and interests of other countries.” He urged “deescalation” and a “return to dialogue and negotiation” rather than further coercive measures. Asked whether Beijing would alter its dealings with Iran or comply with any US timetable for winding down such activity, Lin said China was monitoring developments and would take all necessary steps to “firmly safeguard our rights and interests.”
Seoul Assesses Exposure as Iran Pressure Campaign Raises Wider Economic Risks
On August 25, 2026, South Korea reportedly said it was reviewing the implications for domestic companies and financial institutions of Washington’s latest Iran-related sanctions initiative, particularly its potential secondary effects across technology, shipping, aviation, gold and digital-asset activity. Foreign Ministry spokesman Park Doo-soon said Seoul was consulting relevant agencies, although officials expect limited immediate exposure. Most Korean firms and banks have already exited Iran and bilateral trade has fallen to about USD 150 million from USD 17.4 billion in 2011. Analysts nevertheless cautioned that heightened pressure on Iran could generate broader disruption, especially if it prompts confrontation with China or affects energy markets and regional supply chains. Former Ambassador Yun Kang-hyeon said the effectiveness of the campaign would depend largely on whether major Iranian trading partners, including China, Russia, India, and Turkey, alter their conduct, while another expert warned that an extended conflict could result in indirect political and security pressures on Seoul.
Japan Faces Pressure to Defend ICC After US Sanctions Its Japanese President
On August 30, 2026, Prime Minister Sanae Takaichi reportedly faced mounting criticism over Japan’s response to US sanctions imposed on International Criminal Court President Tomoko Akane, the first Japanese national to head the tribunal. After initially describing the measures as “very regrettable,” Takaichi said they conflicted with Japan’s position and pledged to protect both Akane and the ICC, of which Japan is the largest financial contributor. Akane called the sanctions a threat to the rule of law and urged Tokyo to “make ‘maximum efforts,’ including by engaging with the United States.” Foreign Minister Toshimitsu Motegi has discussed the matter with Akane, but Japan has not publicly demanded that the sanctions be withdrawn.
China Bars Compliance with EU’s JD.com Foreign Subsidies Investigation
China’s Ministry of Justice announced that the European Commission’s cross-border information requests in its Foreign Subsidies Regulation (FSR) investigation of JD.com’s reported EUR 2.2 billion acquisition of German retailer CECONOMY amount to “improper extraterritorial jurisdiction.” Under China’s Regulation on Counteracting Unjustified Extraterritorial Application of Foreign Laws and Measures, which took effect in April 2026, organizations and individuals may not comply with or assist in implementing the identified EU measures. The ministry said the EU had sought broad and unnecessary information from Chinese entities, harming their legitimate interests. It called on the EU to stop what it described as misuse of the FSR investigation tool and warned that China would take countermeasures in accordance with law if the EU continues its approach.
