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Tan Albayrak

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Overview

On 1 October 2026, the UK government announced a significant new package of 31 sanctions against Russia. The package comprises 23 new designations of individuals and entities and eight ship specifications, representing a further intensification of the UK’s economic pressure on Russia ahead of winter. The measures target revenue streams critical to sustaining Russia’s war effort – particularly in the LNG and Arctic shipping sectors – alongside those responsible for serious human rights abuses in occupied Ukrainian territories and those engaged in pro-Kremlin disinformation campaigns.

The package comes against a backdrop of continued Russian aggression, with over 3,100 drone strikes launched into Ukraine in September 2026 alone, and follows sham elections held in temporarily occupied territories of Ukraine that same month. The UK has now imposed over 3,400 designations under the Russia sanctions regime, including more than 500 in 2026, and has sanctioned nearly 600 tankers in connection with Russia’s shadow fleet.

Continue Reading UK sanctions update: new Russia package targets LNG shadow fleet, propagandists, and human rights abusers

Overview

On 24 August 2026, the United States took coordinated action across its Syria and Iran sanctions programmes. Secretary of State Marco Rubio rescinded Syria’s State Sponsor of Terrorism (SST) designation after the 45-day Congressional notification period, and Hay’at Tahrir al-Sham (HTS) was delisted as a Specially Designated Global Terrorist (SDGT) organisation and removed from the Specially Designated Nationals and Blocked Persons (SDN) List. In Iran, the Treasury Department launched “Operation Economic Outcast”, made five sectoral determinations under E.O. 13902, designated nearly 60 entities, individuals and vessels across multiple jurisdictions, and suspended Iran General Licences F and G. It issued General Licences AA and BB, published an alert on Strait of Hormuz passage risks, and designated Singapore-based Wellbred Capital and affiliated entities linked to Mohammad Hossein Shamkhani.

Continue Reading U.S. sanctions update – Syria SST rescission, Operation Economic Outcast, and Iran sanctions developments

The Council adopted its 21st package of restrictive measures against Russia on 23 July 2026. The instruments entered into force on 24 July 2026 (the day following publication in the Official Journal). The principal instruments are Regulation (EU) 2026/1848; Regulation (EU) 2026/1844; and Implementing Regulation (EU) 2026/1843 (amending and implementing Regulation (EU) No 269/2014).

Continue Reading EU’s 21st Sanctions Package: Banks, Barrels, and a Bigger Blacklist

On July 7, 2026, OFAC revoked Iran General License X (GL X) and replaced it with General License X1 (GL X1). The waiver, which had been due to run until August 21, lasted barely two weeks. GL X1 is not a continuation; it is a narrow wind-down authorization that expires on July 17, 2026.

What changed

Three tankers were attacked in the Strait of Hormuz on July 7 and  Washington pulled GL X immediately, a warning of the consequences for Iran’s alleged actions in the strait. Oil prices jumped, and one struck vessel, an LNG carrier, was reportedly at risk of explosion.

GL X had temporarily authorized transactions relating to the production, sale, delivery, and offloading of Iranian-origin crude oil, petrochemicals, and petroleum products. See our previous post on GL X here. The critical point now is that GL X is no longer available, and OFAC can revoke any general license at any time. Parties should structure transactions accordingly.

Continue Reading OFAC Revokes Iran General License X: Only a Short Wind-Down Remains

On 21 June 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorising certain transactions relating to the production, sale, delivery and offloading of Iranian-origin crude oil, petrochemical products and petroleum products. This represents a remarkable — if temporary — departure from the comprehensive United…

Key takeaways

  • Ban on the import of CN 2710 products derived from Russian crude and refined in third countries – subject to diesel and jet fuel exceptions.
  • Prohibition on the maritime transportation of Russian LNG – subject to carve-outs for: (i) pre-existing long-term LNG contracts until 1 January 2027; and (ii) Sakhalin and Yamal 2 projects.
  • Expansion of specified “shadow-fleet” vessel restrictions, with wide-ranging measures prohibiting provision of all principal services to specified ships. These will not automatically apply to pre-existing specified ships.
  • The LNG and refined product restrictions follow announcements in late 2025 by the UK government of an intention to introduce such measures. These largely align with existing EU measures under Council Regulation (EU) 833/2014.
Continue Reading UK imposes new Russia sanctions – mirroring of EU position on the maritime transport of LNG and refined petroleum products derived from Russian crude

On 19 May 2026, the Department for Business and Trade (DBT) issued General Trade Licence GBSAN0004 (the Licence), authorising the import into the United Kingdom of certain processed oil products derived from Russian crude oil. The Licence, which comes into force on 20 May 2026, marks a notable relaxation of the UK’s otherwise comprehensive sanctions…

On 23 April 2026, the EU adopted its 20th package of sanctions against Russia. These measures are contained in (i) Council Regulation (EU) 2026/506 (see here), (ii) Council Implementing Regulation (EU) 2026/509 (see here), and (iii) Council Regulation (EU) 2026/511 (see here), as published in the Official Journal of the EU.…

The U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) issued Russia-related General License 134 (“GL 134”) yesterday, which temporarily authorizes the delivery and sale of Russian-origin crude oil and petroleum products that are already on the water as of March 12, 2026.  It is understood the policy intent…

Key Takeaways

  • OFSI has published updated enforcement guidance introducing a new case assessment matrix, discount structures, a settlement scheme, and fixed penalties for procedural breaches.
  • The new framework allows for cumulative discounts for voluntary disclosure (up to 30%), settlement (20%), and the Early Account Scheme (up to 20%), which can reduce penalties by up to 70%.
  • Fixed penalties of £5,000 or £10,000 will apply to information, reporting, and licensing breaches.
  • OFSI plans to double maximum penalties to £2 million/100% of breach value.
Continue Reading Carrot over the Stick? Reforms to OFSI Civil Enforcement Processes incentivise early engagement and settlement