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.
Sanctions
OFAC General Licence — Iranian-origin petroleum products
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…
UK imposes new Russia sanctions – mirroring of EU position on the maritime transport of LNG and refined petroleum products derived from Russian crude
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.
UK issues General Trade Licence for import of diesel and jet fuel derived from Russian crude oil
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…
EU’s 20th Sanctions Package on Russia
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.…
Temporary U.S. sanctions relief for Russian seaborne oil products
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…
Carrot over the Stick? Reforms to OFSI Civil Enforcement Processes incentivise early engagement and settlement
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.
RePowerEU Update: Six Countries Cleared for Simplified Gas Imports
The European Commission has granted six countries – Algeria, Nigeria, Norway, Qatar, the United Kingdom and the United States – an exemption from prior authorisation requirements for natural gas imports under the RePowerEU Regulation.
What does this mean?
Gas sourced from these six countries will no longer require prior authorisation under Article 5(3) or evidence…
From oil price cap to maritime services ban: A shift in sanctions strategy
By Alexander Brandt on
I was recently quoted in TradeWinds on the growing number of tankers going dark as the EU considers expanding restrictions on maritime services connected to Russia’s oil trade.
It now looks increasingly certain that the EU, and likely the UK, will move to a comprehensive maritime services ban on the carriage of Russian crude…
EU LNG and Pipeline Gas Import Ban – Timing under EU Sanctions (Article 3ra) vs RePowerEU
As a follow-up to our previous client alerts on the EU’s Russian gas phase-out (available here), we have prepared an infographic summarising how the EU sanctions framework (Regulation 833/2014) interacts with the RePowerEU phase-out Regulation (Regulation 2026/261), including the key contract cut-off and phase-out dates for both LNG and pipeline