• The FINMA Notice:

    Updated sanction report: Russia

    The Federal Department of Economics, Education and Research WBF has amended Annex 8 of the Ordinance of 4. March 2022 on measures in connection with the situation in Ukraine (SR 946.231.176.72).

    On the 15th On 1 June 2026, the Federal Department of Economic Affairs, Education and Research WBF amended Annex 8 of the Regulation and published the adjustments on its website. The measures come into force today at 11:00 p.m.


    In accordance with the provisions of the Regulation, financial intermediaries are required to implement the prohibitions, to block the assets of the sanctioned persons and to report the business relationships concerned to SECO. The report to SECO does not relieve a financial intermediary from making additional clarifications in the event of suspicion in accordance with Art. 6 GwG and, if he cannot clear them, to report it immediately to the notification office for money laundering in accordance with Art. 9 GwG.

    The Sanctions Notice:

    Links:

    Files of changes – PDF, XML

    Consolidated program list

  • On June 16th, 2026, Canada announced new sanctions under the Special Economic Measures (Russia) Regulations targeting Russia’s shadow fleet, energy revenues, defence-industrial, and disinformation actors. This package will target a total of 162 individuals, entities, and vessels – all assets of the Russian war machine. The new measures entered into force on June 12th, 2026. See the news release here.

    The specific prohibitions are set out in Regulations Amending the Special Economic Measures (Russia) Regulations

    Please note that the amendments above must be reviewed in tandem with the Special Economic Measures (Russia) Regulations.

    For further information regarding Canadian Sanctions Related to Russia, please visit the Canadian Sanctions Related to Russia.

  • UK Gov logo, 50% resolution.png

    Today, Tuesday 16 June 2026, the UK Government has designated the following 11 individuals and 32 entities, and specified the following 27 ships, under the Russia Sanctions Regime.

    Designated Individuals:

    Name:Unique ID:
    Alexander Petrovich VORONKOVRUS3639
    Ruslan Petrovich KOSHKINRUS3649
    Aleksandr Filippovich VOTCHENKORUS3650
    Nikolay Nikolayevich SAZHINRUS3651
    Sergey Nikolayevich MAZURIKRUS3652
    Aleksandr Vasilyevich MATROSOVRUS3653
    Roman Viktorovich GAIVORONSKIYRUS3654
    Dmitriy Yegorovich ZUBKOVRUS3655
    Stanislav Sergeyevich POPOVRUS3656
    Konstantin Aleksandrovich STRAFILOVRUS3657
    Maksim Yuryevich MAMONTOVRUS3658

    Designated Entities:

    Name:Unique ID:
    JOINT-STOCK COMMERCIAL BANK “EVROFINANCE MOSNARBANK” (JOINT-STOCK COMPANY)RUS3620
    JOINT STOCK COMPANY “YANDEX BANK”RUS3621
    LIMITED LIABILITY COMPANY “WILDBERRIES BANK”RUS3622
    JOINT-STOCK COMPANY COMMERCIAL BANK “VYATICH”RUS3623
    LLC SCIENTIFIC AND PRODUCTION ENTERPRISE SPETSENERGOMEKHANIKARUS3624
    JSC RUSHOLRUS3625
    LLC TECHNOPARITETRUS3626
    LLC NEPTUNE CO LTDRUS3627
    LLC MAGNUS LINKRUS3628
    JSC INTERCONSULRUS3629
    SHTRAL TECHNOLOGY CO LTDRUS3630
    SHTRAL MAKINE ITHALAT IHRACAT SANAYI VE TICARET LIMITEDRUS3631
    IC-ORIENTIRRUS3632
    LLC TPK PEGASRUS3633
    SHENZHEN HUAXIN ANTENNA TECHNOLOGY CO LTDRUS3634
    COMNAV TECHNOLOGY LTDRUS3635
    JOINT STOCK COMPANY MARINE BRIDGE AND NAVIGATION SYSTEMSRUS3636
    P.K.T. MUNGMEE CO., LTDRUS3637
    LIMITED LIABILITY COMPANY TEKHNOPOLRUS3638
    THAI TRADE ASSOCIATION CO., LTDRUS3640
    AEROGLOBAL CO., LTDRUS3641
    BRUKIDA LIMITEDRUS3642
    LLC SMITHRUS3643
    OOO DILMASRUS3644
    KOMPOZIT 21 LLCRUS3645
    OOO KORD-BUNKERRUS3646
    JOINT DEVELOPMENT BANKRUS3647
    “A71” LIMITED LIABILITY COMPANYRUS3648
    “A7-AGENT” LIMITED LIABILITY COMPANYRUS3659
    PILOT FINANCE LIMITEDRUS3660
    JSC BALANCE INSURANCERUS3688
    JSC ROSGOSSTRAKHRUS3689

    Specified Ships:

    Name:Unique ID:
    IMO 9296377 (“MARJORIE”)RUS3661
    IMO 9305556 (“MARVEN”)RUS3662
    IMO 9390587 (“ONEIROI”)RUS3663
    IMO 9333785 (“SEADAR”)RUS3664
    IMO 9291262 (“SILVAR”)RUS3665
    IMO 9290397 (“STORMBRINGER”)RUS3666
    IMO 9417464 (“TANI”)RUS3667
    IMO 9298492 (“TOA PAYOH”)RUS3668
    IMO 9290385 (“ELBUS”)RUS3669
    IMO 9270555 (“INTEGRITY RACER”)RUS3670
    IMO 9380570 (“KURDOS III”)RUS3671
    IMO 9249128 (“SAKHALIN”)RUS3672
    IMO 9408542 (“LING HONG”)RUS3673
    IMO 9294264 (“ORION”)RUS3674
    IMO 9326689 (“MERKURIY”)RUS3675
    IMO 9300817 (“KOSMOS”)RUS3676
    IMO 9317315 (“LUCH”)RUS3677
    IMO 9328170 (“AETHER”)RUS3678
    IMO 9337418 (“ATMOS”)RUS3679
    IMO 9439383 (“BHILVA”)RUS3680
    IMO 9297541 (“DOVE”)RUS3681
    IMO 9198082 (“GLOBAL STAR”)RUS3682
    IMO 9408554 (“HE BO”)RUS3683
    IMO 9413004 (“HORAE”)RUS3684
    IMO 9282041 (“KAVIZ”)RUS3685
    IMO 9274082 (“TM HAI HA 568”)RUS3686
    IMO 9379301 (“VERSA”)RUS3687

    The Sanctions Notice:

    and a press release from the PM himself, FCDO, and Secretary of State Yvette Cooper:

    UK clamps down on shady networks supplying Putin’s illegal war with new sanctions package

    UK announces major new sanctions package choking off Russia’s war effort across multiple fronts. 

    From: Foreign, Commonwealth & Development OfficeThe Rt Hon Yvette Cooper MP and The Rt Hon Sir Keir Starmer KCB KC MP

    Published16 June 2026

    • UK announces 70 new sanctions targeting Russia’s decrepit shadow fleet, military procurement supply chains and illicit finance networks used to circumvent sanctions.  
    • UK ramps up pressure on Russia during G7 Summit following latest abhorrent attacks against Ukraine,  killing innocent civilians and destroying holy sites.
    • The UK has now sanctioned almost 500 individuals, entities and ships under its Russia sanctions regime in 2026 alone, as allied support for Ukraine tops the G7 agenda.  

    The UK has unleashed a major new sanctions package choking off Russia’s war effort across multiple fronts.  

    New action directly targets Russia’s illicit shadow fleet and finance networks used to circumvent Western sanctions and support military procurement.   

    Today’s sanctions further crack down on Russia’s decrepit and ageing shadow fleet, targeting more than 20 oil tankers with new and enhanced powers introduced last month. The UK is also tightening the net around those who are suspected of enabling Putin’s illicit oil trade, further sanctioning ship insurers and other shipping services.  

    The UK is the first G7 country to sanction several Liquefied Natural Gas (LNG) vessels recently acquired by Russia at great expense to service Russia’s sanctioned Arctic LNG 2 project, responsible for exporting millions of tonnes of LNG, in an attempt to source dirty revenue for the Kremlin.    

    Prime Minister Keir Starmer said:

    These sanctions target the vessels, the money and the actors propping up Russia’s war economy, and in turn, threatening European security.

    Working with our G7 allies, we will continue to increase the pressure in Putin and his circle of collaborators until Russia’s war machine is brought to a halt and peace returns to our continent.

    Foreign Secretary Yvette Cooper said: 

    As the Kremlin resorts to ever more shady tactics to sustain its war, from its ageing shadow fleet to covert finance networks, the UK remains one step ahead in shutting them down. 

    These sanctions strike at the heart of these murky efforts, to starve Putin’s war machine and defend Britain’s security. 

    Shoulder to shoulder with our G7 partners, the UK will stand with Ukraine for as long as it takes.

    Those who are suspected of enabling the sale of tankers to Russia’s shadow fleet will be exposed and face action. UK sanctions are greatly limiting Russia’s ability to trade oil – in 2025 the Arctic LNG-2 terminal only exported 1.3 million tons of LNG despite having capacity to export over 13.5 million tons a year.   

    To date, the UK has now sanctioned more than 600 shadow fleet and Russian LNG vessels. 

    New measures also expose and target a Russian military intelligence (GRU) network centred around GRU front company LLC Neptune Co Ltd (‘Neptune’).

    Neptune is involved in covertly procuring western technology for Russia’s military.

    Today’s actions target three companies and 10 GRU officers suspected of acquiring military technology that Russia desperately needs to sustain its military aggression in Ukraine.  

    Elsewhere, sanctions also hit third country suppliers of critical military equipment to Russia in China, Thailand and Türkiye. Several organisations helping Russia illegally move money, bypassing western sanctions, are also targeted including one entity in Nigeria supporting the illicit finance network A7’s sanctions evasions scheme.

    Gathering in Évian-les-Bains, G7 Leaders will discuss their joint determination to tackle the single largest threat to global security – Russia’s illegal war in Ukraine.  

    As the UK increases pressure on Russia’s war economy, today’s action demonstrates an unshakeable determination to defend security in Ukraine, Europe and at home.

    , ,
  • Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2026/9559192 issued

    General Licence INT/2026/9559192 has been issued. The General Licence permits defined persons to take any necessary steps to enable and enact the Interdiction.

    Any persons intending to use the General Licence should consult that Licence for full details of the definitions, permissions and usage requirements.

    Here’s the GL’s Publication Notice:

    and the General Licence:

    , ,
  • Sorry for the delay in filling out the set of guides…. I’ve done a bunch in the last week, and will roll them out over the next week or two…

    First, the Practitioner’s Guide:

  • Cuba Designation; Russia-related Designations Removals and Designation Update; Issuance of Amended Russia-related General Licenses and Frequently Asked Questions

    State Press Release: Sanctioning Cuba’s State-Owned Oil and Gas Company Unión Cuba-Petróleo

    In addition to the SDN List changes below, OFAC issued Russia-related General License 55F (“Authorizing Certain Services Related to Sakhalin-2”) and Russia-related General License 115D (“Authorizing Certain Transactions Related to Existing Civil Nuclear Energy Projects”), and amended eight Russia-related FAQs: 967, 978, 999, 1011, 1117, 1182, 1203, and 1216. The source page didn’t expose the underlying hyperlinks for these items, so they’re listed here without links.

    Additions:

    The following entity has been added to OFAC’s SDN List:

    OFAC Program: CUBA-EO14404 Executive Order 14404 (Cuba Sanctions)

    UNION CUBA PETROLEO

    • AKA: CUPET
    • Address: Avenida Salvador Allende No. 666, Entre Oquendo y Soledad, Havana 10300, Cuba
    • Organization Established Date: 25 Mar 1992
    • Target Type: State-Owned Enterprise
    • Entity Code: 2605 (Cuba)

    Supplemental Information: Per the State Department’s June 11, 2026 press statement, Treasury designated CUPET, Cuba’s state-owned oil and gas company, under Section 2(a)(i)(A) of E.O. 14404 (issued May 1, 2026) for operating in the Cuban energy sector. The statement notes that key CUPET assets had previously been expropriated from American owners. The action also supports the national emergency declared in E.O. 14380, addressing threats to the United States by the Government of Cuba, and NSPM-5. As a result, all CUPET property and interests in property within U.S. jurisdiction or in the possession or control of U.S. persons are blocked and reportable to OFAC, and any entity owned 50% or more by CUPET (individually or in the aggregate with other blocked persons) is also blocked. The State Department further warned that foreign persons dealing with CUPET — or operating in Cuba’s energy, defense and related materiel, metals and mining, financial services, or security sectors — face secondary sanctions risk under E.O. 14404, and that the existing CACR blocking provisions for Cuba remain in effect.

    Delistings:

    The following deletions have been made to OFAC’s SDN List:

    OFAC Program: RUSSIA-EO14024 Executive Order 14024 (Russia)

    MALTSEV, Sergey Aleksandrovich (Cyrillic: МАЛЬЦЕВ, Сергей Александрович), Russia; DOB 28 Feb 1973; POBSolikamsk, Perm, Russia; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024. (individual) (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

    RAYKES, Olga Borisovna (a.k.a. RAIKES, Olga Borisovna), 13/38 Tarmav Street, Rishon Lezion 7529025, Israel; Austria; Singapore; Pokrovka 35-17-1-17, Moscow 105062, Russia; DOB 25 Apr 1984; POB Ekaterinburg, Russia; nationality Russia; alt. nationality Israel; Gender Female; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport 759916267 (Russia) expires 28 Jan 2029; alt. Passport 32392042 (Israel) issued 16 May 2018 expires 15 May 2023 (individual).

    RAIKES, Olga Borisovna (a.k.a. RAYKES, Olga Borisovna), 13/38 Tarmav Street, Rishon Lezion 7529025, Israel; Austria; Singapore; Pokrovka 35-17-1-17, Moscow 105062, Russia; DOB 25 Apr 1984; POB Ekaterinburg, Russia; nationality Russia; alt. nationality Israel; Gender Female; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport 759916267 (Russia) expires 28 Jan 2029; alt. Passport 32392042 (Israel) issued 16 May 2018 expires 15 May 2023 (individual).

    Amendments:

    The following changes have been made to OFAC’s SDN List:

    OFAC Program: RUSSIA-EO14024 Executive Order 14024 (Russia)

    VEND ORE GMBH

    • Address: Novaragasse 55/4B, Vienna 1020, Austria
    • Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Organization Established Date: 26 Sep 2019
    • Linked to: SAVELOV, Marat Maratovich

    List of Changes:

    • Field Name: Linked To
      • Deleted: RAYKES, Olga Borisovna
    , , ,
  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 55F, “Authorizing Certain Services Related to Sakhalin-2;” and Russia-related General License 115D, “Authorizing Certain Transactions Related to Existing Civil Nuclear Energy Projects.”

    Additionally, OFAC is amending eight Russia-related Frequently Asked Questions, FAQs 967, 978, 999, 1011, 1117, 1182, 1203, and 1216.

    The GLs:

    and the FAQs:

    1216. What action has Treasury taken with regard to the provision of petroleum services to Russia? 

    In line with G7 efforts to reduce Russian revenues from energy, on January 10, 2025, Treasury issued a determination pursuant to Executive Order (E.O.) 14071 prohibiting petroleum services to Russia. See The Determination Pursuant to Sections 1(a)(ii), 1(b), and 5 of E.O. 14071, Prohibition on Petroleum Services (“the Petroleum Services Determination”). This determination prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, to any person located in the Russian Federation of petroleum services. The Petroleum Services Determination took effect at 12:01 a.m. eastern standard time on February 27, 2025. See FAQ 1217 for additional information.

    OFAC expects to issue regulations defining petroleum services to include services related to the exploration, drilling, well completion, production, refining, processing, storage, maintenance, transportation, purchase, acquisition, testing, inspection, transfer, sale, trade, distribution, or marketing of petroleum, including crude oil and petroleum products, as well as any activities that contribute to Russia’s ability to develop its domestic petroleum resources, or the maintenance or expansion of Russia’s domestic production and refining. This would include services related to natural gas as a byproduct of oil production in Russia.

    On October 22, 2025, OFAC issued GL 124A. In addition to continuing to authorize transactions prohibited by the Petroleum Services Determination related to the Caspian Pipeline Consortium (CPC) and Tengizchevroil, GL 124A also authorizes otherwise prohibited transactions related to the CPC and Tengizchevroil involving Lukoil, Rosneft, or any entity in which Lukoil or Rosneft owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. Additionally, on June 11, 2026, OFAC issued GL 55F, which extends authorizations for certain activities related to the Sakhalin-2 project that would otherwise be prohibited by the Petroleum Services Determination until December 18, 2026.

    The Petroleum Services Determination does not apply to (1) any petroleum services related to isotopes derived from petroleum manufacturing that are used for medical, agricultural, or environmental purposes, such as Carbon-13; (2) certain covered services related to the maritime transport of crude oil and petroleum products of Russian Federation origin purchased at or below the relevant price cap; and (3) any service in connection with the wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person. See FAQ 1217 for additional information related to price cap related exclusions of the Petroleum Services Determination.

    Date Updated: June 11, 2026

    Updated on Jun 11, 2026

    Russian Harmful Foreign Activities Sanctions

    1203. What does General License (GL) 115D (“Authorizing Certain Transactions Related to Civil Nuclear Energy”) authorize with respect to civil nuclear energy-related payments? 

    GL 115D generally authorizes certain transactions related to civil nuclear energy involving certain entities that are sanctioned pursuant to Executive Order 14024. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects and operations initiated or under construction as of November 21, 2024: the extraction, production, refinement, conversion, enrichment, fabrication, transport, or purchase of uranium in any form; the production, generation, transmission, or exchange of nuclear power, fuel, or waste; and the operation of civil nuclear energy projects. However, GL 115D does not authorize, for instance, transactions involving certain sanctioned Russian financial institutions related to the development of new civil nuclear energy power plants after November 21, 2024.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions for engaging in transactions with blocked persons, including transactions related to existing civil nuclear energy as described in GL 115D, where those transactions would not require a specific license if engaged in by a U.S. person. See GL 132 for authorizations related to the Paks II civil nuclear power plant project in Hungary.

    Updated: June 11, 2026

    Updated on Jun 11, 2026

    Russian Harmful Foreign Activities Sanctions

    1182. Are foreign financial institutions (FFIs) subject to sanctions risk for providing all financial services involving persons blocked pursuant to Executive Order (E.O.) 14024, as amended? What about agricultural, medical, and other transactions authorized by OFAC General Licenses? 

    Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia’s military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may continue to conduct or facilitate any transaction(s) or provide any service related to activities that are otherwise authorized or exempted under the Russian Harmful Foreign Activities Sanctions program. Foreign persons do not risk the imposition of sanctions for engaging in transactions authorized for U.S. persons under General Licenses issued under the Russian Harmful Foreign Activities Sanctions program.

    FFIs may continue to rely on Treasury’s existing authorizations in place for transactions related to agricultural commodities, medicine, medical devices and related replacement parts, components, or software updates, the Coronavirus Disease 2019 (General License (GL) 6D), certain civil nuclear energy-related transactions (GLs 115D and 132), certain transactions in support of non-governmental organizations (GL 27), official business of third-country diplomatic or consular missions located in the Russian Federation (GL 20), certain transactions and official business of certain international organizations and entities by employees, grantees, or contractors thereof (31 CFR 587.510). Additionally, the importation or exportation of information or informational materials and transactions ordinarily incident to travel to or from any country are exempt under the International Emergency Economic Powers Act (IEEPA).

    See OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks for additional guidance.

    Date Updated: June 11, 2026

    Updated on Jun 11, 2026

    Russian Harmful Foreign Activities Sanctions

    1117. My company provides goods or services to, or engages in trade with, persons that operate or have operated in the metals and mining sector of the Russian Federation economy. Does my company risk being sanctioned by OFAC? 

    The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. Non-U.S. persons may also be exposed to sanctions for activities with persons blocked pursuant to E.O. 14024 (see FAQ 980), including persons blocked following a determination that such persons operate or have operated in the metals and mining sector.

    However, OFAC does not intend to target persons for operating in the metals and mining sector where the provision of goods or services is solely for the safety and care of personnel, protection of human life, prevention of accidents or injuries, maintenance or repair necessary to avoid environmental or other significant damage, or activities related to environmental mitigation or remediation. Examples of such goods include personal protective equipment, safety devices, ventilation systems, and alarm systems; examples of such services include rescue and accident response services, cleaning, safety inspections, and services necessary for use of the goods described above.

    In addition, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, including in the metals and mining sector, where those transactions would not require a specific license if engaged in by a U.S. person. For example, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions for engaging in transactions in the metals and mining sector if such transactions would be authorized for U.S. persons by General License (GL) 115D (authorizing certain civil nuclear energy-related transactions) or by GL 6D (authorizing certain transactions related to the production, manufacturing, sale, transport, or provision of medicine or medical devices, including certain industrial isotopes used in nuclear medicine, among other things).

    Date Updated: June 11, 2026

    Updated on Jun 11, 2026

    Russian Harmful Foreign Activities Sanctions

    1011. My U.S. bank refused to process a requested payment related to energy despite the authorization in Russia-related General License (GL) 115D under Executive Order (E.O.) 14024. What can I do? 

    The Office of Foreign Assets Control (OFAC) encourages persons to connect with their financial institution regarding the status of any payment. In addition, persons with questions about engaging in or processing transactions related to GL 115D can contact the OFAC Compliance Hotline.

    Updated: June 11, 2026

    Updated on Jun 11, 2026

    Russian Harmful Foreign Activities Sanctions

    999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)? 

    OFAC issued Russia-related General License (GL) 132 to authorize transactions involving the Paks II civil nuclear power plant project in Hungary, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.

    OFAC issued Russia-related General License (GL) 115D to authorize civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive.

    OFAC issued GL 13Q to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. For further information on the types of transactions authorized by GL 13Q, see FAQ 1118.

    OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity’s sole function in the transaction is to act as an operator of a clearing and settlement system. GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction. In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity. See FAQ 1003.

    Note that GL 13QGL 14GL 115D, and GL 132 continue to authorize against the Russia-related Sovereign Transactions Directive.

    Date Updated: June 11, 2026

    Updated on Jun 11, 2026

    Russian Harmful Foreign Activities Sanctions

    978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 115D, or 132, what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024? 

    GLs 6D7A, or 115D, or 132 do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive). Consequently, in order for a U.S. financial institution to engage in transactions authorized under these GLs (e.g., a funds transfer related to energy), all such funds transfers must be processed indirectly through a non-sanctioned, non-U.S. financial institution.

    Examples of authorized and prohibited funds transfers under GLs 6D, 7A, 115D, and 132 include:

    Payment from third-country originator

    Authorized payment from third-country originator to beneficiary with an account at a sanctioned institution:

    Prohibited payment from third-country originator to beneficiary with an account at a sanctioned institution:
    Step process for prohibited payment starting from Third-Country Originator, to Third-Country Originating Bank, to U.S. Correspondent, to another U.S. Correspondent, to Target Entity, and finally to Beneficiary
     

    Payment from U.S. originator

    Authorized payment from U.S. originator to beneficiary with an account at a sanctioned institution:
    Step process for authorized payment starting from U.S. Person Originator, to U.S. Person Financial Institution, to U.S. Correspondent, to Third-Country Intermediary Bank, to Target Entity, and finally to Beneficiary

    Prohibited payment from U.S. originator to beneficiary with an account at a sanctioned institution:
    Step process for prohibited payment starting from U.S. Person Originator, to U.S. Person Financial Institution, to U.S. Correspondent, to Target Entity, and finally to Beneficiary

    In each of the above examples, the underlying funds transfer must be authorized under the applicable GL.

    Updated: June 11, 2026

    Updated on Jun 11, 2026

    Russian Harmful Foreign Activities Sanctions

    967. What does Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive) prohibit? 

    The Russia-related CAPTA Directive prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive. Please see the Russia-related CAPTA Directive for the definition of the terms “U.S. financial institution” and “foreign financial institution” for purposes of this directive. Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

    Annex 1 to the Russia-related CAPTA Directive lists the foreign financial institutions determined to be subject to the prohibitions as of March 26, 2022. Foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including the foreign financial institutions listed in Annex 1, can be found on the Office of Foreign Assets Control’s (OFAC) List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List). Relevant entries on the CAPTA List will denote when a foreign financial institution became subject to the prohibitions of the Russia-related CAPTA Directive, as well as when the prohibitions of the Russia-related CAPTA Directive come into effect with respect to that foreign financial institution.

    The below table identifies the dates the prohibitions of the Russia-related CAPTA Directive take effect for (i) foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive, and (ii) foreign financial institutions otherwise determined to be subject to its prohibitions and added to the CAPTA List.

    Foreign Financial Institution TypeRelevant Sanctions Effective Date
    Foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive12:01 a.m. eastern daylight time on March 26, 2022
    Foreign financial institution otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive12:01 a.m. eastern time on the date that is 30 days after the date of such determination

    U.S. financial institutions must close any correspondent or payable-through account maintained for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, by the relevant effective date. Separately, as of the relevant effective date, U.S. financial institutions may not process transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, and must reject such transactions unless exempt or authorized by OFAC.

    Accordingly, after the relevant effective date, U.S. financial institutions must reject any transaction involving a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive or involving that foreign financial institution’s property or interests in property. This includes rejecting transactions related to any securities (including depositary receipts) issued by a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including secondary market trading. By virtue of the prohibition on the processing of transactions for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, U.S. financial institutions are also prohibited from engaging in transactions with a covered foreign financial institution in connection with the foreign financial institution’s role as a local custodian for depositary receipt issuances.

    The Russia-related CAPTA Directive does not impose blocking sanctions and, thus, does not require U.S. financial institutions (or other U.S. persons) to block the assets of foreign financial institutions determined to be subject to the prohibitions of this directive. However, U.S. persons should be aware that foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662.

    OFAC has issued several Russia-related general licenses (GLs)authorizing certain transactions involving the foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive, including:

    • GL 6D: authorizing transactions related to (1) the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or (3) ongoing clinical trials and other medical research activities;
    • GL 7A: authorizing overflight payments, emergency landings, and air ambulance services;
    • GL 27: authorizing transactions in support of nongovernmental organizations’ activities; and
    • GL 115D: authorizing certain transactions related to civil nuclear energy.
    • GL 132: authorizing certain transactions involving Paks II civil nuclear power plant.

    On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.

    For additional information, please see FAQs 977978979981982 and 990.

    Date Updated: June 11, 2026

    Updated on Jun 11, 2026

  • Press Release:

    Disrupting Iran’s Weapons Procurement

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, SPOKESPERSON

    JUNE 10, 2026

    Today, the United States is imposing sanctions on thirteen individuals and entities based in Iran, Belarus, and China, including Hong Kong, that have sought to source and purchase weapons, including man-portable air-defense systems (MANPADS), on behalf of the Islamic Revolutionary Guard Corps (IRGC).  These designations follow our action on May 8, 2026, to disrupt procurement networks that support Iran’s military programs and degrade Iran’s ability to advance its military activities in the region.

    Today’s action supports the implementation of United Nations (UN) sanctions and restrictive measures on Iran, reimposed as a direct result of Iran’s “significant non-performance” of its nuclear commitments.  UN Security Council resolution 1929 requires UN Member States to prevent the supply, sale, or transfer of conventional weapons such as MANPADS to Iran.

    Consistent with the President’s National Security Memorandum 2 (NSPM-2), the United States continues to maintain maximum pressure on Iran and take actions to deny the IRGC and the government of Iran access to the resources that sustain their destabilizing activities.  The United States continues to use all available tools, to expose, disrupt, and counter Iran’s destabilizing activities and to stop Iran from efforts to reconstitute its proliferation-sensitive programs.

    The Department of State’s action was taken pursuant to Executive Order (E.O.) 13949, which targets certain persons with respect to the conventional arms activities of Iran.  The Department of the Treasury’s action was taken pursuant to E.O. 13382, which targets weapons of mass destruction (WMD) proliferators and their supporters, and E.O. 13902, which targets persons operating in Iran’s financial sector.  For more information on today’s actions, please see the Department of State’s fact sheet and Department of the Treasury’s press release.

    Fact Sheet:

    Disrupting Iran’s Weapons Procurement

    FACT SHEET

    OFFICE OF THE SPOKESPERSON

    JUNE 10, 2026

    Today, the Department of State is taking action to designate four Iran- and Belarus-based entities and individuals involved in the procurement of arms and related materiel intended to support Iran’s military.

    The United States, as directed in the President’s National Security Presidential Memorandum 2, is committed to disrupting procurement efforts supporting Iran’s military programs.  This action represents the commitment to stop Iran from engaging in activities related to the reconstitution of its proliferation-sensitive programs.

    All Department of State targets are being designated pursuant to Executive Order (E.O.) 13949, which targets certain persons with respect to the conventional arms activities of Iran.

    The Department of the Treasury is concurrently designating nine entities and individuals who have worked to procure weapons on behalf of Iran’s Islamic Revolutionary Guard Corps (IRGC).  For more information on these actions, please see the Department of the Treasury’s press release.

    Designations Pursuant to Section 1(a)(i) of E.O. 13949

    The Department is designating the following entity and individual pursuant to Section 1(a)(i) of E.O. 13949 for engaging in activity that materially contributes to the supply, sale, or transfer, directly or indirectly, to or from Iran, or for the use in or benefit of Iran, of arms or related materiel, including spare parts. 

    Armory Alliance

    Armory Alliance is a Belarus-based entity that has acted as an intermediary between China-based companies and Iran and has been involved in facilitating the purchase of hundreds of man-portable air-defense systems (MANPADS) and their shipment from China to Iran including attempting to route the shipments through third party countries and obfuscating their origin and true end-user.  The Department of the Treasury previously designated Armory Alliance pursuant to E.O. 13382 on May 8, 2026.

    Mohammadmahdi Maleki

    Mohammadmahdi Maleki is a Belarus-based Iranian individual who, as an employee of Armory Alliance has contributed to Armory Alliance’s efforts to procure weapons for benefit of Iran. The Department of the Treasury previously designated Mohammadmahdi Maleki pursuant to E.O. 13382 on May 8, 2026.

    Designating Pursuant to Section 1(a)(ii) of E.O. 13949

    The Department is designating the following entity pursuant to Section 1(a)(ii) of E.O. 13949 for having provided to Iran any technical training, financial resources or services, advice, other services, or assistance related to the supply, sale, transfer, manufacture, maintenance, or use of arms and related materiel described in subsection (a)(i) of section 1 of E.O. 13949. 

    Center for Innovation and Technology Cooperation

    Center for Innovation and Technology Cooperation (CITC) is an Iran-based government entity involved in the procurement of satellite imagery to support kinetic strikes by Iranian armed forces. CITC coordinated with the Iranian Ministry of Intelligence and Security (MOIS) about striking locations within and around a facility hosting U.S. armed forces in late March 2026.  The facility was subsequently targeted by an Iranian attack in late March 2026, resulting in the injury of U.S. service members.  Additionally, officials of CITC have approached China-based facilitators to attempt to procure weapons for use by Iran’s military.  Center for Progress and Development of Iran (CDPI) is the latest name of Iran’s CITC.  CITC was previously designated by the United States on July 12, 2012, pursuant to E.O. 13382.  MOIS was previously designated by the United States on February 6, 2012, pursuant to E.O. 13224 and E.O. 13553.  MOIS was also designated by the United States on April 22, 2012, pursuant to E.O. 1306; September 9, 2022, pursuant to E.O. 13694; and September 8, 2023, pursuant to E.O. 14078.

    Designating Pursuant to Section 1(a)(iii) of E.O. 13949

    The Department is designating the following individual pursuant to Section 1(a)(iii) of E.O. 13949 for having engaged, or attempted to engage, in any activity that materially contributes to, or poses a risk of materially contributing to, the proliferation of arms or related materiel or items intended for military end-uses or military end-users, including any efforts to manufacture, acquire, possess, develop, transport, transfer, or use such items, by the Government of Iran (including persons owned or controlled by, or acting for or on behalf of the Government of Iran) or paramilitary organizations financially or militarily supported by the Government of Iran. 

    Sajjad Ahadzadeh

    Sajjad Ahadzadeh (Ahadzadeh) is the head of CITC. Ahadzadeh has approached China-based facilitators, such as U.S.-designated China-based Yushita Shanghai International Trade Co Ltd (Yushita), to procure man-portable air-defense systems (MANPADS).  Ahadzadeh has attempted to facilitate the procurement of weapons and other arms and related materiel from China for use by Iran including through U.S.-designated Yushita.  Yushita was designated by the Department of the Treasury on May 8, 2026, pursuant to E.O. 13382.

  • Office of Financial Sanctions Implementation HM Treasury

    New FAQs added – Transneft ports, payments and insurance

    OFSI has published new FAQs (188-195) clarifying how UK financial sanctions apply in relation to Transneft and associated activity. These FAQs provide additional guidance to industry on how relevant prohibitions operate in practice, including when a licence may be required and how firms should approach compliance risks.

    The FAQs respond to stakeholder queries and aims to support a consistent understanding of the regime, helping to reduce the risk of circumvention. We encourage insurers, financial institutions and maritime operators to review the guidance and ensure internal processes reflect these considerations.

    Here they are:

    PJSC Transneft

    188. Does insuring a vessel calling at a PJSC Transneft owned or controlled port automatically engage UK sanctions?

    No.

    UK insurers providing insurance or reinsurance cover for vessels simply calling at PJSC Transneft-owned or controlled ports, in itself, is unlikely to engage UK financial sanctions.

    The fact that a UK insured vessel calls at a PJSC Transneft owned or controlled port does not, in itself, automatically engage UK financial sanctions. Although UK financial sanctions do not determine whether a vessel may call at a particular port, UK financial sanctions, however, may still apply to any financial activities connected with such voyages.

    Questions relating to port access, shipping routes, or trade restrictions fall outside the scope of UK financial sanctions and are governed by other regulatory frameworks.

    For guidance on assessing insurance claims, see FAQs 189-190.

    Added on: 11 Jun 2026

    189. What are some of the key considerations when assessing insurance claims and payouts relating to PJSC Transneft owned or controlled ports?

    Depending on the specific facts of the case, the key considerations are whether a payment under an insurance policy would engage the asset freeze prohibitions, for example regulations 12 and 13 of the Russia Regulations- making funds available to, or for the benefit of, designated persons, including PJSC Transneft.

    If so, a licence from OFSI would be required before any such payment can be made.

    Added on: 11 Jun 2026

    190. Can UK insurers pay claims that do not involve PJSC Transneft or PJSC Transneft owned or controlled ports?

    Whether or not such claims can be paid without an OFSI licence will depend on the circumstances and facts of the case.

    For example, although a payment may not result in a direct payment to a PJSC Transneft owned or controlled port/entity, firms must assess whether other UK asset freeze prohibitions are engaged, for example regulation 13 of the Russia Regulations- making funds available for the benefit of a designated entity, including PJSC Transneft.

    Firms must make their own assessment on whether any indirect benefit arises to a designated person or whether any of the other asset freeze prohibitions are engaged. 

    Added on: 11 Jun 2026

    191. Does compliance with EU or other sanctions regimes ensure compliance with UK sanctions?

    No.

    Compliance with EU or other sanctions regimes as it relates to PJSC Transneft should not be taken as evidence of compliance with UK financial sanctions. The UK maintains an independent sanctions framework, and firms must ensure full adherence to UK specific requirements.

    Added on: 11 Jun 2026

    192. Do payments made in connection with calling at a PJSC Transneft-owned or controlled port engage UK financial sanctions?

    Potentially.

    Primarily, there will have to be a UK nexus in relation to the payment(s). Once this has been established, payments such as port fees and terminal charges, amongst others, may engage UK financial sanctions if for example funds are made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations). 

    In such cases, the asset freeze prohibitions are likely to apply, and a licence from OFSI may be required. It is for firms (including UK shipowners, charterers or ship managers for example) to assess whether UK financial sanctions are engaged in relation to such payments.

    Added on: 11 Jun 2026

    193. Can UK financial institutions support transactions linked to voyages involving PJSC Transneft infrastructure?

    UK financial institutions (such as banks or other financial firms) must assess transactions on a case-by-case basis.

    Where a transaction would result in funds or economic resources being made available to, or for the benefit of PJSC Transneft, the asset freeze prohibitions are likely to apply (Regulations 12 and 13 of the Russia Regulations).

    Financial institutions should ensure they conduct appropriate due diligence and consider whether an OFSI licence is required before processing any such transaction.

    Added on: 11 Jun 2026

    194. Does the involvement of PJSC Transneft infrastructure (e.g. oil pipelines or storage facilities) automatically engage UK financial sanctions (where a UK nexus exists)?

    No.

    The mere involvement of PJSC Transneft infrastructure in a supply chain does not, by itself, automatically engage UK financial sanctions. However, firms must conduct their own assessment and apply for an OFSI licence should one be required, for example, where involvement of PJSC Transneft infrastructure will result in funds being made available to PJSC Transneft (Regulation 12 of the Russia Regulations).

    Added on: 11 Jun 2026

    195. Do UK financial sanctions apply to goods (e.g. oil) transported via Transneft infrastructure (e.g. pipelines)?

    Not automatically.

    UK financial sanctions are unlikely to be engaged solely because goods have been transported via infrastructure owned or controlled by a designated person (such as PJSC Transneft).

    However, the asset freeze prohibitions for example may be engaged where activities involving those goods (including payments for transport, storage or port services) result in funds being made available to, or for the benefit of, designated persons, including PJSC Transneft (regulations 12 and 13 of the Russia Regulations). Firms must conduct their own assessment on whether UK financial sanctions are engaged and apply for an OFSI licence should one be required.

    Added on: 11 Jun 2026

    Mr. Sanctions’ editorial note: It would be really, really nice if OFSI’s links went directly to the thing they reference. In this case, the link takes you to the start of the Russia FAQ section, even though there is a special heading for these Transneft FAQs. And when there is a sanctions update, that link takes you to a page where you then have to click again to get to the actual PDF. Yeah, it’s a comparatively small thing, but a blogger can dream, can’t he?