Today, Thursday 23 July, the UK Government has varied 2 designations and made 1 amendment, all sanctioned under the Russia Sanctions Regime.
Varied Individuals:
Amended Individual:
Name: Unique ID: Daria Sergeevna ROSLIAKOVA RUS3697
The Sanctions Notice:
New Visa Restriction Policy to Deter and Dismantle Cyberscams and Sextortion
PRESS STATEMENT
MARCO RUBIO, SECRETARY OF STATE
JULY 23, 2026
As President Trump made clear in E.O. 14390 on Combatting Cybercrime, Fraud, and Predatory Schemes Against American Citizens, his administration is taking action to counter an unprecedented threat from online investment scams. Often orchestrated by Chinese transnational criminal organizations, scammers have defrauded U.S. citizens of at least $10 billion in 2024 alone while fueling corruption, money laundering, and human trafficking. American children also have been specifically targeted by offenders operating overseas for sextortion scams, devastating families and futures.
Today, I am announcing a new global visa restriction policy under Section 212(a)(3)(C) of the Immigration and Nationality Act. This policy targets individuals responsible for, or complicit in, cybercrime and cyber-enabled crime, such as those involved in cyberscams, and sextortion. Immediate family members of individuals engaged in such illicit activities may also be subjected to visa restrictions.
The Trump Administration is deploying every tool at our disposal—sanctions, prosecutions, asset seizures, extradition requests, and international law enforcement cooperation—to dismantle criminal scam networks and impose costs on those who enable them. By restricting visa issuance to those who are responsible for or complicit in these criminal enterprises, we are sending a clear message: The United States will go after those who prey on our citizens.
The United Nations Security Council Subsidiary Organs Branch (the Secretariat) conveys updates to the Committees’ lists and to the United Nations Security Council Consolidated List, to States, regional and sub-regional organizations, and private entities/individuals by e-mail after updates are made to the Lists. At this time, not all documents are available in all languages.
The updates to the lists mentioned in the subject above were made on 22 July 2026.
To this effect, please see the United Nations Security Council Press Release.
Please see the note verbale addressed to Permanent Representatives and Observers to the United Nations in New York conveying the changes made.
An updated version of the United Nations Security Council Consolidated List is accessible in XML and HTML formats in all United Nations official languages at the following URL: United Nations Security Council Consolidated List | Security Council
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Best regards,
Security Council Subsidiary Organs Branch
Security Council Affairs Division
United Nations Department of Political and Peacebuilding Affairs
United Nations Secretariat
New York, NY 10017, USA
and here’s the note verbale referred to:
and the press release:
Security Council Committee concerning Libya Adds One Vessel to Its Sanctions List
On 22 July 2026, the Committee approved the addition of one entry specified below to its List of individuals and entities subject to the assets freeze, travel ban and other measures relating to attempts to illicitly export petroleum, including crude oil and refined petroleum products, from Libya (the Libya Sanctions List), set out in paragraphs 15 and/or 17 of Security Council resolution 1970 (2011) and/or paragraph 19 of resolution 1973 (2011), or paragraph 10 of resolution 2146 (2014) as amended by paragraph 2 of resolutions 2441 (2018) and 2509 (2020) and extended in resolution 2819 (2026), adopted under Chapter VII of the Charter of the United Nations:
B. Entities and other groups
LYe.006 Name: Avax
A.k.a.: na F.k.a.: na Address: na Listed on: 22 Jul. 2026 Other information: IMO: 9058713
Listed pursuant to paragraphs 10(a), 10 (b), 10(c) and 10(d) of resolution 2146 (2014), as amended by paragraph 2 of resolutions 2441 (2018) and 2509 (2020) and extended in resolution 2819 (2026) (prohibition to load, transport or discharge; prohibition to enter ports; prohibition to provide bunkering and vessel services; prohibition to engage in financial transactions with regard to petroleum). Pursuant to paragraph 11 of resolution 2146, as modified by paragraph 2 of resolution 2509 (2020), this designation is valid from 22 July 2026 to 22 July 2027, unless terminated earlier by the Committee pursuant to paragraph 12 of resolution 2146 (2014). Flag State: Cameroon. As of 4 April 2026, the vessel was located near the anchorage area of the Benghazi Old Harbour, Libya.The Committee has made accessible on its website the narrative summary of reasons for listing of the above entry, at the following URL: https://main.un.org/securitycouncil/en/sanctions/1970/materials/summaries.
The updated List is accessible on the Committee’s website at the following URL: https://main.un.org/securitycouncil/en/sanctions/1970/materials.
The Consolidated United Nations Security Council Sanctions List is also updated following all changes made to the Libya Sanctions List. An updated version of the Consolidated List is accessible via the following URL: https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list.
Notice of Changes to the Consolidated List – 23 July 2026
DFAT updated the Consolidated List on 23 July 2026 following receipt of advice from the United Nations Security Council Committee established pursuant to resolution 1533 (2004) concerning the Democratic Republic of the Congo. The UN advice is available here. The changes include:
- Addition of six individuals and two entities.
The updated Consolidated List can be downloaded from the following page: Consolidated List | Australian Government Department of Foreign Affairs and Trade. Guidance on how to interpret the Consolidated List can be found here: Guide to Australia ’s Consolidated List | Australian Government Department of Foreign Affairs and Trade
If you have any queries, please contact the Australian Sanctions Office at sanctions@dfat.gov.au.
Australian Sanctions Office
As a program new to GLs (at least recently), we have GL 2 (Authorizing the Wind Down of Transactions Involving CEIBA Investments Limited):
GL 3 (Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, CEIBA Investments Limited):
and GL 4 (Authorizing Transactions for Third-Country Official Missions in Cuba):
Note: Part 2 is being uploaded prior to Part 1 – due to the size of the update, Claude is taking quite a while making the draft post.
The prompt:
Summarize UK sanctions regulations and exemptions regarding Basic Needs Allowance, including any relevant definitions, in light of today’s FAQs, attached here. plesse provide your response for an audience of non-UK sanctions professonals who are not lawyers.
The final response:
Primary legislation. The Sanctions and Anti-Money Laundering Act 2018 (SAMLA, 2018 c.13) is the enabling statute for essentially all post-Brexit UK sanctions. It doesn’t itself list licensing grounds – it authorises Treasury/the Secretary of State to make regime-specific secondary legislation.
Regime-specific regulations. Each sanctions regime (Russia, Iran, Syria, Belarus, Chemical Weapons, and so on) has its own statutory instrument made under SAMLA – for example the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855). Each of these includes a schedule titled “Treasury licences: purposes,” which is the actual legal source of each licensing ground. I confirmed this schedule structure directly: in the Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 (SI 2019/618), Schedule 2, paragraph 2, “Basic needs” reads almost exactly as you’d expect:
To enable the basic needs of a designated person, or (in the case of an individual) any dependent family member of such a person, to be met.
For individuals, it lists medical needs, food, insurance premiums, tax, rent or mortgage, and utility payments as included needs. The Russia Regulations carry the equivalent ground at Schedule 5, paragraph 2, though I wasn’t able to pull the exact Russia-specific wording (only confirmed its existence and paragraph position via secondary indices) – the substance is consistent across regimes but the schedule number and paragraph numbering differ regime to regime, so it’s worth checking the specific regulation rather than assuming identical numbering.
Where basic needs sits among the other grounds. Per OFSI’s own “How to apply for a financial sanctions licence” guidance, the generally available licensing grounds are:
That page also confirms the general/specific licence mechanics I described earlier: general licences are issued by OFSI at its own initiative for a defined class of activity, and OFSI does not accept applications for them – you either fall within one or you apply for a specific licence.
This is the most useful find. OFSI’s “Designated Individuals Licensing Principles” (a policy document sitting under the General Guidance, last updated 2 February 2026) already contained a formal benchmark for basic needs, at Principle 4:
Licensing should permit basic needs, which OFSI considers to include the reasonable standard of living as compared to a person receiving the net UK median wage.
And Principle 4(a): “Ordinarily, Principle 4 will be generally satisfied by granting a designated individual the net UK median wage.”
That’s a striking match to today’s BNA FAQs, with one difference worth flagging as a genuine shift rather than a restatement: the February principle benchmarks to the net UK median wage (an individual figure), while today’s FAQ benchmarks to a median income household. A household benchmark is not the same number as an individual wage benchmark – it implicitly accounts for household composition and dependents in a way a flat wage figure doesn’t. I can’t tell you from the FAQ text alone whether that’s a deliberate policy refinement or just looser drafting, but it’s the kind of distinction worth watching for in OFSI’s next General Guidance update, since it would change the actual capped amount a DP receives.
Historical background, clearly caveated as background rather than confirmed lineage: In 2023, litigation against OFSI (Fridman v HMT, the first challenge to an OFSI licensing decision under the Russia Regulations) resulted in disclosure of a previously secret internal “Basic Needs Framework,” which split basic needs into “core needs” (proposed to be met by a flat monthly sum pegged to median wage) versus needs beyond that. The High Court dismissed the claim and confirmed OFSI retains “residual discretion to refuse to grant a licence, even if the conditions for the grant of a licence are met” – a principle that reappears in today’s FAQ as “compliance with those conditions does not guarantee that a licence will be renewed or varied.” Commentators at the time (Law Gazette, November 2023) explicitly called for OFSI to formalise exactly this kind of standing monthly allowance rather than handling it case by case. I can’t point to a document that explicitly says “BNA is the formalisation of the Basic Needs Framework” – but the throughline from the 2023 disclosure, to the February 2026 Designated Individuals Licensing Principles, to today’s FAQ is consistent enough that I think it’s a fair inference, not a stretch.
I tried to independently verify FAQs 197-202 on OFSI’s live FAQ page. The version I could retrieve carries a “last updated” stamp of 29 May 2026, predating your attachment’s 21 July 2026 date – so I couldn’t cross-check the exact text against a live, independently-fetched copy; I’m relying on your attachment as the primary source for the BNA-specific content itself. What I can confirm independently is that the FAQ numbering, format, and “Added on:” convention in your document are consistent with OFSI’s genuine, ongoing FAQ series (which runs to at least FAQ 186 in the version I retrieved), so the document is stylistically and structurally what it claims to be – I just can’t yet corroborate the specific new entries from a second, independent live source.
Primary legislation and regulations
OFSI guidance and policy
Commentary (context on the pre-BNA “Basic Needs Framework”)
6 FAQs added on Basic Needs Allowance (BNA)
OFSI has published FAQs 197-202 on Basic Needs Allowance (BNA) licences, which permit designated persons to access a capped monthly sum from frozen funds for essential living expenses. OFSI benchmarks the BNA against median household income. In many cases, including those involving high net worth individuals, the BNA will not provide for the continuation of a pre-designation standard of living.
FAQs 197-202 cover the purpose and scope of BNA licences, permitted expenditure, reporting requirements, treatment of monthly underspend, and how costs falling outside the BNA may be licensed separately.
The guidance is relevant to designated persons and any party facilitating payments under a BNA licence.
The FAQs:
Basic Needs Allowance
197. What is a basic needs allowance licence?
A Basic Needs Allowance (BNA) licence is a type of specific licence which OFSI may issue under the basic needs licensing ground across all non-counter-terrorism sanctions regimes. It permits a designated person (DP) to access a capped monthly sum from their otherwise frozen funds to meet essential day-to-day living expenses. OFSI benchmarks the allowance to reflect a median income household rather than the DP’s previous lifestyle or claimed expenditure. Rent or mortgage payments are considered separately from the BNA and assessed on a case-by-case basis.
Added on: 21 Jul 2026
198. What is the purpose of the basic needs allowance?
The basic needs allowance is intended to help ensure that a DP and any financially dependent family members can meet their day-to-day living costs, broadly in line with a median-income household. It is not intended to enable a DP to maintain the lifestyle, wealth, or business activities they enjoyed prior to designation.
DPs applying for or operating under a BNA licence should ensure that expenditure remains consistent with this purpose. Any party facilitating payments under a BNAlicence should similarly satisfy itself that the payments fall within the terms and purpose of the licence.
Added on: 21 Jul 2026
199. Do basic needs allowance licences include reporting requirements?
Yes. Basic needs allowance licences include reporting conditions requiring expenditure to be evidenced and reported to OFSI. This is a proportionate method that enables OFSI to maintain oversight of the usage of the licence and may inform any future decision when licences are renewed or varied.
Applicants should be prepared to comply with any reporting requirements imposed as conditions of a licence. Compliance with those conditions does not guarantee that a licence will be renewed or varied.
Added on: 21 Jul 2026
200. What can the basic needs allowance be spent on?
OFSI does not provide an exhaustive list of approved purchases. A DP has broad discretion, though not total, in how the allowance is used. That discretion is limited by the terms of the licence, the relevant sanctions regulations, and the purpose for which the licence is granted
The allowance is intended to cover goods and services that reasonably constitute basic needs. This may include (but is not limited to) food, clothing, personal hygiene, local transport, basic household items, and hairdressers. It does not cover expenditure that falls outside the terms of the basic needs licencing purpose, nor expenditure which would otherwise breach the financial sanction’s regime.
Some discretionary spending may be consistent with the terms of a BNA where it supports basic family life and remains proportionate to the benchmark of a median-income household. This may include recreation, education, leisure, and other miscellaneous goods and services. Whether such expenditure is appropriate will depend on the circumstances and must remain consistent with the purpose of the licence.
Added on: 21 Jul 2026
201. Does the basic needs allowance licence permit carry-over of any monthly underspend?
No. Each month’s allowance is a fixed, standalone cap. If a DP does not use the full allowance in a given month, the unspent amount cannot be carried forward or added to the following month’s allowance. The monthly cap resets at the start of each new month.
Added on: 21 Jul 2026
202. Does OFSI license costs separately that may fall outside of the core basic needs allowance?
Yes. Where a cost cannot reasonably be met from the basic needs allowance, OFSI may consider a separate licence application. Such applications are assessed on their individual merits and approval is not automatic.
OFSI will consider whether the relevant cost could reasonably be met from within the basic needs allowance. In particular, OFSI will assess whether the expenditure is of a type that a median-income household would ordinarily absorb through routine day-to-day spending.
Where a cost could reasonably be met from the basic needs allowance, OFSI would generally expect it to be funded from that allowance rather than licensed separately.
Applicants seeking separate licensing should therefore explain why the expenditure cannot reasonably be met from the basic needs allowance, how the relevant licensing purpose is met, and provide supporting evidence where appropriate. Applications can be submitted via OFSI’s application form at: OFSI launches online forms for reporting and licences – Office of Financial Sanctions Implementation.
Added on: 21 Jul 2026
Here’s the FINMA Notice:
Updated sanction message: Democratic Republic of Congo
The State Secretariat for Economic Affairs (SECO) has adopted an amendment to Annex 1 of the Ordinance of 22. June 2005 on measures against the Democratic Republic of the Congo (SR 946.231.12).
On the 16th In July 2026, the responsible UN Sanctions Committee amended the list of persons, companies and organizations sanctioned in this context. The change is directly applicable in Switzerland. SECO therefore, on the 17th July 2026 adapted the sanctions database SESAM (SECO Sanctions Management), which is relevant for Switzerland, and published the adjustment on its website.
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 update:
And the consolidated program list.
Russia-related Designations Updates
Amendments:
The following changes have been made to OFAC’s SDN List:
OFAC Program: RUSSIA-EO14024 Executive Order 14024
A T S HEAVY EQUIPMENT AND MACHINERY SPARE PARTS TRADING LLC
- AKA:
- ALWAHA ALSAFRA GENERAL TRADING L.L.C. (Arabic: الواحة الصفراء للتجارة العامة ش.ذ.م.م.)
- “ATS HEAVY EQUIPMENT”
- Address: Office 02, Span Precast, DIP 2, Dubai, United Arab Emirates
- Secondary sanctions risk: See Section 11 of Executive Order 14024.
- Organization Established Date: 23 Nov 2016
- License: 770917 (United Arab Emirates)
- Economic Register Number (CBLS): 10948598 (United Arab Emirates)
Supplemental Information: ATS Heavy Equipment was originally designated on December 12, 2023, alongside four other UAE-based firms – AMC Service FZE, Aspect DWC LLC, Griffon FZC, and Skyparts FZCO – for operating in the aerospace sector of the Russian Federation’s economy. Per Treasury’s press release announcing that action, the company had delivered a substantial volume of aircraft parts to Russia.
List of Changes:
- Field Name: AKA
- Added: ALWAHA ALSAFRA GENERAL TRADING L.L.C. (Arabic: الواحة الصفراء للتجارة العامة ش.ذ.م.م.)
- Field Name: Organization Established Date
- Added: 23 Nov 2016
LIMITED LIABILITY COMPANY PITERSNAB
- Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ ПИТЕРСНАБ
- Address:
- St. Repishcheva 14R, Saint Petersburg, Russia
- 13 Moskovskoe Highway, Saint Petersburg, Russia
- Parnas, 5th Upper Lane, 15, Saint Petersburg, Russia
- Per. 5-1 Verkhnii D. 15, Lit. A, Pomeshch. 5-N, Kom. 103, Saint Petersburg 194292, Russia
- Secondary sanctions risk: See Section 11 of Executive Order 14024.
- Organization Established Date: 01 Jun 2021
- Tax ID No.: 7802894972 (Russia)
- Registration Number: 1217800085470 (Russia)
List of Changes:
- Field Name: Cyrillic
- Added: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ ПИТЕРСНАБ
- Field Name: Address
- Deleted: Ul. Ordinarnaya D. 20, Lit. A, Pomeshch. 15-N, Rabochee Mesto #2, Saint Petersburg 197136, Russia
- Added: Per. 5-1 Verkhnii D. 15, Lit. A, Pomeshch. 5-N, Kom. 103, Saint Petersburg 194292, Russia
- Field Name: Organization Established Date
- Added: 01 Jun 2021
- Field Name: Tax ID No.
- Changed: 7813660013 (Russia) to: 7802894972 (Russia)
- Field Name: Registration Number
- Changed: 1227800000614 (Russia) to: 1217800085470 (Russia)
Sanctions practitioners routinely face three intertwined licensing problems: general licenses that overlap, authorizations that expire on hard deadlines, and the question of when a specific license is still required on top of a general one. Each reflects a core principle – an OFAC general license authorizes only what its text says, and nothing more.
Overlapping general licenses
A general license (GL) authorizes a category of transactions without any individual application to OFAC. Overlap arises when more than one GL could bear on the same transaction, and the practitioner must confirm which applies and whether each one’s conditions are satisfied.
The Russia program shows how GLs interlock. Russia-related GL 6D authorizes transactions related to the production, sale, transport, or provision of agricultural commodities, medicine, and medical devices. It is notable because, unlike most agricultural/medical authorizations, it is designed principally to permit these dealings even where an otherwise-blocked person is involved – clearing the blocked-counterparty obstacle for humanitarian-type goods.
But GL 6D’s reach is bounded by its own paragraph (c), which excludes several things even for otherwise-covered goods: opening or maintaining a correspondent or payable-through account for any entity subject to Directive 2 under E.O. 14024; any debit to a U.S.-institution account of the Central Bank of the Russian Federation, the National Wealth Fund, or the Russian Ministry of Finance; and transactions prohibited by E.O. 14066, 14068, or 14071 (subject to narrow carve-outs). So an authorized medical-device sale whose payment leg runs through a Directive 2 correspondent account is not cleared by GL 6D alone – that leg needs its own authorization. OFAC reinforces the point in its guidance: the agricultural/medical authorizations do not extend to prohibitions applied to persons sanctioned under other OFAC authorities.
The practice point is that general licenses are not additive by default. Each authorizes only what its text says, subject to its own conditions and exclusions. Where a transaction has two problematic features – a blocked counterparty and an excluded payment channel, or a second program’s designation – each feature needs its own authorization.
Expiring authorizations
Many general licenses, particularly wind-down authorizations, carry hard expiration dates and times. OFAC’s standard convention is 12:01 a.m. eastern on the stated date. Once that moment passes, the transaction reverts to prohibited unless another authorization applies.
The June 12, 2024 designation of Russia’s core financial-market infrastructure illustrates the mechanics, including how staggered the deadlines can be. Alongside blocking a group of entities, OFAC issued a cluster of wind-down GLs:
- GL 98 authorized wind-down of transactions involving the entities blocked that day, through 12:01 a.m. EDT on July 27, 2024.
- GL 99 and GL 100 authorized wind-down, divestment, and related debt/equity transactions involving MOEX, NCC, and NSD, through August 13, 2024.
- Those two were subsequently extended by GL 99A and GL 100A to October 12, 2024.
A payment authorized the day before a GL’s deadline is prohibited the day after; the authorization does not roll over. Because these deadlines do not move in lockstep – GL 98 expired more than two weeks before GLs 99 and 100 – practitioners track each separately.
The practice point is that wind-down GLs authorize the termination of pre-existing dealings, not new business. OFAC has been explicit that wind-down activities do not include the continued processing of funds transfers, securities trades, or other transactions involving a blocked person that were part of ongoing business prior to the imposition of sanctions, unless separately authorized.
When a specific license is still required “on top”
The clearest illustration of a specific license required on top of a general one comes from the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) framework in the Iranian Transactions and Sanctions Regulations (ITSR), because the residual specific-license requirement is written into the licensing architecture itself rather than triggered by an exception.
Section 560.530 of the ITSR sets out a favorable general license for the export and reexport of agricultural commodities, medicine, and medical devices to Iran. But the general license does not stand alone – its own text conditions the authorization. The export is authorized provided that, unless otherwise authorized by specific license, payment terms and financing are limited to, and consistent with, those authorized by § 560.532.
Section 560.532, in turn, generally authorizes only a defined menu of payment mechanisms: cash in advance; sales on open account (where the receivable is non-transferable); financing by non-U.S., non-Iranian third-country financial institutions (which U.S. institutions may confirm or advise); or a letter of credit issued by an Iranian financial institution whose property is not blocked. A practitioner who needs payment or financing terms outside that menu is not covered by the general license – and a specific license is required on top of the general authorization that already covers the goods.
The same structure recurs across the agricultural/medical provisions. Under § 560.533, brokering is authorized only where the underlying sale is itself authorized, either by a one-year specific license under § 560.530(a)(1)(i) or by one of the general licenses in § 560.530(a)(2), (a)(3), or (a)(4); brokering by U.S. persons on behalf of non-U.S., non-Iranian persons may be permitted only by case-by-case specific license. Sections 560.530, 560.532, and 560.533 are meant to be read together: one governs the export, one the payment and financing, one the brokering.
A separate dimension is cross-agency. An OFAC authorization does not resolve a licensing requirement administered by another federal agency. OFAC says so in the licenses themselves – the note to Russia-related GL 25D, for instance, states that nothing in the general license relieves any person from compliance with the export, reexport, and transfer licensing requirements maintained by the Department of Commerce’s Bureau of Industry and Security under the Export Administration Regulations. An OFAC GL and a BIS/EAR authorization are distinct; satisfying one does not satisfy the other.
The practice point is that a general license never obligates OFAC to grant a related specific license. OFAC evaluates specific-license applications case-by-case against the relevant program’s stated licensing policy.
The common thread
All three problems reduce to the same discipline: read the general license against the specific transaction, feature by feature. Identify every prohibited element – the counterparty, the goods, the payment channel, the timing, the agency whose rules are implicated – and confirm that some authorization covers each one. A general license that resolves one obstacle does not resolve the others, its authorization ends when its text says it ends, and where the license’s own terms carve out a category, the specific-license process is the path.
Sources: 31 CFR §§ 560.530, 560.532, 560.533 (ITSR); Russia-related General Licenses 6D, 8J, 25D, 98, 99, 100 (89 FR 65994, Aug. 14, 2024) and 99A/100A; OFAC Russian Harmful Foreign Activities Sanctions FAQ topic page.
