While Claude is chugging through the massive update today (a press chart, 2 Treasury PRs, 3 State PRs, and a fact sheet), I’m going to post the other part…
First, Russia-related General License 131I (Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities):
And OFAC updated 2 related Russian Frequently-Asked Questions again – 1224:
1224. What negotiations does Russia-related General License 131I authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?
Answer
On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131I, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131I expires on September 19, 2026.
GL 131I does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131I must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.
As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.
OFAC may revoke GL 131I at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.
OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128C and GL 131I. The GLs are similar but have different expiration dates and terms as each serves a different purpose.
To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C to extend the existing authorization until October 29, 2026.
To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, GL 131H, and GL 131I, to extend the existing authorization until September 19, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.
GL 128C and GL 131I expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128C and GL 131I. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128C and GL 131I authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.
Both GL 128C and GL 131I also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.
Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128C and GL 131I. Similarly, non-U.S. persons may rely upon GL 128C and GL 131I regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128C and GL 131I, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.
1265. On August 20, 2026, the Department of State designated the Ministry of Construction of Cuba (MICONS) pursuant to E.O. 14404. Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with MICONS?
Answer
The U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, through September 19, 2026. However, non-U.S. persons, including FFIs, should proceed with caution in any dealings with a party sanctioned under this authority. Actions to return assets to a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.
Foreign persons unable to wind down transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, before September 19, 2026, are encouraged to contact the OFAC Compliance Hotline.
Persons subject to U.S. jurisdiction, including U.S. persons and entities owned or controlled by U.S. persons, should additionally note that this limited non-targeting posture does not authorize any transaction prohibited by the Cuban Assets Control Regulations (CACR), 31 CFR part 515, or any other OFAC sanctions authority. Persons subject to U.S. jurisdiction have long been prohibited from transacting with MICONS, including in connection with a non-U.S. person’s wind down of activities with MICONS, absent OFAC authorization. Relevant authorizations may include humanitarian-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1. For additional information on GL 1, see FAQ 1253.
The Trump Administration has been clear: the International Criminal Court (ICC) is a corrupt and fatally politicized supranational court that has maliciously abused its authority and exceeded its mandate. We will not tolerate its assault on state sovereignty.
In furtherance of the diplomatic campaign we launched last month to address the ICC’s abuses of power, I am designating two ICC officials – President of the ICC, Tomoko Akane of Japan, and ICC Senior Trial Lawyer, Abdoulaye Seye of Senegal – pursuant to Executive Order 14203, “Imposing Sanctions on the International Criminal Court.” These individuals have directly engaged in efforts by the ICC to investigate, arrest, detain, or prosecute officials whose government has not consented to ICC jurisdiction.
The ICC has repeatedly attempted to assert authority over nationals of the United States and other countries that have not consented to its jurisdiction or ratified the Rome Statute. This sets a dangerous precedent for all nations.
Our whole of government campaign to dismantle the threat posed by the ICC to national sovereignty will be sweeping and we expect more countries to join our campaign by ending their funding and participation in this politicized and unaccountable court. The ICC’s ability to target American nationals and those of other non-States Parties must end. The Trump Administration stands ready to take additional measures, if necessary, to systematically dismantle the ICC until it is incapable of threatening American sovereignty.
These individuals are being designated pursuant to section 1(a)(ii)(A) of Executive Order (E.O.) 14203.
Regulations Amending the Special Economic Measures (Iran) Regulations
Whereas the Governor in Council is of the opinion that the actions of the Islamic Republic of Iran constitute a grave breach of international peace and security that has resulted or is likely to result in a serious international crisis;
Therefore, Her Excellency the Governor General in Council, on the recommendation of the Minister of Foreign Affairs, makes the annexed Regulations Amending the Special Economic Measures (Iran) Regulations under paragraph 4(1)(a)a and subsections 4(1.1)b, (2)c and (3) of the Special Economic Measures Actd.
a S.C. 2022, c. 10, s. 438(1)
b S.C. 2017, c. 21, s. 17(2)
c S.C. 2023, c. 26, ss. 254(2) to (4)
d S.C. 1992, c. 17
Amendment
1 Part 2 of Schedule 1 to the Special Economic Measures (Iran) Regulations1 is amended by adding the following in numerical order:
Ali Abdollahi (born in 1959) (also known as Ali Abdollahi Aliabadi)
Ebrahim Zolfaghari
Ebrahim Azizi (born on June 22, 1963)
Hamid Hosseini
Shahram Irani (born in 1967)
Application Before Publication
2 For the purpose of paragraph 11(2)(a) of the Statutory Instruments Act, these Regulations apply according to their terms before they are published in the Canada Gazette.
Coming into Force
3 These Regulations come into force on the day on which they are registered.
1 SOR/2010-165
Mr. Sanctions’ Note: Why bother listing parties if all you’re going to provide is the name? How do you expect people to resolve matches? Or is this just performative? Just sayin’
Count the EU’s Russia packages by designations added and you learn almost
nothing. Package 21 alone carried 218 listings, the largest single batch in four
years, and not one of them changed how a screening program works. What changes
your program is a new kind of restriction: a category of counterparty you now
have to test for, a contract term you now have to insert, a service you can no
longer provide.
By that measure the twenty-one packages contain roughly two dozen genuinely
distinct restriction types, and they did not arrive evenly.
One note on where this starts. The EU has had Russia sanctions since 2014,
and the post-Crimea framework already limited Russian bank and corporate access
to European capital markets. Package 1 extended that framework rather than
inventing it, and the same is arguably true of parts of the early export
controls. The 2022 measures are different enough in scale and in kind to be
worth treating on their own terms, which is what this article does, but the
baseline was not zero.
Note: this is a long article. A PDF version is available for download at the end, and it adds an appendix listing the amending regulation behind each of the twenty-one packages.
Package 1 restricted Russian access to EU capital and financial markets
(Regulation 2022/262). Package 2 opened the export control front, covering goods
and technology for defence, aviation and space, and oil refining (Regulation
2022/328).
Package 3 is the consequential one. It banned transactions with the Central
Bank of Russia, cut seven banks off the SWIFT financial messaging network, and
closed EU airspace to Russian aircraft (Regulation 2022/334, extended by
2022/345, 2022/350 and 2022/394).
Package 4 added three measures (Regulation 2022/428). The first banned new
investment in Russia’s energy sector. The second barred imports of Russian iron
and steel. The last prohibited exports of luxury goods.
Timing matters here in a way it rarely does later. The Central Bank measure
landed on 28 February, four days into the invasion, alongside parallel US and UK
action. That simultaneity was the point. A reserve freeze telegraphed in advance
is a reserve freeze that gets moved.
Why it mattered
The immediate effect was severe and short-lived. The ruble fell from roughly
80 to 120 per dollar within two weeks. Russia’s central bank raised its key rate
from 9.5 percent to 20 percent on 28 February.
Within about two months the currency had recovered to pre-invasion levels.
Capital controls, a requirement that exporters convert 80 percent of their
foreign currency earnings, and a demand that energy buyers pay in rubles did
most of that work. Analysts have generally read this as the financial shock
being absorbed rather than proving decisive. Roughly €300 billion in Russian
central bank reserves sat frozen across the EU, other G7 states and Australia,
about two-thirds of it in the EU, but Russia’s current account surplus kept
climbing on continued energy sales.
The EU’s approach already differed from Washington’s in one visible way. It
deliberately left Sberbank and Gazprombank off the SWIFT cutoff, because those
were the payment channels for European gas. The United States had no equivalent
reason to carve anyone out.
Switzerland aligned almost immediately, a real departure from its historical
posture. It did so by mirroring EU measures through its own Ukraine Ordinance
rather than adopting them directly, and that mechanism would later produce
timing gaps that still cause trouble. Belarus was pulled in from package 3
onward, establishing the mirroring pattern that has held since.
Packages 5-9: building the sectoral toolkit
April to December 2022
This is where the sectoral measures were built.
Package 5 carried four distinct measures (Regulation 2022/576). It closed EU
ports to Russian vessels and barred Russian road hauliers from EU territory. Coal
imports were banned outright. And this package introduced the first restriction
on crypto assets, capping what Russian persons could hold.
Package 6 delivered the crude oil and refined products import ban, the
measure that took longest to negotiate (Regulation 2022/879). The ban reached oil
arriving by sea but excluded oil delivered to the EU through pipelines, an
exemption Hungary, Slovakia and Czechia still operate under. The same package
brought the first professional services ban, covering accounting, audit,
bookkeeping and consulting.
Package 7 banned gold imports and extended the port access ban to locks
(Regulation 2022/1269).
Package 8, in October 2022, did two things that would define the following
four years (Regulation 2022/1904). It created a listing criterion aimed
specifically at people facilitating circumvention, which meant the EU could now
designate someone for helping others evade sanctions rather than for any
underlying conduct. The same package established the oil price cap. Less
prominently, it also widened the services bans to architectural, engineering, IT
consultancy and legal advisory work (Article 5n).
Package 9 closed the year with a ban on new investment in Russian mining and
a prohibition on advertising and market research services (Regulation
2022/2474).
Why it mattered
The revenue effect was real and measurable. The Council reported Russian
revenues down 26.9 percent in January 2023 against January 2022, and down 41.7
percent in February. The Council’s explanation of these figures is somewhat
vague, but they most likely refer to oil and gas revenues. The February number
is the one most plausibly connected to package 6, since the refined products ban
and the price cap only took effect on 5 February 2023.
The price cap is the more interesting story, because it is the clearest case
of a sanctions measure generating its own countermeasure. The cap was designed
to keep Russian oil flowing to global markets while limiting what Russia earned
from it, and it worked through leverage over Western shipping and insurance.
Russia’s answer was to assemble a fleet of older tankers under opaque ownership
and arrange insurance outside the coalition, so the shipping and insurance
leverage the cap depended on no longer reached the trade. The shadow fleet went
from essentially nothing to carrying most Russian crude within about two
years. Elisabeth Braw has argued publicly that Western governments would not
have imposed the cap had they anticipated that outcome, which is a strong claim
but not an unreasonable one.
The cap is also the most genuinely coalition-built instrument of the entire
effort, agreed across the G7, the EU and Australia. That agreement did not
extend to enforcement. The United States leaned on the threat of secondary
sanctions against foreign financial institutions that handled capped oil. The EU
leaned instead on its jurisdiction over the shipping and insurance companies
themselves. Same cap, different levers, and third-country intermediaries learned
quickly which one bit harder.
Packages 10-13: the circumvention turn
February 2023 to February 2024
Four packages over a full year, and almost everything in them is aimed at closing the routes goods were taking around the restrictions already in place, rather than at adding new targets. These packages also refined measures already on the books in three places.
Package 10 banned transit of dual-use goods and arms through Russian territory (Regulation 2023/427). Package 11 extended that transit ban and formalised cooperation with third countries (Regulation 2023/1214).
Package 12 introduced three measures worth singling out (Regulation 2023/2878). The first is the “no-Russia clause”, which requires EU exporters to write a contractual prohibition on re-export to Russia into their sales agreements (Article 12g). The second is a ban on providing enterprise management and industrial design software. The third is a reporting requirement for outbound transfers above €100,000 by EU companies owned or controlled by Russian persons. Package 12 also banned imports of Russian diamonds, along with LPG and several metals, which is a story in itself and taken up below.
Package 13, at the two-year mark, was mostly additional sanctions designations (Regulation 2024/745). It added 194 individuals and entities and took the total past 2,000. But two things in it pointed forward.
The first was a widening of export controls. Aluminium electrolytic capacitors went onto the list of goods that could strengthen Russia’s military and technological base (Annex VII Part B). Electrical transformers, static converters and inductors went onto the separate list of goods that could build up Russian industry generally (Annex XXIII, Article 3k). That second list had previously covered three specific tariff codes. Package 13 replaced them with the entire tariff heading that sits above those codes, so every transformer, converter and inductor became controlled rather than three named types. For an exporter, that is the difference between checking a code list and re-screening a product line. Existing contracts had until 25 May 2024 to complete.
The second was the addition of 27 entities to the list carrying stricter dual-use and advanced technology export restrictions (Annex IV). Those designations reached into mainland China, India, Sri Lanka, Serbia, Kazakhstan, Thailand and Turkey.
The no-Russia clause, and why it has no US twin
The no-Russia clause deserves attention because it is an EU original. Washington’s route to the same problem runs through the BIS Entity List and the foreign direct product rules. The Entity List is the Bureau of Industry and Security’s roster of foreign parties that US exporters need a licence to ship to, with those licences generally presumed denied. The foreign direct product rules extend US licensing authority to goods manufactured outside the United States when they were made using US technology or equipment, which is how Washington reaches transactions with no American party in them at all.
Brussels went the other way. It pushed the obligation into private contracts, making the exporter responsible for a term in a sales agreement. Neither approach has obviously won. The EU version is cheaper to administer and harder to enforce. The US version is the reverse.
Diamonds, and the limits of provenance
The diamond ban deserves its own treatment, because it shows what happens when a restriction depends on where something came from rather than who paid for it.
Russia is the world’s largest diamond producer by volume, at roughly a third of global supply. Alrosa accounts for over 90 percent of Russian production, and the Russian state holds a majority stake in it, split between the federal government and the Republic of Sakha (Yakutia), the region of eastern Siberia where the mines sit, together with that republic’s districts. Diamond revenue therefore reaches the Russian state rather than private shareholders. In absolute terms the target is small. Alrosa’s 2023 results put the business at around $3.5 billion, a rounding error against hydrocarbons.
The cost to Antwerp was more visible. Belgium imported roughly €1.8 billion of Russian rough diamonds in 2021, about a quarter of its total rough imports. That fell to around €1.4 billion in 2022 and to €288 million in the first half of 2023, most of the decline arriving before the ban did. The Antwerp World Diamond Centre argued throughout that an EU-only ban would be dramatic for Antwerp and produce no impact on Russia, because trade would simply reroute through Dubai and Mumbai.
Belgium’s position is the interesting part. Rather than resisting, it ended up leading the coordination, on the reasoning that serving as the world’s Russian-diamond laundromat was doing more damage to Antwerp’s standing than a ban would do to its trade.
India is where enforcement actually lives. Over 90 percent of the world’s diamonds are cut and polished there, and Alrosa supplied around 40 percent of India’s rough imports. A ban on Russian-origin stones only means something if Indian polishers segregate Russian goods from everything else, which is why G7 delegations went to India in September 2023 to make the case. The EU’s answer was to require that rough diamonds of half a carat or more be certified through Antwerp from September 2024, with the record kept on a blockchain ledger. Smaller stones fell outside the requirement.
Then the coalition came apart. The United States disengaged from the G7 traceability working groups after pushback from African producers, Indian polishers and New York jewellers. A Biden administration official’s position was that the September 2024 commitment bound the EU rather than the United States. The polished-diamond traceability deadline slipped from 1 March 2025 by ten months, and Botswana was added as a second verification hub alongside Antwerp.
That is a sharper illustration of the pattern than anything in the financial measures. Everyone agreed on the target. Only the EU built the verification regime.
Russian countermeasures become a compliance problem
This is also when Russian countermeasures stopped being defensive and became something screening and legal teams had to account for.
Presidential Decree 302 of April 2023 created a mechanism for placing assets of companies from “unfriendly states” under external management. It was used. Carlsberg and Danone are the well-known examples.
In parallel, Russian claimants began using Article 248 of the Arbitrazh Procedure Code to pull disputes into Russian courts in breach of arbitration agreements. The results included the seizure of roughly $155.8 million of JPMorgan funds on VTB’s application, and a freeze of around $1.15 billion of assets held by a UK subsidiary of Linde.
For EU companies still holding Russian assets, this is when exit became materially more expensive than staying.
Switzerland was still keeping close pace, completing its package 10 alignment on 29 March 2023, about a month behind.
Packages 14-17: shadow fleet and the third-country pivot
June 2024 to May 2025
Package 14 is the densest single package in the entire set of measures (Regulation 2024/1745). It banned LNG re-exports and new investment in Russian LNG projects. Use of the Central Bank’s SPFS financial messaging system, Russia’s domestic alternative to SWIFT, was outlawed. The same package created a port access and services ban aimed at vessels supporting the war, which is the first version of what became the shadow fleet regime. Least noticed at the time, it also built a litigation and expropriation shield, letting EU companies claim damages in member state courts from Russian parties that benefited from expropriation (Articles 11a and 11b).
Package 15 completed that last thought by making Russian court judgments obtained under Article 248 unrecognisable and unenforceable in the EU (Regulation 2024/3192).
Packages 16 and 17 were mostly additional sanctions designations, but with a telling shift. Of the 53 entities added to export restrictions in package 16, roughly two-thirds were located in third countries (Regulation 2025/395). Package 17 added chemical precursors and 189 more vessels, taking the listed total to 342 (Regulation 2025/932).
Why it mattered
This is where the EU stopped writing rules about Russia and started writing rules about everyone else who deals with Russia. The third-country listing shift matters operationally more than the vessel counts. A screening hit on a Kyrgyz, Emirati or Hong Kong trading company is now a routine outcome rather than an anomaly.
The shadow fleet data is the most useful evidence available on whether any of this works, and it points somewhere specific. Alignment beats aggression. Robin Brooks’ analysis of tanker departures found activity in vessels sanctioned jointly by the United States, EU and UK down about 90 percent year over year, against 86 percent for US-only designations. The gap is small, but the direction matches what practitioners see. A vessel designated in one jurisdiction shops for ports. A vessel designated in three runs out of them.
The litigation shield is worth flagging as a genuine novelty. Sanctions regimes normally regulate what their own persons may do. Articles 11a and 11b instead create a private right of recovery against Russian beneficiaries of expropriation, which is closer to a tort remedy than a restrictive measure. No other major regime has copied it.
Switzerland’s lag started lengthening here. Package 16 was adopted on 24 February 2025 and implemented on 14 May 2025.
Packages 18-21: the energy endgame and the crypto build-out
July 2025 to July 2026
Energy tightened on every remaining front.
Package 18 lowered the oil price cap and, more significantly, set it to adjust periodically under the terms of the relevant Council Decision rather than sitting at a fixed number (Regulation 2025/1494). It also banned imports of refined products made from Russian crude, regardless of where the refining took place.
Package 19 banned LNG imports outright (Regulation 2025/2033). It also prohibited transactions involving Mir and the Faster Payments System, known as SBP. Mir is Russia’s domestic card scheme, built after 2014 precisely so that being cut off from Visa and Mastercard would not stop domestic payments. SBP is the central bank’s instant payments system. Prohibiting them closes the retail payment channels that survived the SWIFT measures.
Package 20 banned the provision of services to Russian LNG terminals and imposed due diligence obligations on tanker sales (Regulation 2026/506). Package 21 extended the terminal services ban to third-country operators controlled by Russian companies (Regulation 2026/1848).
The second development is crypto becoming a separate target category in its own right, rather than an incidental restriction attached to other measures.
Package 5 capped the value of crypto assets Russian persons could hold. Package 8 banned providing crypto wallets to them outright. Package 20 went considerably further, prohibiting transactions with crypto-asset service providers and platforms established in Russia, and naming RUBx, a ruble-pegged stablecoin, as a specific target (Article 5bb). Package 21 added a prohibition on Russian citizens and residents owning, controlling or holding positions in EU crypto-asset service providers, effective 25 August 2026.
The price cap is the clearest case in the whole set of a restriction that kept being re-tuned after it was imposed. Package 18 set it to adjust on a periodic basis. Package 21 then suspended that adjustment for a full year, to July 2027, loosening a measure the EU had built specifically so that it would keep tightening without further decisions.
That is the kind of regulatory detail that disappears when a package is summarised by its number of sanctioned designations.
October 2025: same targets, three different rules
Three jurisdictions moved on Russia’s two largest oil companies inside nine days, using three different legal instruments.
Date
Jurisdiction
Action
Mechanism
15 Oct 2025
UK
Rosneft and Lukoil designated, with 88 other targets
Asset freeze. OFSI licensed certain German Rosneft subsidiaries through at least October 2027, in coordination with German authorities, so those refineries could keep operating.
22 Oct 2025
US
Rosneft, Lukoil and more than 30 subsidiaries designated
SDN listing under EO 14024, pulling in the 50 percent rule and exposing foreign financial institutions to secondary sanctions risk.
23 Oct 2025
EU
Package 19 adopted
Full transaction ban on Rosneft and Gazprom Neft under Article 5aa, applying the EU’s own ownership and control test.
Same companies, same week, three different legal hooks. A screening team covering all three regimes got three different answers about the same corporate family in the same month.
Does any of it work
The evidence is genuinely contested, and the research organizations disagree with each other.
The evidence that oil is still moving despite the designations is substantial. As of mid-June 2026, the United States, UK, EU, Australia, Canada and New Zealand had collectively designated 653 unique tankers. Analysis from earlier in the year found 111 of the 623 then-designated vessels still loading Russian cargo, and G7-plus sanctioned tankers carrying roughly 68 percent of Russian crude exports. KSE put Russian oil export revenues at $20.8 billion in April 2026, down slightly month over month but $8.2 billion above the prior year.
The evidence pointing the other way is thinner but real. Russian reliance on Western maritime services climbed back to around 42 percent by May 2026, and new shadow fleet entrants slowed to a trickle across 2026. Both suggest vessel designations have made the shadow route expensive enough to push cargo back under the price cap’s reach.
Both can be true. Designating vessels one at a time degrades the alternative faster than it stops the trade. CREA has argued the entity-based approach is too easily defeated by intermediaries and special purpose vehicles, and has pushed for a full maritime services ban instead. Package 20’s groundwork for exactly that suggests the argument landed.
Two other developments
In December 2025 the EU moved to freeze Russian central bank assets in Europe indefinitely rather than on a renewable basis. That is a change in the character of the measure, not just its duration, and it has drawn commentary about longer-term effects on how other states think about holding reserves in European institutions.
Switzerland’s lag became a live compliance problem. Package 19 was adopted on 23 October 2025. Swiss implementation was partly done on 12 December 2025 and only completed on 25 February 2026. Baker McKenzie noted plainly that the delay created legal uncertainty for firms operating across both jurisdictions, and that the pattern is likely to repeat.
All twenty-one, grouped
Twenty-one packages, and the pattern is hard to miss once it is laid out. Everything the EU uses today was invented in the first ten months. The four years since have been spent extending those measures to new counterparties, new routes and new intermediaries.
There is a useful corollary for anyone tracking alignment with other regimes. Gaps between the EU, United States and UK appear when someone invents a mechanism, not when someone extends one. The moment a new tool is created is the moment the other jurisdictions either copy it or decline to, and the diamond traceability regime is the clearest example. Packages that extend existing measures rarely change the alignment picture, because whatever alignment there was got settled when the measure was first built.
The practical implication is that a new package is not by itself news. The question is what kind of change it contains. If all that changed is more names on the list, your existing screening already absorbs it. If there is a new kind of restriction, meaning a contract term you have to insert, a class of counterparty you now have to test for, or a service you can no longer provide, that is the one where somebody has to read the annex.
Sourcing and self-check
Documented, traceable to primary or official sources. Every package’s contents, adoption date and amending regulation number come from the Council of the EU’s package timeline, the Official Journal, and the Council’s own press releases. The Council’s timeline page was last reviewed on 23 April 2026 and therefore stops at package 20. Package 21 content comes from the Council’s 23 July 2026 press release and from law firm and P&I club analyses published since. Central bank reserve figures and the January and February 2023 revenue decline percentages are the Council’s own published numbers. The 28 February 2022 rate move from 9.5 to 20 percent and the ruble’s move from roughly 80 to 120 per dollar are contemporaneous reporting. Swiss implementation dates are from SECO decrees as reported by Lenz & Staehelin and Baker McKenzie. The October 2025 Rosneft and Lukoil actions and their differing legal bases are from Covington, Sullivan & Cromwell, Arnold & Porter and McDermott alerts. Diamond trade figures are from IPIS and Reuters reporting.
Secondary analysis, flagged as such. The shadow fleet effectiveness figures of 90 percent against 86 percent are Robin Brooks’ calculation from his own vessel database. Vessel counts, revenue figures and the share of exports carried by sanctioned tankers come from KSE Institute, CREA and GSSC, which use different methodologies over different reporting periods and do not fully agree with each other. The claim that the price cap caused the shadow fleet is widely held but not formally established, and the Braw remark is an argument rather than a finding. CREA’s call for a full maritime services ban is advocacy, though package 20’s language suggests the EU is moving that way.
Editorial judgment, not anyone’s official framing. The six-category taxonomy and the decision about what counts as a distinct restriction type rather than an extension of an existing one are mine. Reasonable practitioners would draw some of these lines differently.
Known gaps. Belarus is treated here as a mirroring jurisdiction rather than as an actor in its own right, and the Belarus packages are not traced individually. The parallel EU regimes covering hybrid threats, human rights and riot control agents are outside scope except where they intersect, and the boundary between “the Russia package” and “the other measures adopted the same day” has been getting blurrier since package 17.
and now, a PDF which might be easier for you to digest:
1257. Are non-U.S. persons exposed to sanctions for dealing with digital asset exchanges designated pursuant to Executive Order 13902, “Imposing Sanctions with Respect to Additional Sectors of Iran” (E.O. 13902)?
Answer
Yes. OFAC’s designation of Nobitex, Wallex, Bitpin, Ramzinex, Aban Tether, or any digital asset exchange pursuant to Executive Order (E.O.) 13902 for operating in the Iranian financial sector means that foreign financial institutions and other non-U.S. persons who transact with these exchanges may also face sanctions under E.O. 13902 or other Iran-related authorities. For example, pursuant to E.O. 13902, OFAC has authority to:
Designate persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of any digital asset exchange designated pursuant to E.O. 13902; or
Prohibit or impose strict conditions on correspondent account or payable-through account opening or maintenance by foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for or on behalf of any digital asset exchange designated pursuant to E.O. 13902.
Foreign financial institutions may be exposed to statutory sanctions for engaging in significant financial transactions with any designated Iranian financial institutions, including Nobitex, Wallex, Bitpin, Ramzinex, and Aban Tether, pursuant to the National Defense Authorization Act of Fiscal Year 2012. Please see FAQ 174 for more information.
For more information on Iranian digital asset exchanges being blocked under OFAC sanctions, please see FAQ 1250.
The United States is taking decisive action to cut the financial lifelines that sustain Iran’s ruling elite. Today, the U.S. Department of the Treasury took steps to dismantle a web of currency exchange houses and shell companies that helped Iran secretly move hundreds of millions of dollars through the international financial system. Through these networks, Tehran accessed oil revenue and evaded sanctions designed to curb its destabilizing activities, laundering funds using front companies.
This action demonstrates the Trump Administration’s continued maximum pressure on Iran by cutting off resources the regime uses to threaten regional stability, support terrorism, and advance its military capabilities. By targeting the banks, exchange houses, and individual facilitators that operate this illicit system, the United States makes clear that those who help Iran evade sanctions will face serious consequences.
The United States remains committed to working with partners across the region and the world to close every avenue Iran uses to fund its destabilizing activities. As the regime’s economic mismanagement and corruption become increasingly apparent to the Iranian people, actions like today’s further isolate the regime from the international financial system and reinforce that Iran’s continued support for terrorism and regional aggression will carry a steep and lasting cost.
Today’s action is being taken pursuant to Executive Order (E.O.) 13902, which targets persons operating in Iran’s financial and petroleum sectors, and advances the President’s National Security Presidential Memorandum 2 (NSPM-2), to impose maximum pressure on Iran. This is OFAC’s eighth action in 2026 targeting Iran’s shadow banking apparatus, including Iranian banks and their rahbar front companies, exchange houses and their managers, major financiers, and the Iranian importers and exporters who rely on these financial networks to launder and repatriate revenues. Please see the Department of the Treasury’s press releases.
but I have not gotten anything from OFAC yet – even checked the Recent Actions page.
But the press release page already has 2 things with today’s date:
so, stay tuned? I’ll include both Treasury releases when we get the official stuff from OFAC (since my prompt includes the relevant info with the specific designations)
As a general matter, U.S. sanctions under E.O. 14404 are not focused on disrupting the delivery of food, medicine, or medical devices to Cuba. The U.S. government does not intend to target non-U.S. persons under E.O. 14404 for engaging in transactions related to the provision, directly or indirectly, of agricultural commodities, including food, as well as medicine, medical devices, replacement parts and components for medical devices, and software updates for medical devices, to Cuba. This non-targeting posture includes those described humanitarian-related transactions that involve a person designated pursuant to E.O. 14404, or entities in which such persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
Consistent with humanitarian authorizations related to agricultural commodities, medicine, and medical devices issued by the Office of Foreign Assets Control (OFAC) for other sanctions programs under the International Emergency Economic Powers Act (IEEPA), OFAC interprets those terms for purposes of E.O. 14404 as follows:
Agricultural commodities: Agricultural commodities are products that fall within the term “agricultural commodity” as defined in section 102 of the Agricultural Trade Act of 1978 (7 U.S.C. 5602) and are intended for use as:
Food for humans (including raw, processed, and packaged foods; live animals; vitamins and minerals; food additives or supplements; and water) or animals (including animal feeds);
Seeds for food crops;
Fertilizers or organic fertilizers; or
Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food animals.
Medicine: Medicine is an item that falls within the definition of the term “drug” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).
Medical devices: A medical device is an item that falls within the definition of “device” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).
Any U.S. person involvement in such transactions must comply with authorizations and requirements in Cuba-related General License (GL) 1. See FAQ 1253 for additional information on GL 1. As of August 2026, the U.S. government is working to operationalize $100 million in humanitarian assistance directly to the Cuban people, delivered through independent organizations operating under appropriate authorizations, including those operating as contractors or grantees on official U.S. government business.
For non-U.S. persons engaged in humanitarian-related activity that may fall outside the scope outlined in this Frequently Asked Question, OFAC considers requests on a case-by-case basis, prioritizing those requests that are related to humanitarian activity. Non-U.S. persons may contact the OFAC Compliance Hotline with additional information.
Today, Thursday 6th August, the UK Government has designated the following individual and 12 entities, and specified the following 6 ships, under the Russia (Sanctions) (EU Exit) Regulations.
Foreign Secretary Ed Miliband steps up UK action against Russia, with new sanctions targeting the Kremlin’s military machine, oil and gas revenues and ageing shadow fleet.
Government continues to support Ukraine after the Prime Minister and Foreign Secretary welcomed President Zelenskyy to the UK last week.
Russian banks, shadow fleet ships and shady businesses have been slapped with UK sanctions for their role in Russia’s barbaric war on Ukraine.
In his first major sanctions package, Foreign Secretary Ed Miliband has reinforced the UK’s commitment to the people of Ukraine by announcing new measures against those supporting the Kremlin’s war effort.
The package targets individuals and businesses enabling Russia’s war in Ukraine, further constraining the networks and revenue streams on which the Kremlin relies.
Among the 19 targets sanctioned today are six Russian banks propping up its war economy, six newly acquired shadow fleet tankers responsible for dodging Western sanctions and four Russian companies importing tantalum and niobium, rare metals critical for producing military equipment used on the battlefield in Ukraine.
Foreign Secretary Ed Miliband said:
Today’s new sanctions demonstrate the UK’s unwavering commitment to supporting Ukraine and bearing down on those propping up the Kremlin’s aggression.
Ukraine’s fight is our fight. Those that threaten Ukraine’s freedom and democracy are a threat to Britain’s security at home. That’s why we will continue stepping up the pressure on Russia until a just and lasting peace has been reached.
Today’s action further builds on the Foreign Secretary’s work on Ukraine since taking office. In recent weeks he has held his first bilateral call in the role with Foreign Minister Sybiha, attended the ASEAN conference in Manila where discussions focussed on support for Ukraine and joined the Prime Minister in Portsmouth last week to host President Zelenskyy, where the UK announced support for cutting-edge drone capabilities to bolster Ukraine’s frontline defences.
Yesterday the Foreign Secretary travelled to Washington DC where he met US Secretary of State Marco Rubio. Discussions focused on efforts to maintain pressure on Russia and underlined that Ukraine’s security is inseparable from European and transatlantic security.
Chancellor John Healey MP said:
Our commitment to stand with the Ukrainian people is absolute.
That’s why we’re introducing new tougher sanctions to choke off the funds that fuel Putin’s illegal war and are targeting his shadow fleet.
And the UK will continue to step up our action against Russia and its shadow fleet activity to protect our national security, our economy, and global stability.
This year alone the UK has imposed sanctions on over 500 individuals, entities and ships under its Russia sanctions regime, and today’s decisive action sends a clear signal that the UK will not let up on its efforts to hold Russia to account and support Ukraine for as long as it takes.
The UK government has now sanctioned over 3,400 individuals, entities and ships under the Russia sanctions regime. The latest measures form part of the UK’s ongoing effort to defend European and NATO security and weaken Russia’s ability to continue waging war in Ukraine.
In a historic and decisive action in support of President Trump’s mission to eliminate narco-terrorist cartels threatening the American people, the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs is announcing reward offers under the Narcotics Rewards Program (NRP) and Transnational Organized Crime Rewards Program (TOCRP) totaling up to $102 million for information leading to the arrests and/or convictions, in any country, of eight leaders and associates of Cártel de Jalisco Nueva Generación (CJNG). These rewards are offered in coordination with the DOJ, DEA, FBI, HSI, IRS, CBP, and the National Coordination Center.
Last year, the Trump Administration designated CJNG as a Foreign Terrorist Organization (FTO) and a Specially Designated Global Terrorist (SDGT). CJNG is among the most violent and dangerous narco-terrorist organizations in our Hemisphere, and poisons American communities with illicit fentanyl, cocaine, heroin, and methamphetamine.
The reward offers include up to $25 million (an increase from up to $5 million) for Juan Carlos Valencia González, a.k.a. “Pelón,” the new leader of CJNG following the recent death of his stepfather, CJNG founder Nemesio Rubén Oseguera Cervantes, a.k.a. “El Mencho”; up to $15 million (an increase from up to $5 million) for Audias Flores Silva, a.k.a. “Jardinero”; up to $15 million each for Gonzalo Mendoza Gaytán, a.k.a. “Sapo,” and Oseguera Cervantes’ son-in-law, Julio Alberto Castillo Rodríguez, a.k.a. “Chorro”; up to $10 million each for Ricardo Ruiz Velasco, a.k.a. “Tripa,” Julio César Montero Pinzón, a.k.a. “El Tarjetas,” and Carlos Andrés Rivera Varela, a.k.a. “La Firma”; and up to $2 million for Griselda Margarita Arredondo Pinzón. These reward offers support our U.S. law enforcement partners in crippling the organization’s leadership.
Additionally, the Department is imposing visa restrictions on 65 individuals who are family members or close personal or business associates of persons linked to CJNG (who have been sanctioned under Executive Order 14059, Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade). Twenty-six of those individuals had existing visas, which have now been revoked. Since announcing this visa restriction policy in June 2025, a total of 93 visas have been revoked from family members and associates of sanctioned drug traffickers connected to FTO-designated cartels. Under President Trump and Secretary Rubio’s leadership, violent cartel operatives and their criminal facilitators are no longer able to enter our country and terrorize the American people.
Today’s reward offers complement the Department of Justice’s announcement of the unsealing of charges against Mendoza Gaytán, Castillo Rodríguez, Ruiz Velasco, Montero Pinzón, and Rivera Varela.
Today’s reward offers are authorized by the Assistant Secretary for International Narcotics and Law Enforcement Affairs under the NRP, which supports law enforcement efforts to disrupt transnational drug trafficking globally and bring fugitives to justice, and the TOCRP, which supports law enforcement efforts to disrupt transnational organized crime globally. The NRP, which was established in 1986, celebrates its 40th anniversary this year and, along with its sister program, the TOCRP, has brought more than 90 transnational criminals and major narcotics traffickers to justice and paid out more than $200 million for information leading to apprehensions and other qualifying outcomes.
If you have information on Valencia González, Mendoza Gaytán, Castillo Rodríguez, or Ruiz Velasco, please contact the DEA by phone at 1-213-237-9990 (text/WhatsApp/Signal/Threema) or by email at CJNGtips@dea.gov. If you have information onMontero Pinzón,Rivera Varela, or Arredondo Pinzón, please contact the FBI by phone at 1-800-CALL-FBI or 212-384-1778 (WhatsApp), or online at http://www.fbi.gov/cjngrewardtips. If you have information on Flores Silva, please contact HSI by phone at 866-347-2423 or online at https://www.ice.gov/tips. If you are located outside of the United States, please contact the nearest U.S. Embassy or Consulate. If you are in the United States, please contact the local DEA, FBI, or HSI office in your city.
ALL IDENTITIES ARE KEPT STRICTLY CONFIDENTIAL. Government officials and employees are not eligible for rewards for information furnished while in the performance of his or her official duties.
well, OFAC is also a strict liability regime – all who touch the transaction have violated the regulations, but the consequences, if any, vary according to the Enforcement Guidelines. So, OFAC just balances the scales differently, wouldn’t you say?
Claude responded:
Yes — and that’s a genuinely better way to put it than how it was left last message, so it’s worth correcting rather than defending the weaker version.
The mechanics check out
OFAC’s civil liability is strict: a violation exists the moment a blockable transaction occurs, full stop — OFAC need not prove fault or intent to bring an enforcement action and issue a civil penalty, and a civil penalty can be assessed even if the violator had no idea they were dealing with a sanctioned party. What actually happens next is calibrated entirely by the Enforcement Guidelines at 31 CFR Part 501, Appendix A — egregious versus non-egregious, voluntary self-disclosure, willfulness or recklessness, quality of the compliance program, awareness of the conduct, harm to program objectives. So the fault inquiry hasn’t been discarded, it’s just been relocated to the remedy stage instead of the liability stage. “Balances the scales differently” describes that far more precisely than the earlier “bets on speed vs. bets on accuracy” line, which overstated the contrast.
And here’s the part that actually strengthens the parallel rather than just conceding it: the UK made exactly this same move. For breaches committed on or after 15 June 2022, OFSI can impose civil monetary penalties on a strict liability basis, regardless of the absence of knowledge or a reasonable cause to suspect — before that date, OFSI had to show knowledge or reasonable cause to suspect on the balance of probabilities. So the “we wait for fault before we act” framing offered earlier doesn’t even hold up as a clean description of the UK’s own penalty regime anymore. Knowledge and intent still matter there, but now as a severity factor within OFSI’s case assessment, not as a threshold for liability — the same architecture as OFAC’s General Factors.
So where does the real difference actually live now?
Not in whether fault matters — both regimes have converged on “fault affects the size of the punishment, not whether a violation occurred.” It survives in what strict liability is allowed to reach. OFAC’s fault-blindness attaches to an immediate, automatic property action: the money gets locked up the moment the objective trigger exists, and that seizure doesn’t reverse just because a later fault inquiry clears the customer — unblocking still requires its own separate license. The UK’s 2022 reform, notably, didn’t build an equivalent mechanism. It made it easier to fine someone for the underlying conduct without proving they knew — but it stopped there. It didn’t create a parallel power to seize Customer A’s payment while that question gets sorted out, because there’s still nothing belonging to the designated person to seize in Scenario A, for the reasons worked through earlier.
That’s actually a more interesting finding than where things were left before: it isn’t that UK-style regimes are squeamish about strict liability in general — 2022 proves they aren’t. It’s that they’ve kept strict liability confined to punishing conduct after the fact, and never extended it into a mechanism for provisionally seizing an uninvolved party’s property before fault is even alleged. OFAC does both.