Monthly Sanctions Update (June 2026)

///Monthly Sanctions Update | June 2026

KEY DEVELOPMENTS

· Enforcement related to Russia: OFSI published a £1,000,920.59 penalty against Sabre Global Technologies Limited, the UK’s largest financial sanctions penalty since Russia’s 2022 invasion of Ukraine and OFSI’s first penalty involving circumvention; HMRC announced a £569,157 compound settlement with Petrofac Facilities Management Limited; and OFAC announced a $1,050,000 settlement with FTI Consulting, Inc.

· Russia sanctions packages and renewals: The UK announced 70 further Russia sanctions targeting shipping actors linked to oil and LNG, military procurement networks and sanctions evasion finance organisations; the EU listed 34 individuals and 47 entities in connection with Russia’s war against Ukraine; and the EU renewed its economic sanctions against Russia until 31 July 2027.

· Other global designations: US measures targeted Cuban revenue generating entities, DRC armed group and mineral smuggling networks, digital asset exchanges linked to Iran, LPG shipping and procurement networks, and procurement and recruitment networks related to Sudan.

· Regulatory, licensing and guidance updates: OFSI issued or amended Russia related general licences concerning interdiction activity, Lukoil International and Prince Group insolvency activities; added FAQs on transferable securities, PJSC Transneft and the Lukoil General Licence; and published, with OFAC, comparative guidance on the UK and U.S. sanctions regimes.

GLOBAL SANCTIONS

Cuba

· On 23 June 2026, the US Department of State announced further sanctions targeting the Cuban regime’s revenue generation network pursuant to Executive Order 14404. The measures include the designation of five Cuban entities and one individual alleged to generate revenue for, or otherwise support, the Cuban regime. The newly designated entities comprise Almacenes Universales S.A. (AUSA), Rafin S.A., and Banco Financiero Internacional S.A., all of which are affiliated with the previously designated military controlled conglomerate Grupo de Administración Empresarial S.A. (GAESA). The Department of State also designated Geominera S.A., a state owned mining company, and Empresa Siderúrgica José Martí, Cuba’s largest producer of raw steel. In addition, Annalie Lilliam Rueda Cardero, a member of the extended Castro family, was designated.

DRC

· On 2 June 2026, OFAC designated Gustave Kubwayo, also known as “Colonel Sirkoof”, and John Imani Nzenze under the DRC sanctions regime. Kubwayo is described by OFAC as a commander of an intelligence and special operations unit within the Democratic Forces for the Liberation of Rwanda, while Nzenze is described as a commander and chief of intelligence of the March 23 Movement.

· On 25 June 2026, OFAC sanctioned a Rwanda based network alleged to have worked with the Rwanda backed March 23 Movement to smuggle minerals from eastern DRC into Rwanda. The designations include Gasabo Gold Refinery LTD, Jean Malic Kalima Karekezi, Bosco Kayobotsi, Bugambira Mines LTD, Wolfram Mining and Processing LTD, and Rwinkwavu Mining Corporation LTD. OFAC stated that Gasabo acted as a key partner in sourcing and transporting gold from areas of South Kivu occupied by RDF/M23, with at least 60kg of gold allegedly moved from eastern DRC to the refinery in early 2026.

Iran

· On 2 June 2026, OFAC designated Rahkar Fanavari Nooyan, also known as Nobitex, Iran’s largest digital asset exchange, together with several other Iranian exchanges, including Khalgh Sarvat Sarzamin Parseh, also known as Wallex, Sana Ayman Mubadala, also known as Bitpin, and Ramzineh Electronic Commerce Innovation Company, also known as Ramzinex. OFAC also designated several Nobitex officials, including Amir Hossein Rad, its chairman and cofounder. OFAC stated that Nobitex processed more than half of all Iranian digital asset inflows in 2025 and facilitated transactions linked to the Islamic Revolutionary Guard Corps, sanctions evasion and ransomware activity.

· On 5 June 2026, OFAC designated a network alleged to have shipped Iranian origin liquefied petroleum gas to South and East Asia while disguising it as Omani origin LPG. Key targets included alleged network operators Sarbaz Abdul Zada and Mohammad Shakol Mihandoust, also known as “Haji Shakoor”, together with trading companies based in the UAE and China involved in the alleged scheme. OFAC also designated several vessel owning or operating companies and identified a number of LPG tankers as blocked property, including MD 23, GLENDALE, AMIR GAS, GAS LAGOON, MILE, and GAZ GMS. Separately, OFAC designated Mehrdad Geramian Nik and Partners Company, an Iranian exchange house alleged to have processed illicit financial transactions connected to Iranian oil revenue.

· On 10 June 2026, OFAC designated a procurement network based in China and Hong Kong alleged to have supported weapons procurement for Iran’s Islamic Revolutionary Guard Corps and Ministry of Defense and Armed Forces Logistics. Key targets included Chinese nationals Liu Boyu, Wang Hongyi and Xu Lichun, as well as Mustad Shanghai International Trade Co Ltd and Domus Trading HK Limited. OFAC also designated a Hong Kong based company alleged to operate within Iran’s clandestine banking network. The measures were imposed under Executive Orders 13382 and 13902.

Russia

· On 1 June 2026, OFAC announced a $1,050,000 settlement with FTI Consulting, Inc. concerning apparent breaches of U.S. sanctions targeting Russia’s financial sector. The matter concerned FTI’s work for the benefit of VTB, where invoices were routed indirectly and, on six occasions between April 2019 and May 2021, either remained outstanding or were paid after the permitted 14 day payment period. OFAC treated this as indirect dealing in prohibited debt. The apparent violations were found to be not egregious and were not voluntarily disclosed.

· On 15 June 2026, the Council of the EU imposed further sanctions in connection with Russia’s ongoing war against Ukraine, listing 34 individuals and 47 entities. The package focuses on parties said to support Russia’s war economy, including suppliers of drones and military equipment, actors connected to the transport of Russian oil, and those involved in pro Russian influence activity. It also includes listings linked to serious human rights concerns in Russia, including matters connected with the poisoning of Alexei Navalny. The Council also decided to extend the EU’s Crimea and Sevastopol sanctions framework until 23 June 2027.

· On 16 June 2026, the UK Government announced 70 further Russia sanctions aimed at networks supporting Russia’s war effort. The package covers vessels and shipping linked actors connected to Russian oil and LNG activity, including more than 20 oil tankers and several LNG vessels linked to the Arctic LNG 2 project. It also targets a GRU linked procurement network alleged to have sought Western technology for Russia’s military, third country suppliers of military equipment, and organisations involved in moving funds in ways said to bypass sanctions.

· On 17 June 2026, OFSI published details of a £1,000,920.59 monetary penalty imposed on Sabre Global Technologies Limited (“SGTL”) for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019, the UK’s largest penalty for financial sanctions breaches since Russia’s 2022 invasion of Ukraine. The penalty related to SGTL’s continued provision of travel technology services to Ural Airlines after its designation in May 2022, the making of funds and economic resources available to or for the benefit of a designated person, and the testing of alternative payment routes after sanctions concerns had been raised. OFSI assessed the case as “most serious”, including because SGTL actively circumvented UK financial sanctions, and applied a 20 percent discount to reflect SGTL’s voluntary disclosure and settlement under OFSI’s transitional settlement arrangements.

· On 25 June 2026, the Council of the EU renewed the EU’s economic sanctions against Russia for a further 12 months, until 31 July 2027. The measures, first introduced in 2014 and expanded significantly following Russia’s full scale invasion of Ukraine in 2022, cover areas including trade, finance, energy and dual use technology. They also include restrictions on Russian seaborne crude oil and certain petroleum products, transaction bans affecting financial institutions and crypto service providers, and measures aimed at addressing sanctions circumvention.

· On 29 June 2026, HMRC announced that Petrofac Facilities Management Limited had paid a £569,157 compound settlement in relation to breaches of Russia sanctions regulations. The breaches took place in 2022 and 2023 while the company was winding down its Russian operations, and concerned the supply of sanctioned industrial goods to persons connected with Russia, as well as related technical assistance. PFML self reported the breaches and cooperated with HMRC’s investigation. HMRC also stated that PFML is the first company to be publicly named by HMRC after accepting a compound settlement, reflecting a new approach under which naming may be included as a condition of settlement for strategic export and sanctions offences.

Sudan

· On 26 June 2026, OFAC designated eight individuals and entities linked to procurement and recruitment networks supporting the Sudanese Armed Forces and the Rapid Support Forces. The designations include Target Multiactivities Company Ltd., SBL Energy Limited, Ports Engineering Company LTD, and individuals connected to Talent Bridge, S.A., a Panama based company linked to the recruitment of former Colombian military personnel for the RSF. The measures were imposed under Executive Order 14098, which targets persons destabilising Sudan and undermining its democratic transition.

GLOBAL REGULATIONS / TOOLS UPDATE

General Licences

· General Licence INT/2026/9559192: On 12 June 2026, OFSI issued General Licence INT/2026/9559192 under the Russia (Sanctions) (EU Exit) Regulations 2019. The licence permits persons contracted or directed by HMG to take necessary steps to enable and enact an “Interdiction”, defined as action taken to facilitate, enable or otherwise support HMG’s exercise of legal powers to enforce possible breaches of the Russia Regulations. It also permits certain related payments, including payments made for the benefit of a designated person where this is solely for the purpose of enabling and enacting the interdiction, and permits Relevant UK Institutions to process payments made in accordance with the licence. The licence took effect from 12 June 2026.

· General Licence INT/2025/8031092: On 19 June 2026, OFSI amended General Licence INT/2025/8031092, which permits certain otherwise prohibited activities to enable the continuation of business involving Lukoil International GmbH and its subsidiaries. The amendment removed the restriction previously set out in paragraph 4.2, under which certain funds to which Lukoil International or its subsidiaries were entitled were required to be paid into a frozen account. OFSI has clarified that the amendment does not permit funds to be returned to PJSC Lukoil. The licence currently expires on 25 August 2026.

· General Licence INT/2026/9491628: On 24 June 2026, OFSI amended General Licence INT/2026/9491628, which permits certain otherwise prohibited insolvency related payments and activities connected with the Prince Group and its subsidiaries. The amendment revises the definition of “Permitted Insolvency Activities” to permit the making, receiving or processing of payments, and other actions connected with insolvency proceedings, where conducted at the direction of, or with the consent of, an Insolvency Practitioner, provided that no funds or economic resources are made available to, or for the benefit of, any designated person other than a Prince Group DP or Subsidiary. The licence took effect from 14 April 2026, was amended on 24 June 2026, and expires on 13 April 2031.

FAQs

· On 8 June 2026, OFSI added FAQ 187 to its UK Financial Sanctions FAQs, addressing how the “date of issue” should be assessed for transferable securities and money market instruments under the Russia and Belarus sanctions regimes. The FAQ explains that instruments issued before the relevant dates are not prohibited from being dealt with solely on that basis, provided no other sanctions prohibitions are engaged. Where a new security or instrument is created in connection with a security issued earlier, including through a mandatory corporate action, OFSI states that the assessment will depend on the facts, with particular weight given to whether the process raises new finance for the issuer. By way of example, the FAQ indicates that a mandatory stock split may fall outside the relevant restrictions where it does not raise new finance and does not materially alter the rights or value of the shares.

· On 11 June 2026, OFSI added FAQs 188 to 195 to its UK Financial Sanctions FAQs, addressing how UK financial sanctions may apply to activities involving ports and infrastructure owned or controlled by PJSC Transneft. The FAQs indicate that a vessel’s call at a port owned or controlled by Transneft, or the use of Transneft infrastructure within a supply chain, will not by itself trigger UK financial sanctions. However, firms are expected to consider the facts of each case, including whether there is a UK nexus and whether any related insurance, port, terminal, transport, storage or other payment would result in funds or economic resources being made available to PJSC Transneft or another designated person. OFSI also confirms that compliance with EU or other sanctions regimes does not, of itself, demonstrate compliance with UK financial sanctions.

· On 24 June 2026, OFSI added FAQ 196 to its UK Financial Sanctions FAQs, explaining the purpose of the 19 June 2026 amendment to General Licence INT/2025/8031092. The FAQ states that the amendment is intended to allow Lukoil International subsidiaries to access funds needed to meet operational costs, including payments to staff, suppliers and essential services, and to support the viability of Lukoil International’s assets while sale negotiations are ongoing. The FAQ also reiterates that the General Licence does not permit funds to be made available to, or for the benefit of, PJSC Lukoil, the designated Russian parent company.

Publications

· On 18 June 2026, the House of Commons Library published a research briefing considering the domestic and international legal frameworks governing UK enforcement action against Russia’s shadow fleet, including vessels suspected of being used to evade restrictions on Russian oil exports. The briefing notes recent UK and allied enforcement action, while highlighting that enforcement is more straightforward against “stateless” vessels and that significant legal questions remain in relation to foreign flagged vessels, particularly where issues of innocent passage through territorial waters arise. The full research briefing can be found here.

· On 23 June 2026, HM Treasury and OFSI published joint guidance with OFAC titled ‘The U.S. and UK Economic Sanctions Authorities: A Comparative Overview’. The guidance compares key aspects of the US and UK sanctions regimes, including sanctions lists, licensing, reporting, recordkeeping, ownership and control, and enforcement. The guidance highlights both similarities and important differences between the regimes. In particular, it contrasts OFAC’s “50 Percent Rule” with the UK’s broader ownership and control test, and compares the approaches of OFAC and OFSI to reporting, recordkeeping and voluntary disclosures. The publication is a useful practical tool for businesses operating across both jurisdictions and reflects continued coordination between OFAC and OFSI, while making clear that the two regimes should not be treated as identical. The guidance can be found here.

CONCLUSION