Monthly Sanctions Update (March 2026)

KEY DEVELOPMENTS

• Major US, UK and EU designations: EU cyber sanctions against Integrity Technology Group, Anxun Information Technology and associated individuals linked to hacking activity affecting EU member states and partners; EU human rights sanctions against 16 individuals and three entities in Iran in connection with the authorities’ handling of protests earlier in 2026; EU cyber sanctions against Iranian entity Emennet Pasargad; EU Russia-regime listings targeting individuals involved in foreign information manipulation and interference and nine individuals linked to atrocities committed during the Bucha massacre.

• Sanctions litigation and enforcement developments: Central Bank of Russia challenge before the EU General Court to measures providing for the indefinite freezing of its assets held in the EU; German criminal convictions for the export of luxury vehicles to Russia in breach of EU restrictions, including custodial sentences and confiscation of proceeds; OFSI monetary penalty of £390,000 imposed on Apple Distribution International for breaches of UK Russia financial sanctions.

• General licences: OFAC General License No. 14 under the Belarus programme authorising certain transactions involving Belinvestbank Joint Stock Company and related entities; OFAC General License No. 1 under the DRC programme authorising wind-down transactions involving the Rwanda Defence Force; OFAC General License U authorising certain transactions relating to Iranian-origin crude oil and petroleum products loaded by 20 March 2026; OFAC General License 134 authorising certain transactions relating to Russian-origin crude oil and petroleum products already loaded onto vessels as of 12 March 2026; OFSI General Licence INT/2026/9247168 authorising certain activities involving PJSC Transneft in connection with Kazakh-origin crude oil.

• Russia-related developments: EU listings targeting foreign information manipulation and individuals linked to Bucha atrocities; OFAC extension of the deadline for negotiations relating to the potential sale of Lukoil’s foreign assets to 1 May 2026; updated UK guidance on countering Russian sanctions evasion and circumvention; OFSI enforcement action against Apple Distribution International for payments to a Russian entity owned by a designated person.

• Regulatory and guidance updates: UK publication of its cross-government strategic approach to sanctions enforcement; updated UK statutory guidance under the Central African Republic regime; UK guidance on Belarus trade sanctions licensing, including a structured tool for assessing licence availability; updated UK Starter Guide to Sanctions; OFSI update on evidential requirements and “reasonableness” in licence applications; OFSI open call for evidence on the ownership and control test closing on 13 April 2026; UK Sanctions List updates under the Afghanistan regime making variations to identifying information on existing entries.

• Trade controls and export licensing: ECJU update to the Open General Export Licence for military goods: Collaborative Project Typhoon, including expansion of permitted destinations.

GLOBAL SANCTIONS

AFGHANISTAN

• On 11 March 2026, the Foreign, Commonwealth & Development Office updated the UK Sanctions List under the Afghanistan (Sanctions) (EU Exit) Regulations 2020, making 22 variations to existing entries. The changes relate to updates to identifying information, including dates of birth, passport details, aliases and other biographical data for listed individuals. All affected persons remain subject to asset freezes and travel bans, and the variations do not alter the underlying sanctions measures.

BELARUS

• On 5 March 2026, the UK Government published guidance setting out considerations for granting trade sanctions licences under the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019. The guidance provides a structured “look-up” tool to assist businesses in determining whether a licence may be available across a range of restricted sectors, including military goods, dual-use items, industrial goods, energy-related products and luxury goods. It outlines the types of circumstances in which licences may be granted, such as for humanitarian purposes, protective use or certain civil applications, and emphasises that a licence must be obtained before engaging in any activity otherwise prohibited by the regime.

• On 26 March 2026, OFAC issued General License No. 14 under the Belarus Sanctions Regulations, authorising transactions involving Belinvestbank Joint Stock Company, Belinvest-Engineering, Belbizneslizing, and entities in which they hold a 50 percent or greater interest. The licence permits transactions otherwise prohibited under the regime but does not authorise the unblocking of property or transactions involving other blocked persons not covered by the licence.

CENTRAL AFRICAN REPUBLIC

• On 25 March 2026, the UK Government updated its statutory guidance under the Central African Republic (Sanctions) (EU Exit) Regulations 2020 to reflect changes introduced by the 2025 Amendment Regulations and recent UN Security Council measures. The updated guidance provides further clarity on the operation of financial sanctions, including asset freeze obligations and restrictions on making funds or economic resources available, as well as the scope of remaining trade and export prohibitions following the lifting of the arms embargo. It also expands on the application of director disqualification measures, preventing designated persons from participating in the management of UK companies, and clarifies available exceptions, including the UN humanitarian exemption. The updates are intended to improve usability and support consistent compliance without materially altering the underlying framework.

CHINA

• On 16 March 2026, the Council of the European Union imposed restrictive measures under its cyber sanctions regime on Integrity Technology Group and Anxun Information Technology, as well as the two co-founders of Anxun. The designations relate to the provision of hacking tools and services used to compromise devices and target critical infrastructure in EU member states and partner countries. Those listed are subject to asset freezes, with EU persons prohibited from making funds or economic resources available to them, and the individuals also subject to travel bans.

DEMOCRATIC REPUBLIC OF CONGO

• On 2 March 2026, OFAC issued General License No. 1 under the Democratic Republic of the Congo Sanctions Regulations, authorising transactions ordinarily incident and necessary to the wind down of activities involving the Rwanda Defence Force (RDF) and entities in which it holds a 50 percent or greater interest. The authorisation remains in effect until 12:01 a.m. EDT on 1 April 2026, subject to the condition that any payments to blocked persons are made into blocked accounts.

GERMANY

• On 2 March 2026, a German court convicted two individuals for exporting 111 luxury vehicles to Russia in breach of the EU’s luxury goods restrictions under Article 3h of Regulation (EU) 833/2014. The vehicles, including armoured cars, were supplied to Russian customers via a network of intermediary companies. One defendant received a six-year custodial sentence, while the other was given a two-year suspended sentence. The court also ordered the confiscation of approximately €20 million in proceeds of crime. Authorities indicated that the scheme involved plans to export a further 400 vehicles valued at around €40 million.

IRAN

• On 16 March 2026, the Council of the European Union introduced further sanctions under its Iran human rights regime, adding 16 individuals and three entities in response to the authorities’ handling of protests earlier in 2026. Those designated include senior government, security and judicial figures, as well as organisations linked to the coordination of enforcement measures and surveillance activities. The listings impose asset freezes and travel bans and prohibit EU persons from making funds or economic resources available. The additions bring the total number of listings under the regime to 263 individuals and 53 entities.

• On 16 March 2026, the Council of the European Union imposed sanctions under its cyber regime on Emennet Pasargad, an Iranian entity linked to cyber activities affecting EU member states. The designation relates to unauthorised access to data, including a French subscriber database, and the compromise of advertising billboards and a Swedish SMS service.

• On 20 March 2026, OFAC issued General License U, authorising transactions ordinarily incident and necessary to the sale, delivery or offloading of Iranian-origin crude oil and petroleum products loaded onto vessels on or before 12:01 a.m. EDT, 20 March 2026. The licence applies to such cargoes, including those carried on blocked vessels, and remains in force until 12:01 a.m. EDT, 19 April 2026. It also confirms that authorised transactions may include importation into the United States where such activity is incidental to the permitted sale or delivery. The licence does not authorise transactions involving persons connected with North Korea, Cuba or certain regions of Ukraine, or entities owned or controlled by such persons.

RUSSIA

• On 3 March 2026, the Central Bank of Russia brought proceedings before the EU General Court challenging Council Regulation (EU) 2025/2600, which provides for the indefinite freezing of its assets held in the EU. The claim, filed under Article 263 TFEU, seeks annulment of the measure and raises arguments relating to property rights, access to justice and sovereign immunity, as well as alleged procedural deficiencies in its adoption, including the use of a majority vote rather than unanimity. The case forms part of wider efforts to contest EU measures affecting Russian sovereign assets, estimated at around $300 billion held in Europe.

• On 12 March 2026, the U.S. Treasury’s Office of Foreign Assets Control issued General License 134, authorising transactions ordinarily incident and necessary to the delivery, sale and offloading of Russian-origin crude oil and petroleum products already loaded onto vessels as of that date. The licence provides a time-limited exemption, allowing such cargoes to be completed notwithstanding existing sanctions, and is set to expire on 11 April 2026.

• On 16 March 2026, the Council of the European Union adopted additional sanctions under its framework targeting Russia’s destabilising activities, listing four individuals involved in foreign information manipulation and interference directed at the EU and its partners. Those designated include media figures and propagandists linked to the dissemination of disinformation relating to Russia’s war against Ukraine. Following these additions, the regime applies to 69 individuals and 17 entities.

• On 16 March 2026, the Council of the European Union imposed additional restrictive measures under its Russia sanctions regime, listing nine individuals for their roles in atrocities committed during the Bucha massacre in 2022. The individuals, including senior military personnel, were identified as having played a significant role in actions undermining Ukraine’s territorial integrity and sovereignty, with the EU stating that the conduct in question amounts to war crimes and crimes against humanity.

• On 30 March 2026, OFAC extended, for a fourth time, the deadline for potential buyers to negotiate the purchase of Lukoil’s foreign assets, moving it to 1 May 2026. The extension provides additional time for discussions relating to assets reportedly valued at around $22 billion, with any eventual transaction remaining subject to OFAC approval.

TURKEY

• On 9 March 2026, the U.S. Department of Justice and Türkiye Halk Bankası A.Ş. (Halkbank), a state-owned Turkish bank, agreed a proposed Deferred Prosecution Agreement (DPA) in a long-running U.S. criminal case in which U.S. prosecutors allege that Halkbank participated in a scheme to evade U.S. sanctions on Iran involving approximately $20 billion in transactions. The agreement, filed in the U.S. District Court for the Southern District of New York, would suspend the criminal proceedings subject to court approval. Under the proposed terms, Halkbank would not admit to wrongdoing or pay financial penalties but would be required to implement compliance enhancements, including the appointment of an independent monitor, and refrain from transactions involving Iran during the term of the agreement.

GLOBAL REGULATIONS/TOOLS UPDATE – UK

• UK Government strategic approach to sanctions enforcement: On 10 March 2026, the UK Government published its cross-government strategic approach to sanctions enforcement, setting out how civil and criminal breaches of UK sanctions are investigated and enforced across departments and agencies. The document outlines key enforcement principles, the respective roles of enforcement bodies, and the range of tools available, including civil penalties and criminal action, together with the factors taken into account when determining outcomes. It also emphasises the importance of strong compliance, noting that enforcement is intended both to deter non-compliance and to address deliberate attempts to evade sanctions.

• Open General Export Licence update: On 11 March 2026, the Export Control Joint Unit (ECJU) updated the Open General Export Licence (OGEL) for military goods: Collaborative Project Typhoon, revoking the previous 30 September 2022 licence. The updated licence expands the list of permitted destinations to include Turkey (for maintenance purposes), while continuing to authorise exports of specified military goods, software and technology in support of the Typhoon programme to approved partner nations and permitted end users. The licence remains subject to conditions including prior ECJU approval of eligible contracts, compliance with security requirements, and record-keeping and reporting obligations, with exporters also required to include the relevant licence reference in customs declarations.

• Guidance on countering Russian sanctions evasion and circumvention: On 12 March 2026, the UK Government updated its guidance on countering Russian sanctions evasion and circumvention, aimed at supporting exporters in identifying and mitigating diversion risks. The guidance can be found here. The guidance outlines common evasion tactics, including the use of third-country intermediaries, indirect shipping routes and falsified end-use information, and highlights categories of high-risk goods, particularly military, dual-use and industrial items. It also sets out red flag indicators and recommended enhanced due diligence measures, emphasising that businesses are responsible for assessing their exposure and implementing appropriate compliance controls to avoid facilitating sanctions breaches.

• OFSI updated blog on “reasonableness” in licence applications: On 13 March 2026, OFSI published an updated blog on its approach to assessing “reasonableness” in sanctions licence applications, providing greater clarity on evidential requirements across key licensing grounds. The update introduces a requirement for an independent Costs Draftsperson’s Report in certain high-value legal fee cases, including where total legal fees exceed £2 million (including VAT) within a six-month period, or £1 million where Counsel is instructed directly. These thresholds apply cumulatively per designated person across related applications. OFSI also emphasised that applicants must demonstrate that requested payments are reasonable, supported by appropriate evidence.

• Updated Starter Guide to UK Sanctions: On 25 March 2026, the UK Government updated its Starter Guide to UK Sanctions, an introductory resource designed to help businesses and organisations understand the structure and operation of the UK sanctions regime. The guidance can be found here. The guidance outlines who must comply, the different types of sanctions, including financial, trade, immigration and transport measures, and key concepts such as designated persons, ownership and control, and the UK Sanctions List. It also highlights core compliance expectations, including sanctions screening, due diligence and the use of licensing and exceptions.

• OFSI monetary penalty against Apple Distribution International: On 19 March 2026, OFSI imposed a £390,000 monetary penalty on Apple Distribution International (ADI), with the decision published on 30 March 2026, for breaches of UK financial sanctions relating to Russia. The case concerned two payments totalling £634,570.08, made on 6 June and 8 July 2022, to a Russian entity owned by a designated person. OFSI determined, on the balance of probabilities, that the payments constituted breaches of the asset freeze, notwithstanding that ADI voluntarily disclosed the transactions. The penalty was imposed following settlement discussions and reflects OFSI’s assessment of the seriousness of the breach and mitigating factors.

• OFSI open call for evidence: OFSI’s open call for evidence on the operation of the ownership and control test in UK financial sanctions regulations, including how it is applied in practice and the challenges faced by firms, closes on Monday 13 April 2026. The survey can be accessed here.

General Licences

• On 19 March 2026, OFSI issued General Licence INT/2026/9247168 permitting certain activities involving PJSC Transneft and its subsidiaries in connection with the transportation and handling of Kazakh-origin crude oil. The licence authorises transactions, including payments, relating to the supply, purchase and movement of Kazakh oil where the oil is not owned by a person connected with Russia and is only transiting through or departing from Russia. The licence also allows relevant UK financial institutions to process associated payments. It remains in force until 18 March 2028 and is subject to standard record-keeping requirements.

CONCLUSION

March 2026 reflects an increasingly active sanctions environment, with new EU cyber and Russia-related listings, ongoing litigation such as the Central Bank of Russia challenge, and criminal enforcement in Germany signalling continued regulatory focus. In the UK, recent guidance on enforcement, evasion and licensing, alongside OFSI’s penalty against Apple Distribution International, reinforces the practical impact of the strict liability regime, where breaches may arise without knowledge or intent. At the same time, the use of general licences across US and UK regimes highlights the need for careful navigation of permitted activity within complex restrictions.

Overall, firms should ensure their sanctions compliance frameworks remain proactive, risk-based and responsive to ongoing developments. MR’s monthly sanctions update will continue to monitor these developments, providing timely insight into international sanctions measures, regulatory reforms and key enforcement trends shaping the global sanctions landscape.

This blog post is not offered, and should not be relied on, as legal advice. You should consult an attorney for advice in specific situations.