KEY DEVELOPMENTS
- Russia-focused multilateral action: EU adoption of its 20th package of sanctions against Russia, adding 120 new listings and expanding restrictions across energy, military-industrial, trade, financial services and crypto-asset sectors, alongside enhanced anti-circumvention measures targeting shadow fleet operations and third-country intermediaries; accompanying US licensing activity facilitating limited operational continuity, including in relation to Lukoil-linked assets and pre-existing oil shipments; UK amendment to an existing Russia designation.
- Expansion of licensing and wind-down measures: Continued reliance by OFAC on general licenses to permit the orderly wind-down of transactions and limited ongoing activity across multiple regimes, including Iran, Nicaragua and Venezuela, as well as authorisations supporting administrative and day-to-day operations for US persons in Russia, reflecting a calibrated approach to maintaining core prohibitions while allowing practical disengagement and compliance with local requirements.
- UK sanctions framework reform and enforcement focus: Publication of OFSI’s Strategy for 2026 to 2029 introducing a revised implementation and enforcement model, coupled with the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 establishing a new criminal offence targeting circumvention by diversion and updating licensing grounds, procedural mechanisms and financial thresholds.
- Strengthening of anti-circumvention controls: Introduction of UK Sanctions End-Use Controls extending licensing requirements to goods and technology at risk of onward diversion to sanctioned jurisdictions, supported by detailed government guidance emphasising risk-based due diligence, supply chain visibility and enhanced compliance obligations.
- Guidance and general license developments: Updated UK guidance clarifying the operation of sanctions exceptions and licences across regimes, including the interaction between financial and trade restrictions; issuance of new and revised UK general licences, including a Legal Services General Licence and an insolvency-related licence concerning the Prince Group, reflecting continued refinement of licensing frameworks.
- Geopolitical recalibration of sanctions regimes: Further easing of UK Syria sanctions, including removal of certain trade restrictions and confirmation of broader reforms aimed at supporting economic recovery, alongside targeted US measures permitting limited commercial engagement with the Government of Venezuela and associated entities.
GLOBAL SANCTIONS
AFGHANISTAN
- On 14 and 16 April 2026, the Foreign, Commonwealth & Development Office updated the UK Sanctions List under the Afghanistan (Sanctions) (EU Exit) Regulations 2020, making a series of variations to existing entries. The amendments relate to updates to identifying information, including names, aliases and other biographical details for designated individuals. All affected persons remain subject to asset freezes and travel bans, and the variations do not alter the underlying sanctions measures.
- On 29 April 2026, the Foreign, Commonwealth & Development Office updated the UK Sanctions List under the Afghanistan regime, making 17 variations to existing entries. All individuals remain subject to asset freezes and travel bans, with the updates reflecting changes to identifying information and designation details.
IRAN
- On 24 April 2026, OFAC issued General License V under Executive Order 13902, authorising the wind-down of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. The licence permits activities ordinarily incident and necessary to terminate existing dealings with the entity and its majority-owned subsidiaries until 24 May 2026, subject to conditions. In particular, any payments to blocked persons must be made into blocked, interest-bearing accounts in the United States. The measure reflects a targeted wind-down authorisation, allowing the orderly cessation of pre-existing business while maintaining broader prohibitions on dealings with sanctioned parties.
NICARAGUA
- On 16 April 2026, OFAC issued General License No. 5 under the Nicaragua Sanctions Regulations, authorising transactions ordinarily incident and necessary to the wind down of activities involving Exportadora de Metales Sociedad Anonima (EMSA) and entities in which it holds a 50 percent or greater interest. The authorisation remains in effect until 12:01 a.m. EDT on 16 May 2026, subject to the condition that any payments to blocked persons are made into blocked accounts.
RUSSIA
- On 8 April 2026, OFAC issued General License 13Q under the Russian Harmful Foreign Activities Sanctions Regulations, authorising certain administrative transactions necessary for the day-to-day operations of U.S. persons in Russia. The licence permits payments such as taxes, fees and import duties, as well as the receipt of permits, licences and similar authorisations, where these would otherwise be restricted under Directive 4. The measure is intended to allow continued basic operational compliance with local legal requirements, while maintaining broader prohibitions, including restrictions on dealings with blocked persons and limitations on access to accounts of key Russian state financial institutions.
- On 14 April 2026, OFAC issued General License 128C under the Russian Harmful Foreign Activities Sanctions Regulations, authorising certain transactions involving Lukoil retail service stations located outside Russia. The licence permits activities necessary for the continued operation, maintenance or wind-down of such stations, including the purchase of goods and services, subject to conditions. The measure reflects a targeted approach to allow limited commercial continuity outside Russia, while preserving core sanctions restrictions, including prohibitions on transfers to Russia and dealings with other blocked persons.
- On 14 April 2026, OFAC also issued General License 130A under the Russian Harmful Foreign Activities Sanctions Regulations, authorising transactions involving specified Lukoil entities operating in Bulgaria. The licence permits otherwise restricted dealings with these entities until 29 October 2026, reflecting a continued effort to manage the impact of sanctions on energy infrastructure and regional markets. The authorisation remains limited in scope and does not extend to other blocked affiliates or broader transactions prohibited under the Russian sanctions regime.
- On 17 April 2026, OFAC issued General License 134B under multiple Russia-related sanctions authorities, authorising transactions necessary for the delivery and offloading of Russian-origin crude oil and petroleum products loaded onto vessels prior to 17 April 2026. The licence provides a time-limited wind-down period, allowing such cargoes to be delivered through 16 May 2026, including associated services required for safe transport and handling. The measure is intended to facilitate the orderly completion of pre-existing shipments, while maintaining restrictions on new transactions and broader sanctions prohibitions.
- On 23 April 2026, the Council of the European Union adopted its 20th package of sanctions against Russia, introducing 120 additional listings alongside expanded economic measures targeting energy revenues, the military-industrial sector, trade and financial services, including crypto-assets. The package also includes strengthened anti-circumvention measures, new restrictions on access to sensitive technologies, and further action targeting the shadow fleet and third-country intermediaries involved in sanctions evasion.
- On 29 April 2026, the Foreign, Commonwealth & Development Office amended an entry on the UK Sanctions List under the Russia regime, updating the designation for one individual. The individual remains subject to asset freeze, travel ban, trust services and director disqualification measures.
SYRIA
- On 22 April 2026, the UK Government updated its guidance on the Syria sanctions regime following amendments to the Syria (Sanctions) (EU Exit) Regulations 2019, including the removal of restrictions relating to gold, precious metals, diamonds and luxury goods. The update builds on earlier reforms introduced in April 2025, which lifted a range of trade, financial, transport and energy-related sanctions to support Syria’s economic recovery, while maintaining targeted measures against former regime figures and associated persons. The guidance also reflects the lifting of asset freezes on certain previously designated state-linked entities, including financial institutions and energy companies, and confirms that the Government of Syria is not currently designated under UK sanctions, underscoring a continued shift towards facilitating investment and reconstruction while preserving accountability measures.
VENEZUELA
- On 14 April 2026, OFAC issued General Licences 56 and 57 under the Venezuela Sanctions Regulations, authorising certain commercial and financial activities involving the Government of Venezuela and specified state-linked entities. The measures permit U.S. persons to engage in negotiations of contingent commercial arrangements with the Government of Venezuela, as well as to provide a broad range of financial services involving designated Venezuelan banks and certain government-affiliated individuals, subject to conditions. The licences form part of a broader easing of restrictions aimed at facilitating limited commercial engagement and improving access to financial channels, while maintaining core sanctions prohibitions, including restrictions on entering into or performing contracts without further authorisation and the continued application of asset freezes and other targeted measures.
GLOBAL REGULATIONS/ TOOLS UPDATE
- On 15 April 2026, OFSI published its Strategy for 2026–2029, setting out an updated framework for the implementation and enforcement of UK financial sanctions. The strategy introduces a new operating model built around four pillars, Promote, Enable, Respond and Change, aimed at improving compliance clarity, streamlining licensing processes, strengthening enforcement activity and embedding long-term behavioural change across regulated sectors. It also emphasises a more data-driven and intelligence-led approach, enhanced engagement with industry, and closer coordination with domestic and international partners, reflecting a broader shift towards proactive compliance support alongside more targeted and effective enforcement.
- On 20 April 2026, the UK Government made the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (SI 2026/443) under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) which come into force on 13 May 2026. The regulations introduce a new criminal offence aimed at addressing the risk of sanctions circumvention through diversion. The offence applies where a UK person proceeds to export goods or transfer technology after being notified by the Secretary of State that there is a risk those items could be diverted to a sanctioned destination or end user, without first obtaining a licence. The Regulations implement these end-use controls across a number of trade sanctions regimes, including those relating to Russia, Belarus, Iran, Syria and Myanmar, with licence applications to be assessed on a case-by-case basis. The amendments also revise the “prior obligations” licensing ground so that obligations are no longer limited to being discharged using a designated person’s frozen funds or by that person alone, and remove that ground entirely from the Afghanistan regime. Additional changes include updating financial thresholds for certain regulated sectors, allowing licensing decisions to be communicated electronically, clarifying the scope of the debt payment exception, and removing outdated statutory references, reflecting a broader effort to enhance the effectiveness and operability of the UK sanctions framework.
- On 22 April 2026, the UK Government introduced new Sanctions End-Use Controls and issued guidance for businesses, establishing a licensing requirement where exporters are aware, or have been notified, that goods or technology exported to non-sanctioned countries may ultimately be diverted to sanctioned destinations or end users. The measures are intended to address circumvention risks and apply to items not otherwise subject to existing military or dual-use export controls, thereby expanding the scope of regulated activity. The guidance outlines compliance expectations, including responding to government notifications, undertaking risk-based due diligence on end use and end users, and maintaining appropriate records, reflecting an increased emphasis on supply chain scrutiny and enforcement.
- On 23 April 2026, the UK Government updated its guidance on how to use exceptions and licences to comply with sanctions, providing consolidated direction across financial, trade and transport regimes. The guidance clarifies the distinction between “exceptions”, which operate as automatic exemptions where specific conditions are met, and “licences”, which constitute formal authorisation to undertake otherwise prohibited activities. It also outlines the role of different competent authorities in issuing licences across regimes and emphasises the need for businesses to assess applicability carefully, including compliance with any notification and record-keeping requirements attached to exceptions. The update highlights the potential for overlapping financial and trade restrictions, reinforcing the importance of ensuring that all necessary permissions are obtained before proceeding with sanctioned activities. The guidance can be found here.
General Licences
General Licence INT/2026/9512597 (Legal Services), issued 24 April 2026
OFSI issued General Licence INT/2026/9512597, introducing a new framework permitting UK legal firms and counsel to receive payment from designated persons for legal services, subject to specified conditions. The licence replaces the previous Legal Services General Licence expiring on 28 April 2026, takes effect from 29 April 2026, and remains in force until 28 October 2026, with associated reporting and record-keeping requirements applying.
General Licence INT/2026/9491628 (Prince Group Insolvency), issued 14 April 2026
This licence permits insolvency-related payments and activities in connection with the sanctioned Prince Group and its subsidiaries, including the making, receiving and processing of payments necessary for insolvency proceedings, without breaching UK financial sanctions. It applies to insolvency practitioners, relevant institutions and other persons involved in such proceedings, provided that any funds or economic resources remain frozen and are not made available for the benefit of designated persons except as permitted. The licence imposes notification requirements to HM Treasury within 14 days of relevant activity and requires records to be maintained, reflecting a targeted approach to facilitate orderly insolvency processes while preserving asset freeze restrictions.
CONCLUSION
April’s developments highlight the increasing focus by US, UK and EU authorities on targeted licensing, regulatory reform and enhanced anti-circumvention tools as key mechanisms for shaping the global sanctions landscape. The expanded use of general licences to facilitate wind-downs and limited commercial activity, alongside significant EU measures relating to Russia, reflects a continued effort to balance geopolitical objectives with practical compliance considerations. At the same time, the UK’s introduction of new end-use controls and updated enforcement strategy signals a more proactive and operationally focused approach to sanctions implementation, with a growing emphasis on supply chain scrutiny and risk-based compliance. These developments contribute to an increasingly complex and enforcement-driven environment for businesses and financial institutions operating across jurisdictions. 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.