Monthly Sanctions Update | August 2026

/// Monthly Sanctions Update | August 2026

KEY DEVELOPMENTS

· Operation Economic Outcast: The US expanded sanctions against Iran across five additional economic sectors, designated nearly 60 individuals, entities and vessels, and suspended five existing authorisations.

· Continued pressure on Russia: The UK imposed 13 new designations and specified six shadow-fleet vessels, while the EU listed five figures connected with Russia’s defence and military-technology sectors.

· New Venezuela authorisations: OFAC issued two telecommunications licences and amended eight existing licences to remove US governing-law requirements while retaining specified dispute-resolution requirements.

· Cuba military-related designations: The US designated eight Cuban officials and five entities involved in foreign military cooperation and the procurement or maintenance of military equipment.

· Increased UK enforcement focus: The UK issued its first nationwide alert concerning the A7 sanctions-evasion network and announced that OFSI’s maximum monetary penalty would be doubled.

GLOBAL SANCTIONS

Cuba

· On 6 August 2026, the US Department of State designated eight Cuban officials and five Cuban state-owned or military entities under Executive Order 14404. The targets were involved in procuring and maintaining military equipment for Cuba’s armed forces and security services, including equipment obtained from Russia and China, or in facilitating Cuba’s foreign military cooperation. The designations block property within US jurisdiction and expose non-US persons to potential sanctions for certain dealings with the targets.

· On 6 August 2026, OFAC issued Cuba-related FAQ 1264 to clarify the treatment of non-US persons engaged in humanitarian trade under Executive Order 14404. OFAC stated that it does not intend to target the supply of food, agricultural commodities, medicines, or medical devices to Cuba, even where a designated person or a business at least 50% owned by a designated person is involved. Any US person involvement must remain within the requirements of the Cuba General Licence 1.

Iran

· On 7 August 2026, OFAC targeted two Iran-linked digital-asset exchanges and a related multinational corporate network allegedly used to fund the IRGC and evade sanctions. OFAC stated that the exchanges processed transactions involving previously sanctioned Iranian platforms and transferred digital assets to and from IRGC-controlled addresses. The wider network, which operated across the UAE, Georgia and Poland, allegedly used front companies and online gambling activity to disguise the source and movement of funds. The designations formed part of a broader SDN List update covering five individuals and twelve entities across Iran, the UAE, Georgia, Poland, Hong Kong and Singapore. On the same day, OFAC also amended Iran-related FAQ 1257 concerning the sanctions risks associated with Iranian digital-asset exchanges.

· On 12 August 2026, OFAC announced that it had reached a $60,764 settlement with Rice Lake Weighing Systems, Inc. and the company’s Italian subsidiary, Dini Argeo S.r.l., in relation to eight apparent violations of OFAC’s Iran sanctions regime. Between July 2019 and November 2021, the Italian subsidiary had supplied weighing equipment through the UAE with the knowledge that its ultimate destination was Iran. OFAC treated the apparent violations as voluntarily disclosed and non-egregious.

· On 24 August 2026, the US launched “Operation Economic Outcast”, substantially expanding sanctions against Iran. OFAC made five sectoral determinations covering Iran’s digital-assets, technology, gold, aviation and shipping sectors and sanctioned nearly 60 individuals, entities and vessels connected with nuclear and missile procurement, cyber operations and oil-revenue networks. OFAC also suspended five existing authorisations covering educational activities, non-commercial personal remittances, conferences, sporting exchanges and academic exchanges. General Licence BB permitted the wind-down of previously authorised transactions until 8 September 2026.

Russia

· On 6 August 2026, Foreign Secretary Ed Miliband announced his first major Russia sanctions package, comprising 13 new designations and six vessel specifications. The measures targeted six Russian banks, six shadow-fleet tankers, four companies importing tantalum and niobium used in military equipment, two maritime businesses supporting Russia’s shipping operations and one individual connected with sanctions-evasion infrastructure.

· On 7 August 2026, the EU listed five senior figures in Russia’s defence and military-technology sectors for supporting Russia’s war against Ukraine. The designations target individuals connected with the production of missiles, military communications systems, drone software and other military technologies. The individuals are subject to asset freezes and travel bans.

· On 17 August 2026, EU foreign policy chief Kaja Kallas said that she intended to put forward significantly wider sanctions listings against Russia in the autumn. Kallas said that, if adopted, the proposed listings would increase the total number of sanctioned Russian entities by approximately one-third. Any new listings would require the unanimous approval of all 27 EU Member States.

· On 20 August 2026, OFAC issued General Licence 131I, titled “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities”. The licence replaced General Licence 131H and extended the relevant authorisations from 22 August to 19 September 2026. It permits transactions necessary to negotiate contingent contracts for the sale of Lukoil International GmbH and its majority-owned entities, as well as transactions required to maintain or wind down their operations. Completion of any sale still requires separate OFAC authorisation, and the licence does not permit funds to be transferred to persons or accounts in Russia.

· On 31 August 2026, the UK Government and NCA issued the first ever nationwide industry alert against A7, a Kremlin-backed payments network alleged to facilitate sanctions evasion through third-country financial institutions and cross-border payment structures. The network, which has also been linked to Iranian state-associated actors, claims to have processed more than $86 billion in transactions during its first year of operation. The Government also announced plans to increase the maximum monetary penalty for breaches of UK financial sanctions from 50% to 100% of the value of the breach.

Syria

· On 24 August 2026, the US provided further sanctions relief in relation to Syria. The State Department rescinded Syria’s designation as a State Sponsor of Terrorism and revoked Hay’at Tahrir al-Sham’s designation as a Specially Designated Global Terrorist. OFAC consequently removed the organisation from the SDN List and revoked Syria General Licence 25 because transactions involving it were no longer prohibited solely on that basis. US persons may now transact with the organisation without separate OFAC authorisation, provided the transaction does not involve another blocked person or prohibited activity. This did not remove targeted sanctions against former regime figures, human-rights abusers, Captagon traffickers, terrorist organisations and other destabilising actors. OFAC simultaneously designated two former affiliates for supporting al-Qaida and Hurras al-Din. OFAC also updated FAQs 1220 to 1222 and removed FAQ 1223. The revised guidance confirms that the comprehensive Syria sanctions programme has not been in force since 1 July 2025, that US financial institutions may establish relationships with Syrian banks where no listed parties are involved, and that OFAC authorisation is not required to export food or medicine to Syria. Separate US export-control requirements may still apply.

Venezuela

· On 21 August 2026, OFAC issued General Licences 61 and 62 concerning Venezuela’s telecommunications sector. General Licence 61 authorised the provision of US goods, technology, software and services needed to install, maintain, repair, upgrade or operate telecommunications in Venezuela, including certain transactions involving the Venezuelan Government and state telecommunications providers. General Licence 62 authorised negotiations and contingent contracts for new telecommunications investment but did not authorise performance of those contracts without separate OFAC approval.

· On 27 August 2026, OFAC replaced General Licence 61 with General Licence 61A and amended seven existing licences covering oil, petrochemicals, diluents, electricity, PDVSA, gold and other minerals. The amendments removed the requirement for contracts directly with the Venezuelan Government or specified blocked entities to be governed by US law. Such contracts must still require related dispute-resolution proceedings to take place in the United States, United Kingdom, France or Singapore.

GLOBAL REGULATIONS / TOOLS

· On 3 August 2026, the Office of Trade Sanctions Implementation published guidance on banknote sanctions. The guidance explains prohibitions on exporting, supplying, or making sterling or specified European banknotes available to Russia and Belarus. The guidance confirms the personal use exception of up to £10,000 per journey where the money is required for the essential needs of the traveller or accompanying immediate family. The exception does not cover commercial, investment, or professional purposes, or delivering cash to family or friends living in Russia and Belarus. The full guidance can be found here.

· On 3 August 2026, the House of Commons Library published a Research Briefing titled “Sanctions against Russia: What has changed since January 2025?”. The briefing considers the increasing divergence between US and European sanctions policy, recent UK and EU measures targeting Russia’s defence, financial, energy and shadow-fleet networks, and the continuing debate over the use of immobilised Russian state assets to support Ukraine. It also provides an overview of the wider UK and EU sanctions regimes addressing Russian cyber activity, chemical weapons, human rights abuses and hybrid threats. The full briefing can be found here.

· On 27 August 2026, OTSI published its first Annual Review, covering 1 April 2025 to 31 March 2026. OTSI received 178 reports or referrals concerning potential trade sanctions breaches, of which 156 related to Russia, and closed 104 enforcement cases, including 40 referred to HMRC. Although OTSI did not impose any civil monetary penalties during the period, it reported that a substantial number of investigations had reached an advanced stage. OTSI also received 51 licence applications, 50 under the Russia regime, and granted 17, with an average processing time of 96 working days. The full review can be found here.

General Licences

· On 12 August 2026, OFSI amended General Licence INT/2025/8031092 permitting the continuation of business operations involving Lukoil International GmbH and its subsidiaries. The amendment revised the definition of a “Lukoil International Subsidiary” and introduced the definition of an “Entity”. The amendment also introduced a new notification requirement for entities using the licence and extended its expiry date to 26 February 2027.

· On 12 August 2026, OFSI also amended General Licence INT/2025/7895596, which permits the continuation of business operations with the Lukoil Bulgaria Entities. The amendment revised the definition of the subsidiaries covered by the licence, introduced a definition of “Entity” and a new notification requirement for entities using the licence, and extended its expiry date to 29 October 2026.

Case Law

· On 29 July 2026, the UK Supreme Court refused permission to appeal to Dana Astra IOOO, a Belarus-registered construction company and one of Belarus’s largest property developers, on the basis that its application raised no arguable point of law. DANA, which has no assets or business in the UK, was designated under the UK’s Belarus sanctions regime in December 2020. The designation was based on the Secretary of State’s assessment that there were reasonable grounds to suspect DANA of involvement in the repression of civil society or democratic opposition through its sponsorship of the Belarusian National Olympic Committee, and of benefiting from or supporting the Belarusian government through its construction activities. The refusal leaves in place the Court of Appeal’s dismissal of DANA’s challenge to its designation. The decision can be found here.

Investigations

· On 27 August 2026, ENEX Premium Trading Limited agreed to forfeit more than $5.2 million, equivalent to approximately £3.84 million, following an NCA civil recovery investigation into suspected money laundering and sanctions evasion. The forfeited money was traced through ENEX’s Chinese bank accounts to payments from companies later sanctioned by the US for facilitating illicit Iranian oil sales and revenue and sending funds to the Iranian QODS Force. The NCA suspects that the forfeited funds represented the proceeds of money laundering. However, the settlement did not amount to an admission of unlawful conduct by ENEX or its owner and does not constitute evidence of criminal conduct.

CONCLUSION