Monthly Sanctions Update | July 2026

///Monthly Sanctions Update | July 2026

KEY DEVELOPMENTS

· EU’s 21st Russia package: The EU adopted its largest set of Russia related listings in four years, comprising 218 designations, new financial sector and crypto restrictions, a paused oil price cap mechanism, and expanded shadow fleet and export measures.

· First joint UK and EU cyber sanctions package: The UK and EU coordinated designations targeting GRU cyber figures, the Lumma Stealer network, and Russian state linked disinformation entities, alongside attribution of an attempted cyberattack on Poland’s energy grid.

· Chemical weapons designations: The UK sanctioned seven individuals and two Russian research institutes linked to Novichok nerve agents and the poisonings of Alexei Navalny and Dawn Sturgess.

· Continued US pressure on Iran: OFAC targeted the Mohammad Hossein Shamkhani commercial and shipping network (50+ targets) and the Babak Zanjani financial network across Iran, Türkiye and the UAE.

· Renewed UN regimes: The UN Security Council renewed its Central African Republic regime until 31 July 2027 and added six individuals and two entities to the DRC sanctions list.

· Notable case law: In R v Hauser & Wirth Gallery Ltd, the English court clarified that goods can be “made available” to a person connected with Russia without physical delivery, though the charges were dismissed on residence grounds.

GLOBAL SANCTIONS

Central African Republic

· On 29 July 2026, the UN Security Council unanimously adopted Resolution 2827 (2026), renewing until 31 July 2027 the sanctions regime concerning the Central African Republic. The measures include an arms embargo targeting armed groups and associated individuals operating in the country, together with an asset freeze and travel ban applicable to designated persons and entities responsible for undermining the country’s peace, stability or security. The mandate of the Panel of Experts was extended until 31 August 2027.

Democratic Republic of Congo

· On 14 July 2026, the UN Security Council’s 1533 Sanctions Committee added six individuals and two entities to its DRC sanctions list. The additions included Corneille Nangaa Yobeluo, leader of Alliance Fleuve Congo; commanders associated with the FDLR, ADF, M23 and Twirwaneho; Alliance Fleuve Congo itself; and Twirwaneho. The listed parties are subject to the measures imposed under the UN’s DRC sanctions regime.

Iran

· On 13 July 2026, the UK designated the Islamic Movement of Companions of the Right, also known as IMCR or HAYI, under the 2023 Iran Sanctions Regulations. The organisation is subject to an asset freeze for its suspected involvement in hostile activity on behalf of the Iranian regime. The UK stated that the group had claimed responsibility for seven attacks at locations associated with Jewish and Israeli communities and Persian language media.

· On 14 July 2026, OFAC designated more than 50 individuals, entities and vessels connected with the commercial and shipping network of Mohammad Hossein Shamkhani. The targets included financiers, shipping and freight companies, vessel owners and managers and other businesses located in jurisdictions including the UAE, Singapore, Hong Kong, India, the British Virgin Islands and the Marshall Islands. OFAC stated that the network used foreign exchange services and companies outside Iran to facilitate trade in sanctioned goods and recover the proceeds. The designations were imposed under Executive Order 13902 as part of the United States’ continuing efforts to restrict Iran’s petroleum revenues.

· On 24 July 2026, OFAC designated four individuals and several entities associated with Iranian businessman Babak Zanjani. The targets included companies operating in the financial technology, digital asset, gold, aviation, rail and travel sectors in Iran, Türkiye and the UAE. Among the entities listed were the digital asset businesses ZedPay and ZedX, BZ Diamond, DotOne Gold and other members of the DotOne group. OFAC linked the network with the movement and concealment of funds derived from Iranian petroleum sales. The listed parties are subject to US blocking sanctions, and several were identified as presenting secondary sanctions risk.

Russia

· On 6 July 2026, the UK sanctioned seven individuals and two Russian scientific research institutes for their alleged involvement in the research, development and production of toxic chemicals, including Novichok nerve agents and Epibatidine. The entities designated were SC Signal, also known as NTs Signal, and the State Research Institute of Military Medicine. The seven individuals included directors, senior researchers and technical specialists associated with those institutes and with the State Scientific Research Institute for Organic Chemistry and Technology. The UK linked the relevant chemical weapons programme with the substances used to poison Alexei Navalny and Dawn Sturgess.

· On 9 July 2026, HHJ Baumgartner handed down judgment in R v Hauser & Wirth Gallery Limited and another [2026] EWCR 7, dismissing charges alleging that an art gallery and logistics company had made a luxury artwork available to a person connected with Russia, contrary to regulation 46B of the Russia (Sanctions) (EU Exit) Regulations 2019. The Court held that goods may be “made available” without being physically delivered to the recipient or entering Russia, including where they are released into a logistics chain under the recipient’s direction. However, the charges were dismissed because there was insufficient evidence that the purchaser was ordinarily resident in Russia at the relevant time. Russian nationality, property, business interests and other continuing links were not, without evidence of a settled and regular residential life in Russia, sufficient to establish ordinary residence.

· On 13 July 2026, the UK imposed sanctions on 24 individuals and entities connected with Russian cyber operations, cybercriminal networks and information warfare. The designations included senior GRU figures Vyacheslav Stafeyev, Ivan Senin and Ivan Kasyanenko, together with individuals and an entity connected with cyber operations undertaken by GRU Unit 29155. The measures also targeted individuals associated with Lumma Stealer, malware used to obtain sensitive information from compromised devices. The UK Government stated that Russia had used credentials stolen through Lumma Stealer to undertake cyber espionage operations internationally. Ten individuals connected with Rybar LLC were also designated. The UK described Rybar as a Russian state supported media company involved in disseminating false narratives about Ukraine and interfering in elections in countries including Moldova and Armenia. The announcement formed part of the first joint UK and EU cyber sanctions package and accompanied the attribution of an attempted cyberattack against Poland’s energy grid to Russia’s FSB Centre 16.

· Also on 13 July 2026, the Council of the EU listed four individuals and five entities under its Russia human rights sanctions framework for their involvement in abusive surveillance and the repression of civil society and democratic opposition. The entities included VK Company, also known as VKontakte, and its subsidiary Communication Platform LLC, which developed and managed the Max App under the supervision of the FSB. The Council stated that the application contained extensive surveillance features used against persons criticising Russia’s war against Ukraine or posting material prohibited by the Russian authorities. The EU also listed Citadel, VAS Experts and Norsi-Trans, which manufacture or develop equipment connected with Russia’s System for Operative Investigative Measures.

· On 23 July 2026, the Council of the EU adopted its 21st package of restrictive measures against Russia. The package contained 218 individual listings, comprising 48 individuals and 170 entities, the EU’s largest batch of Russia related listings in four years. In the financial sector, the EU imposed asset freezes and restrictions on 94 banks and major financial institutions, extended its transaction ban to 33 additional Russian credit and financial institutions, a Kyrgyz bank connected with Russia’s SPFS financial messaging system and three other non Russian banks. It also imposed a transaction ban on 14 crypto service platforms and introduced a mechanism for a comprehensive third country ban on transactions with crypto providers used by Russia to evade sanctions. The package paused the automatic adjustment of the Russian oil price cap mechanism until 15 July 2027, listed 41 additional vessels (bringing the total to 673), and expanded measures covering the shadow fleet, oil refineries, traders, ports, airports, LNG tankers, the gold and diamond sectors and Russia’s military industrial complex. It added 51 entities to enhanced dual use export restrictions, including parties located in China (including Hong Kong), India, Kazakhstan, Kyrgyzstan, Türkiye and the UAE, and included mirroring measures against Belarus.

Sudan

· On 16 July 2026, the UK designated eleven individuals and entities connected with conflict gold, procurement and financing networks supporting the Rapid Support Forces or Sudanese Armed Forces. The targets included financiers, procurement operatives, UAE and Hong Kong based companies and three Sudanese state owned mining businesses.

GLOBAL REGULATIONS / TOOLS

General Licences

· General Licence INT/2026/8893924: On 6 July 2026, OFSI amended and extended the Maritime Mutual Re-Insurance Wind Down General Licence until 7 October 2026. The licence permits UK insurers and insurance brokers to make or receive certain payments involving Maritime Mutual Association Limited, Maritime Mutual Insurance Association (NZ) Limited and their subsidiaries under insurance or reinsurance contracts agreed before 24 February 2026, including where necessary to terminate or exit those contracts. The amendment introduced a monthly reporting requirement.

· General Licence INT/2025/6641960: On 13 July 2026, OFSI extended General Licence INT/2025/6641960 under the Russia and Belarus sanctions regimes, which permits non designated persons who have made investments through a designated broker to transfer their funds to a non designated broker. The licence has been extended and now expires on 16 July 2027.

· General Licence INT/2025/5787748: On 16 July 2026, OFSI amended the reporting requirements under General Licence INT/2025/5787748, which permits payments to arbitration associations and arbitrators to cover fees and expenses that would otherwise be prohibited under the UK’s Russia and Belarus sanctions regulations.

· OFAC Russia Related General License 13R: On 8 July 2026, OFAC issued Russia Related General License 13R, authorising certain administrative transactions otherwise prohibited by Directive 4 under Executive Order 14024. OFAC also amended two related Russia related FAQs, FAQs 999 and 1118, to reflect the updated authorisation.

FAQs

· On 21 July 2026, OFSI added FAQs 197 to 202 to its UK Financial Sanctions FAQs, providing guidance on Basic Needs Allowance licences. These licences permit designated persons to access a capped monthly amount from otherwise frozen funds to meet essential living expenses. OFSI confirmed that the allowance is benchmarked against median household income and is intended to cover basic needs rather than preserve a designated person’s pre designation lifestyle.

CONCLUSION