On October 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published an alert (the “Alert”) warning that foreign financial institutions (“FFIs”) that continue to transact with sanctioned Iranian financial institutions “could be targeted at any time without advance notification.” OFAC also amended Iran-related FAQ 156 to remove earlier language indicating that OFAC would generally contact an FFI about its conduct before making a finding that the FFI knowingly engaged…
On 29 September 2026, a range of new and expanded UK sanctions targeting Iran entered into force, following the publication on 8 September 2026 of the Iran (Sanctions) (Amendment) Regulations 2026 (the “Regulations”). The Regulations amend both the Iran (Sanctions) Regulations 2023, which principally address human rights abuses and hostile activity by Iran, and the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019, which seek to restrict Iran’s ability to develop nuclear weapons and implement certain…
Earlier this month, as part of Operation Economic Outcast targeting Iran, the US Department of the Treasury ushered in a flurry of administrative and regulatory changes. On September 10, 2026, the Office of Foreign Assets Control (“OFAC”) modified its Iran-related specific licensing policy, announced a settlement agreement, and updated the Specially Designated Nationals and Blocked Persons List (“SDN List”). These changes landed two days after OFAC’s September 8, 2026 action against Iran’s aviation sector, which…
President Trump signed the much-anticipated Russia (and Iran) sanctions bill into law on Friday, September 18, 2026. The final text of H.R. 5334 is available here. In Brief It has been a long journey since Senator Lindsey Graham introduced an earlier version of the bill in the Senate in April 2025. After Senator Graham passed away in July, a new Russia sanctions bill was introduced bearing his name, the Lindsey O. Graham Sanctioning Russia and…