On October 1, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a determination under Section 1(a)(i) of Executive Order (“EO”) 13902 that extends sanctions to the automotive and rail sectors of the Iranian economy, designated 28 entities and two individuals under its Iran-related authorities, amended FAQ 831 to broaden its description of the financial sector of the Iranian economy, and designated the Russia-linked A7 Network as a significant transnational…
On 2 October 2026, the Japanese government announced further sanctions against the Russian Federation under the Foreign Exchange and Foreign Trade Act in line with measures adopted by other major countries. The additional measures, based on the Cabinet Understanding of “Asset Freeze Measures for Parties of the Russian Federation, etc.,” designate parties subject to asset freeze measures and export prohibitions and vessels subject to service and capital transaction restrictions while also prohibiting the export of…
On October 1, 2026, the US Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR”) to remove Syria from the list of countries subject to a policy of denial for licenses and other approvals for exports, imports of defense articles and defense services. The rule took effect on publication of the final rule, and the State Department will now adjudicate applications for licenses or other approvals involving Syria on…
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…