On 22 May 2026, the Swiss Federal Council announced the expansion of its sanctions lists against Russia and Belarus (see press release here). With this step, Switzerland has partially implemented the measures adopted by the EU under its 20th sanctions package. The corresponding amendments to the Ordinance on Measures in Connection with the Situation in Ukraine (“Ukraine Ordinance”) and the Ordinance on Measures against Belarus (“Belarus Ordinance”) entered into force on 22 May 2026. Following…
On May 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 58 (“GL 58”), authorizing transactions ordinarily incident to the provision of certain services in connection with potential debt restructuring of the Government of Venezuela. GL 58 provides a limited authorization for specified transactions, subject to conditions and exclusions, and reflects OFAC’s continued use of general licenses to relax US sanctions on Venezuela. Our prior blog…
On May 1, 2026, President Trump signed Executive Order 14404 (“EO 14404”) entitled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy,” which significantly expands the US sanctions framework targeting Cuba. EO 14404 imposed a modern US secondary sanctions regime targeting Cuba that is likely to encourage many non-US companies – particularly those with US assets/business and/or reliance on the US financial system –…
On May 11, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “Alert”) to financial institutions outlining funding streams and procurement networks that support Iran’s Islamic Revolutionary Guard Corps (“IRGC”). The Alert supplements an earlier June 6, 2025 FinCEN Advisory on the Iranian Regime’s Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons Procurement Efforts, as well as FinCEN’s May 8, 2024 Advisory to to Counter the Financing…