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Sanctions Targets

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Since issuing its Frequently Asked Questions (“FAQ”) 1249 on April 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has updated its position with respect to “toll” payments to Iran for safe passage through the Strait of Hormuz. At the time of its publication, FAQ 1249 made it clear that payments to Iran for “safe passage” through the Strait of Hormuz are prohibited for U.S. persons. However, to further maximize…

On 9 June 2026, European Commission President Ursula von der Leyen announced that the European Commission is preparing a 21st sanctions package against Russia, marking a further step in the EU’s ongoing effort to intensify economic pressure following Russia’s continued aggression in Ukraine. The proposed measures focus on high-impact sectors, including energy, financial services (including crypto-assets) and trade restrictions. Key Elements of the Proposed 21st Package Energy and Transport: Expanded Targeting of the Shadow Fleet…

On June 4, 2026, the US Department of State announced a new round of designations under Executive Order 14404 (“EO 14404”) targeting five entities and five individuals for being “associated with developing, implementing, and funding the Cuban regime’s violent revolutionary network.” Secretary of State Marco Rubio issued a press statement explaining the purpose of these designations. Concurrent with these designations, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new…

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…