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…
On April 28, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took a series of Iran-related actions as part of the Administration’s “Economic Fury” campaign of exerting maximum pressure against Iran. Specifically, OFAC (1) issued an alert warning of the sanctions risks of dealing with Chinese “teapot” oil refineries that process Iranian crude oil and (2) published FAQ 1249, which warns that “toll” payments to the Government of Iran (“GoI”)…
On March 20, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Iran-related General License U (“GL U”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026.” One day earlier, on March 19, 2026, OFAC issued Russia-related General License 134A (“GL 134A”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on…
In Japan, there were two major updates to its export control and sanction regime announced in the past few weeks. 1. Reimposition of Sanctions Against Iran On 29 September 2025, Japanese government announced the reimposition of the following measures under the Foreign Exchange and Foreign Trade Act, in response to United Nations Security Council Resolution 2231based on which sanctions against Iran concerning its nuclear issue under United Nations Security Council Resolutions 1737, 1747, 1803, and…