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…
On April 17, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia‑related General License No. 134B (“GL 134B”), extending the duration of General License No. 134A, which authorized certain transactions involving crude oil and petroleum products of Russian Federation origin that had already been loaded onto vessels. As with GL 134A, GL 134B authorizes transactions that are ordinarily incident and necessary to the sale, delivery, or offloading of Russian‑origin…
On April 14, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License Nos. 128C and 130A (“GL 128C” and “GL 130A”, respectively), further extending prior authorizations relating to certain transactions involving certain subsidiaries of Public Joint‑Stock Company Oil Company Lukoil (“Lukoil”). As with earlier iterations, these general licenses permit limited, time‑bound transactions to proceed notwithstanding the designation of Lukoil and certain affiliates as Specially Designated Nationals (“SDNs”). We…
On April 18, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the UK’s Foreign, Commonwealth & Development Office (“FCDO”) announced a coordinated sanctions package targeting Iran. In the US, OFAC added 16 individuals and 10 entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and the US Commerce Department’s Bureau of Industry and Security (“BIS”) also expanded the scope of Foreign Direct Product (“FDP”) rules for foreign-produced items…