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…
On 29 September 2026, a range of new and expanded UK sanctions targeting Iran entered into force, following the publication on 8 September 2026 of the Iran (Sanctions) (Amendment) Regulations 2026 (the “Regulations”). The Regulations amend both the Iran (Sanctions) Regulations 2023, which principally address human rights abuses and hostile activity by Iran, and the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019, which seek to restrict Iran’s ability to develop nuclear weapons and implement certain…
Earlier this month, as part of Operation Economic Outcast targeting Iran, the US Department of the Treasury ushered in a flurry of administrative and regulatory changes. On September 10, 2026, the Office of Foreign Assets Control (“OFAC”) modified its Iran-related specific licensing policy, announced a settlement agreement, and updated the Specially Designated Nationals and Blocked Persons List (“SDN List”). These changes landed two days after OFAC’s September 8, 2026 action against Iran’s aviation sector, which…
On 8 September 2026, the UK government designated five settlers under the existing Global Human Rights Sanctions Regulations 2020 and announced that it will introduce a new sanctions regime targeting settlements in the occupied West Bank over the next six to nine months, under the powers conferred to it by the Sanctions and Anti-Money Laundering Act 2018. The announcement formed part of a coordinated cross-jurisdictional effort and was made alongside a joint statement by the UK and 11 other countries, including France, Canada, Denmark, Spain, Finland, Ireland, Iceland, Norway, Poland, Portugal, and Sweden. These countries committed…