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Sanctions Regimes

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In brief On September 4, 2026, the Argentine Executive Branch issued Executive Order No. 868/2026 (the “Executive Order”), introducing new measures to strengthen the enforcement of Law No. 26,659 regarding hydrocarbon activities on the Argentine Continental Shelf. This law not only prohibits certain hydrocarbon activities carried out without Argentine authorization on the continental shelf, including the area surrounding the Falkland Islands (Islas Malvinas), but also imposes restrictions that may extend to direct, and indirect shareholders,…

On July 31, 2026, authorities from the United States, Japan, the Republic of Korea, Australia, Canada, France, Germany, Italy, the Netherlands, New Zealand, and the United Kingdom issued a joint alert warning countries, companies, and other entities about the threat posed by information technology (“IT”) workers of the Democratic People’s Republic of Korea (“DPRK” or “North Korea”). According to the alert, North Korea relies on a network of skilled IT workers, deployed both within and…

On July 20, 2026, the US State Department published Public Notice 13072 imposing additional sanctions on Sudan under Section 307(b) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “Act”). The action follows the State Department’s April 24, 2025, determination under Section 306(a) of the Act, that the Government of Sudan used chemical weapons in violation of international law. Section 307(b) of the Act calls for additional sanctions unless the…

On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of Iran-related sanctions designations targeting Iranian financial facilitator Ali Ansari and his financial network, as well as several Iranian exchange houses accused of facilitating transactions for sanctioned Iranian banks. Concurrently, OFAC issued General License Y (“GL Y”), authorizing the temporary wind down of transactions involving Smart Global Limited, a newly designated holding company allegedly controlled by Ansari.…