On 2 October 2026, the Japanese government announced further sanctions against the Russian Federation under the Foreign Exchange and Foreign Trade Act in line with measures adopted by other major countries. The additional measures, based on the Cabinet Understanding of “Asset Freeze Measures for Parties of the Russian Federation, etc.,” designate parties subject to asset freeze measures and export prohibitions and vessels subject to service and capital transaction restrictions while also prohibiting the export of…
Global Affairs Canada (GAC) published new guidance clarifying the application of the deemed ownership provisions under Canada’s economic sanctions legislation. The guidance, updated on 13 October 2026, addresses the thresholds for establishing control over an entity, including through aggregated ownership by multiple designated persons, board appointment rights and the exercise of influence. It also provides illustrative scenarios involving indirect ownership structures and potential proxies for designated persons. Background Canada’s deemed ownership provisions were introduced into…
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…