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Sanctions Regimes

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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…

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…