Weekly Sanctions Update: April 27, 2026

The Sanctions Update is compiled by Steptoe’s International Trade and Regulatory Compliance team and Steptoe’s Strategic Risk team. You can subscribe to receive the Sanctions Update every week through Steptoe’s International Compliance Blog and Stepwise Risk Outlook publication home pages.

For more information or advice on any of the developments discussed below, please contact a member of our sanctions team here.

US Developments

Treasury Sanctions Cambodian Senator and Affiliated Network for Scam Activities

On April 23, 2026, OFAC announced that it was designating Kok An, a Cambodian senator, as well as 28 individuals and entities alleged to be part of a network operating scam centers in Southeast Asia. According to OFAC, Kok An and his affiliates’ network of scam centers, operating out of casinos and office parks, launder victims’ funds and provide a base to target American citizens and commit human rights abuses with impunity.

Alongside the designations, the Department of Justice’s Scam Center Strike Force, which was created on November 12, 2025, announced a series of coordinated actions against Southeast Asian criminal organizations operating scam centers. These include:

• Criminal charges against two Chinese nationals who are alleged to have managed a cryptocurrency investment fraud compound in Burma and attempted to open another compound in Cambodia;
• Seizure of a Telegram messaging app channel allegedly used to recruit human trafficking victims to a scam compound in Cambodia; and
• Seizure of 503 fake investment websites.

The Department of State also announced its offer under the Transnational Organized Crime Rewards Program (TOCRP) of:

• Up to $10 million for information leading to the seizure or recovery of funds involved in money laundering scams operated out of the Tai Chang scam centers in Burma, which were the subject of certain OFAC designations from November 12, 2025; and
• Up to $4 million for information leading to the arrest of Daren Li, who was convicted and sentenced in absentia on money laundering charges in the US District Court for the Central District of California on or around February 9, 2026.

Southeast Asia-based scam centers have been an enforcement priority for the Trump administration. OFAC previously imposed sanctions on individuals and entities linked to scam centers or cyber-enabled fraud on May 5, May 29, September 8, October 14, and November 12, 2025. The DOJ has initiated multiple proceedings against individuals and entities alleged to be affiliated with scam centers or cyber-enabled fraud, and has caused the restraint of more than $700 million in cryptocurrency involved in money laundering from US victims.

Continued enforcement is expected following President Trump’s signing of Executive Order (EO) 14390, “Combating Cybercrime, Fraud, and Predatory Schemes Against American Citizens,” on March 6, 2026. Among other things, EO 14390 declares it the policy of the US to “protect Americans from, and harden [its] financial and digital systems against,” the threat of cybercrime, fraud, and predatory schemes. It also directs the Secretaries of State and the Treasury, among others, to review their regulatory frameworks and determine how each can be improved to best combat transnational criminal organizations (TCOs) engaged in cyber-enabled crime against Americans, and empowers the Secretary of State, specifically, to take all “necessary and appropriate steps” to ensure that nations that tolerate predatory activity against Americans face consequences, including targeted sanctions and visa restrictions.

OFAC Targets Iranian Networks Under “Economic Fury”

On April 21, 2026, OFAC sanctioned 14 individuals, entities, and aircraft based in Iran, Türkiye, and the United Arab Emirates (UAE) for their alleged involvement in procuring or transporting weapons or weapons components on behalf of the Iranian regime. In a statement accompanying the designations, Secretary of the Treasury Scott Bessent said that “as part of Economic Fury, Treasury will continue to follow the money and target the Iranian regime’s recklessness and those who enable it.”

Among those targeted by OFAC were three Iranian nationals who were alleged to have facilitated payments or shipments to Iran-based Pishgam Electronic Safeh Company (PESC), a company that was sanctioned on September 27, 2023, for procuring thousands of servomotors for Iran’s UAV program. Also included in the designations were individuals and entities that allegedly provide support or are otherwise linked to Mahan Air, which was sanctioned by OFAC on October 12, 2011, and two of Mahan Air’s aircraft.

In addition, on April 24, 2026, OFAC sanctioned China-based teapot refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. (Hengli) for allegedly being one of Iran’s largest customers for crude oil and other petroleum products. OFAC also sanctioned 40 shipping firms and vessels that allegedly operate as part of Iran’s shadow fleet. Since February 2025, OFAC has sanctioned over 1,000 Iranian-related persons, vessels, and aircraft as part of President Trump’s reinstated “maximum pressure” campaign under National Security Presidential Memorandum 2.

These are the third and fourth tranches of sanctions issued under Economic Fury, following those issued by OFAC on April 15 and April 17, 2026.

Treasury Imposes Sanctions on Opioid Procurement Network Tied to Sinaloa Cartel

On April 23, 2026, OFAC sanctioned 23 individuals and entities it alleged comprise a “sophisticated synthetic opioid procurement network with ties to the Sinaloa Cartel,” a designated Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT). The individuals and entities targeted by OFAC include chemical suppliers and brokers in India, Guatemala, and Mexico, and include two Mexican nationals alleged to have smuggled or produced fentanyl specifically for the Los Mayos or Los Chapitos factions of the Sinaloa Cartel.

In an accompanying statement, Secretary of the Treasury Scott Bessent said that the Treasury will not allow “terrorist cartels… to wreak havoc on our borders and in our communities,” and that it will continue to “target every stage of the opioid supply chain to Keep America Safe.” Bessent’s statement aligns with President Trump’s EO 14157 from January 20, 2025, which called for the “total elimination” of cartels’ presence in and ability to threaten the United States.

UK Developments

UK Removes Selected Syria Trade Sanctions on Luxury and Precious Goods

The UK has amended its Syria sanctions regime through the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2026, which came into force on April 22, 2026. The amendments remove trade prohibitions relating to gold, precious metals, diamonds, and luxury goods by revoking the relevant provisions of the 2019 Syria Regulations. As a result, UK persons are no longer restricted from exporting or importing gold, precious metals, and diamonds to or from Syria, nor from supplying luxury goods to persons in or connected with Syria.

The changes form part of a broader easing of certain sectoral restrictions introduced in 2025 and are accompanied by technical updates to the regime. However, the core Syria sanctions framework remains in place, including asset freezes, financial restrictions, and other trade and services prohibitions. Businesses should therefore continue to assess Syria-related activity carefully, as broader compliance obligations and designation risks remain unchanged despite the targeted relaxation of these trade measures.

UK Introduces End-Use Controls to Tighten Sanctions Enforcement on Diversion Risk

The UK has significantly strengthened its trade sanctions framework through the introduction of the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (the “Regulations”) and accompanying guidance from OTSI (the “Guidance”). The changes introduce targeted trade sanctions and end-use controls (“SEUC”), allowing the UK government to require exporters to obtain a licence where there is a risk that goods exported to non-sanctioned third countries could be diverted to sanctioned destinations or persons connected with such destinations, particularly but not limited to Russia. This closes a key gap in the regime, where such exports could previously proceed despite known diversion risks. The Regulations come into force on May 13, 2026.

The new requirement is triggered by a formal notification to the exporter by the Department for Business and Trade, after which a licence must be obtained before the export can proceed. The Guidance confirms that the SEUC will be used selectively and, in an intelligence-led manner, focusing on high-risk goods, routes, and counterparties. Licence applications will be assessed on a case-by-case basis, considering factors such as the nature of the goods, end-user risk, and the exporter’s compliance history. Russia is identified as the primary initial focus of these measures.

For businesses, the implications are material. Exporters must be prepared to respond quickly to UK government notifications and ensure that due diligence processes can identify and escalate diversion risks. Non-compliance may lead to detention of goods, monetary penalties, public enforcement action, and potential criminal liability, reinforcing the UK’s shift toward a more proactive and risk-based sanctions enforcement model.

UK Confirms Updates to Sanctions Regulations under Miscellaneous Amendments Regulations 2026

The UK has implemented further changes to its sanctions framework through the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (the “Regulations”), which come into force on May 13, 2026. The amendments introduce a number of technical and operational updates aimed at improving alignment with other regulatory regimes and streamlining sanctions administration. Key changes include updating the reporting threshold for “relevant firms”, such as financial institutions, high-value dealers, and art market participants, from €10,000 to £10,000, aligning sanctions obligations with the UK’s anti-money laundering framework. The Regulations also confirm that licensing authorities may issue notices electronically without prior consent, reflecting existing practice, and clarify that the HM Treasury debt exception applies across the full payment chain, including intermediaries. In addition, the prior obligations licensing ground has been broadened to provide greater flexibility in licensing legitimate pre-designation obligations, while maintaining safeguards against circumvention.

OTSI Expands Licensing Remit for Sanctioned Goods Now in Force

The UK Government has updated its guidance to reflect that OTSI has formally expanded its licensing remit, with effect from April 27, 2026, to include responsibility for licensing the export of all sanctioned goods, technology, and associated ancillary services (with the exception of military and dual-use items subject to UK strategic export controls) to sanctioned destinations. This marks a significant shift in the UK’s trade sanctions framework, building on OTSI’s existing role in licensing standalone services such as professional and business services. Responsibility for goods and services subject to strategic export controls, including where they overlap with sanctions, remains with the Export Control Joint Unit. The application process remains unchanged, with exporters continuing to submit licence applications via the Department for Business and Trade’s SPIRE platform. OTSI now assesses relevant applications and, where appropriate, issues Standard Individual Export Licences to ensure alignment with HM Revenue and Customs and Border Force processes.

EU Developments

EU Council Adopts 20th Sanctions Package Against Russia

On April 23, the EU Council formally adopted its 20th sanctions package against Russia, ending months of deadlock caused by opposition from Slovakia and Hungary. The new sanctions package marks the largest set of new designations under EU asset freeze sanctions in two years, adding 120 individuals and entities, and expands sectoral sanctions across energy, finance, trade, and military sectors. In addition, the sanctions framework under Decision 2012/642/CFSP and Regulation (EC) 765/200 targeting Belarus has been aligned with the newly adopted measures against Russia.

In the trade sector, the package expands existing export bans to include items and technologies used for Russia's military effort, such as explosives, laboratory glassware, and high‑performance lubricants and additives for lubricants, articles made of steel, tools for metal production, and industrial tractors. It also extends import bans of goods generating significant revenues for Russia, including certain raw materials, metals, minerals, scrap of steel and other metals, chemicals, articles of vulcanized rubber, and tanned furskins. The package further introduces a quota on ammonia imports.

In the financial sector, the 20th sanctions package imposes a transaction ban on 20 additional Russian banks, bringing the total number of sanctioned financial institutions to 70. The EU has also targeted four banks in Kyrgyzstan, Laos, and Azerbaijan with a transaction ban for facilitating sanctions evasion or connecting to the Russian banking messaging network, the System for Transfer of Financial Messages (SPFS). The package introduces a sectoral ban on conducting exchanges with any Russian crypto-asset service provider and with any decentralized platform that enables crypto trading, due to their use in circumventing sanctions. It also prohibits any transaction involving RUBx, a rouble-backed stablecoin, as well as the digital rouble, a currency under development by the Central Bank of Russia intended to facilitate sanctions evasion.

In the military sector, the package designates 58 Russian companies and associated individuals involved in the development and manufacturing of military goods, including drones. To address Russia’s reliance on third countries for the supply of high-priority items that enhance its defense sector, the EU has also designated 16 entities based in China, Türkiye, the United Arab Emirates, Uzbekistan, Kazakhstan, and Belarus. Furthermore, 60 entities, located in Russia and in third countries such as China, including Hong Kong, Türkiye, and the United Arab Emirates, are now subject to additional export restrictions on items contributing to the technological advancement of Russia’s defense capabilities.

Additional measures include the designation of individuals and entities involved in the abduction, forced transfer, and indoctrination of Ukrainian children, as well as those responsible for the looting of Ukrainian cultural heritage.

Lastly, with regard to the energy sector, the restrictive measures introduced in the 20th sanctions package are detailed in the Lede.

EU Council Renews Moldova Sanctions Framework

The EU Council has renewed the restrictive measures in view of actions destabilizing the Republic of Moldova for another year until April 29, 2027. The sanctions framework targets individuals and entities responsible for, supporting, or implementing actions or policies that undermine the sovereignty and independence of the Republic of Moldova.

Currently, the EU restrictive measures apply to 23 individuals and 5 entities, and comprise asset freezes, a prohibition on making funds or economic resources available, and travel bans within the EU.

In parallel, the EU Council reviewed the sanctions list to amend the entries of seven designated persons.

EU Council Revises Russia Sanctions Listing Over Hybrid Activities

The EU Council listed two additional entities under its sanctions regime targeting Russia’s destabilising activities, due to their role in ongoing hybrid threats against the EU, its Member States, and partners. The newly listed entities are Euromore, a Brussels-based media platform operating within the pro-Kremlin information network and acting as an unofficial media relay for Russian narratives and disinformation, and the Foundation for the Support and Protection of the Rights of Compatriots Living Abroad (Pravfond), a Moscow state-funded organization used to promote propaganda narratives about Ukraine and reinforce key Kremlin talking points.

With these additions, the sanctions regime now applies to a total of 69 individuals and 19 entities. The restrictive measures include asset freezes and a prohibition on making funds or economic resources available.

EU Council Updates Sanctions Listing Targeting Sudan

The EU Council recently amended the listing under the sanctions framework in view of activities undermining the stability and political transition of Sudan. Specifically, the entries of four commanders and leaders of the Rapid Support Forces (RSF) were deleted from the Annex to Decision (CFSP) 2023/2135. The EU Council had already listed these four individuals under sanctions in view of the situation in Sudan, as adopted on March 5 by Council Implementing Decision (CFSP) 2026/529, following an update from the United Nations Security Council Committee.

Asia-Pacific Developments

China Targets 7 European Firms in Retaliation Against EU Sanctions

On April 24, 2026, Beijing moved swiftly to impose countermeasures in response to the European Union’s imposition of sanctions against Russia, which included multiple Chinese firms accused of supplying dual-use goods and high-tech components to Moscow’s military sector. After the EU’s announcement, China placed seven European defense and electronics firms on its export control list, thereby prohibiting the sale or transfer of Chinese-origin dual-use items to them. The targeted companies include major contractors from Germany, Belgium, and the Czech Republic. The Ministry of Commerce (MOFCOM) condemned the EU’s decision as an exercise of “long-arm jurisdiction” and a breach of mutual trust, reiterating China’s firm opposition to unilateral sanctions imposed without authorization from the United Nations Security Council.

India to Divest from Chabahar Port as US Sanction Waiver Expires

On April 24, 2026, reports indicated that India planned to divest its stake in Iran’s Chabahar Port, transferring control to a local Iranian entity ahead of the expiration of the extended US sanctions waiver on April 26, 2026. India Ports Global Ltd (IPGL) would sell its holding in the India Ports Global Chabahar Free Zone, under an arrangement allowing control to revert to India if sanctions are lifted or a new waiver is secured. Since 2018, India has benefited from exemptions, investing approximately USD 120 million in equipment for the project, which has been widely described as the “Golden Gate” to West and Central Asia. The port is a key link in the “International North–South Transport Corridor,” enabling India to transport goods to Russia and Afghanistan, bypassing routes denied by Pakistan. Previously, New Delhi had considered continuing operations despite US sanctions, but legal experts cautioned that such defiance could expose associated companies to punitive measures, potentially undermining India’s broader ambitions in global port operations.

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