October 2026

OVERVIEW

Russia and Iran remained the focus of international sanctions throughout October.  The EU listed 77 people for involvement in elections in occupied Ukraine, and the UK targeted Russia’s energy revenues, military procurement and human rights abuses.  Whilst the US waived new restrictions on Russiaintroduced only a month ago, it sanctioned 28 companies in Iran’s automative and rail-sectors, alongside successive packages targeting shipping, weapons procurement and shadow banking. The UK separately sanctioned two Iranians after the suspected planned terrorist attack at RAF Fairford.

The US designation of the International Criminal Court (ICC) has been criticised by the UK, Canada and several other governments.  The US claimed the action defends its sovereignty as it added the entity to the 17 already-designated individuals under the ICC programme.  More widely, the UK expanded its global human rights sanctions powers, and the US, UK, EU and UN implemented further measures concerning Sudan, Rwanda and North Korean revenue-generation networks.

Bank of America was the primary target of enforcement in the US this month, receiving approximately $1.21 billion in penalties for over 470 sanctions breaches between September 2021 and April 2025, as well as reported wilful reporting failures for suspicious-transactions.  OFAC separately agreed settlements totalling $1.7 million with companies over apparent violations of sanctions involving exports to Russia and China.

Russia

• Less than one month after President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act, he issued an executive order indefinitely waiving the majority of the Russian sanctions and duties introduced by the Act.  The waived measures relate to imports from Russia and countries that purchase Russian-origin crude oil or natural gas or facilitate Russian oil sanctions evasion, as well as sanctions on certain persons and financial institutions affiliated with the Kremlin. The waiver has been criticised by Ukrainian president Zelensky and several US congressmen from both the Republican and Democrat parties for enabling Vladimir Putin to continue the war in Ukraine.
• The UK imposed two packages covering 25 people, 24 entities and 20 ships.  The first targeted abuses against Ukrainian civilians, the deportation and re-education of children, and Russian energy interests.  The second targeted oil production and transport, military suppliers and financial circumvention, including Zarubezhneft, Stolichny Kredit and Kyrgyz payment processor Processing KG.  Five financial-sector entities also face internet-services restrictions.
• The EU sanctioned 74 candidates and three election commissioners involved in September’s Russian State Duma elections in occupied Ukraine.  It separately listed three people and nine entities for procurement, payment and shadow-fleet circumvention, including Movers Group and its director Dmitry Chudovsky.  The EU also renewed its Russia hybrid-threats framework until October 2027.

Iran

• As part of the expansion of sanctions on Iran, the US targeted its automative and railway sectors, designating car manufacturers Iran Khodro and SAIPA, and the state railway company amongother industrial interests.  Separate procurement measures targeted five people and eight entities supporting Iran’s military.  The US designated A7 as a transnational criminal organisation for alleged Iranian sanctions evasion, with the Financial Crimes Enforcement Network (“FinCEN”) proposing barring US financial institutions from transfers involving A7-controlled companies.FinCEN also announced cooperation with European partners investigating an unnamed Greek bank’s potential Iranian ties.
• The US imposed two shadow-fleet packages on Iran. The first listed six people, shipping companies and 22 vessels. The second targeted five people, four entities and nine vessels, including Panama- and Greece-based law firm Karnakis and Karnakis for registering vessel-owning companies. The US separately designated 16 people and 10 entities linked to shadow banking and oil revenues, including International Development Bank for Investment and Finance, accused of facilitating Iranian access to US dollars, and Jazireh International Bank Company. The US also renewed export-denial measures against Iranian airline Mahan Airways and 11 linked parties for one year, citing continuing apparent breaches.
• Following the arrest of several individuals in late September 2026 for suspicion of a planned terrorist attack on RAF Fairford, the UK announced that the attack was coordinated by the Iranian Revolutionary Guards Corps (“IRGC”). Several governments, including the US, UK, Canada, Australia and 25 European countries, signed a joint statement supporting the UK’s attribution of Iran’s involvement in the incident. The UK subsequently listed IRGC official Ruhollah Bazghandi and alleged criminal-network facilitator Shahram Ali Reza Tamarzadeh Jakki over suspected involvement.

 

 

Enforcement

 

Other Designations, De-Listings, and Regulatory Updates

• Having already imposed sanctions on 17 individuals at the ICC to date, the US Department of State designated the ICC itself on 9th October.  The State Department claimed the action defends US sovereignty and neutralises the threat posed by the ICC.  The UK, Canada, Japan, and several European governments opposed the designation.
• US counterterrorism and counternarcotics packages targeted 21 people and 25 entities linked to Sinaloa, nine people and two entities linked to Tren de Aragua, and four people and 11 entities linked to Cartel del Noreste.  Measures covered leadership, cash-machine cyberattacks and commercial financing networks.  Remaining in Latin America, the US designated Cuban bank Banco Internacional de Comercio SA for providing services to sanctioned Iranian lender Karafarin Bank.  Separate Hamas-financing measures covered three people and two entities, including France-based fundraisers allegedly collecting over $2 million.  The US also sanctioned five entities linked to the theft of US trade secrets by Chinese national Linwei Ding.
• In Africa, the UN extended its Sudan sanctions programme and the UK designated 15 commanders from Sudan’s Rapid Support Forces and Sudanese Armed Forces over suspected sexual violence and humanitarian-law breaches. The US sanctioned Rwanda’s Defence Ministry and Zigama Credit and Savings Society for supporting the Rwanda Defence Force, March 23 Movement and Congo River Alliance in the Democratic Republic of the Congo (“DRC”).  The EU amended its DRC regime, including military-trade restrictions and wider circumvention provisions.
• Focusing on North Korea, the US listed 10 people and one entity linked to a North Korean information technology worker scheme allegedly generating weapons-programme revenue through fabricated identities and appropriated wages.  The EU separately sanctioned three people and four entities supporting North Korean weapons programmes and prohibited cooperation with Russia.
• The UK expanded its global human rights regulations from 15th October, adding designation grounds for serious violations of liberty and personal security, international humanitarian law, and obstruction of humanitarian assistance.  Separately, it expanded destinations under three open general export licences covering military and dual-use goods.
• The US delisted Venezuelan parliamentary president Jorge Jesús Rodríguez Gómez without explanation, and removed Syria from its defence-export policy-of-denial list.  Venezuela licence amendments added methanol to authorised petrochemical products and extended earthquake-relief permissions until April 2027.  The EU renewed its chemical-weapons framework until 2031, with individual listings renewed annually, and extended its Nicaragua, Niger, Transnistrian-leadership and Islamic State/Al-Qaeda regimes until October 2027.