The Graham Act creates immediate compliance risks beyond companies that trade directly with Russia by authorizing tariffs on all goods from major buyers of Russian energy, codifying much of the existing U.S. sanctions regime, and increasing secondary-sanctions exposure for foreign financial institutions. Treasury’s additional Iran-related designation of VTB Bank compounds that banking risk, while the EU’s removal of Alisher Usmanov and Mikhail Fridman—and their continued designation under Latvian and Estonian national sanctions—underscores the need for jurisdiction-specific screening.

OFAC’s new Sanctions Penalties Regulations, effective September 25, 2026, consolidate the enforcement procedures and penalty provisions for IEEPA- and UNPA-based sanctions programs in 31 C.F.R. Part 505. Although OFAC describes the rule as non-substantive, it has immediate compliance consequences: entity settlements and civil penalties must be disclosed publicly at least monthly; respondents have 30 days to contest a Pre-Penalty Notice or initial Finding of Violation; and criminal violations now carry an express willfulness standard, while civil liability remains strict.

OFAC’s latest rules tighten Cuba sanctions by restricting intermediary payments, withdrawing authorization for certain dollar transfers and private-sector bank accounts, and narrowing educational and professional travel permissions. Effective September 30, 2026, the changes require prompt review of payment processing, affected accounts, and planned travel. Separate rules codify existing Iran and Cuba sanctions authorities and consolidate administrative provisions without repealing underlying compliance obligations. OFAC announcement

The changes primarily reorganize existing rules and reflect sanctions relief already granted. OFAC’s new penalties regulations preserve existing enforcement provisions, while the Syria amendment removes an authorization made unnecessary by the country’s earlier delisting.

The compromise preserves EU restrictions on more than 2,600 Russia-linked targets until 2029 but lifts EU-wide asset freezes and travel bans on Usmanov and Fridman. Latvia objected that the delistings weakened pressure on Moscow, ultimately abstaining to save the broader regime while imposing national sanctions on both men.

Carlyle’s bid for Lukoil’s international business is facing a challenge from a rival consortium backed by the White House and Gulf investors, complicating a deal that has OFAC clearance but still awaits final Trump administration approval, the Financial Times reported.

The delistings lift sanctions imposed in 2017 over Olenga’s leadership of the Republican Guard, which Treasury accused of suppressing political opposition and undermining democratic processes under then-President Joseph Kabila. Safari Club was sanctioned because Olenga owned or controlled it.

Latvia has blocked a proposed compromise that would have removed Russian-linked billionaires Alisher Usmanov and Mikhail Fridman from the European Union’s sanctions list while extending restrictions on more than 2,600 other individuals and entities.

The expiration ends the sanctions imposed under E.O. 14046 on six Eritrean parties originally designated for contributing to the conflict in northern Ethiopia or supporting those involved. The action comes as UNHCR and European assessments continue to document protection risks, conflict-related abuses and failures of accountability

The U.S. Treasury Department’s Office of Foreign Assets Control removed a Mexican associate of the Sinaloa Cartel, a Swiss national associated with Russian Intelligence, and a Turkish firm responsible for exporting prohibited metalworking equipment to Russia. ater in the week, the Treasury removed two Belarus state-owned firms.

The measure would sanction Russian officials, financial institutions, energy projects, and vessels associated with sanctions evasion. It also would direct the president to impose additional tariffs of up to 100 percent on goods from countries that continue qualifying purchases of Russian crude oil or natural gas and rank among the five largest importers by volume during the 12 months preceding enactment.

Treasury’s new Iran-related designation of VTB increases sanctions exposure for foreign banks that have maintained correspondent relationships with the already blocked Russian lender, putting their access to the U.S. financial system at risk. The practical impact will be difficult to gauge: VTB’s disconnection from SWIFT in 2022 removed an important source of payment-network visibility, and Treasury has disclosed neither the extent of its remaining correspondent relationships nor the transaction volumes involved.

House Republican leaders have scheduled the Senate-passed Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 for consideration during the week of September 14, reviving legislation that appeared unlikely to reach the House floor before the midterm elections.

The policy sharply reduces the prospect of OFAC approval for otherwise prohibited Iran transactions, including many pending requests.

The extension gives diamond dealers and jewelers another year to import qualifying Russian or unknown-origin stones that were already outside Russia before the G7 restrictions took effect. It offers relief for pre-ban inventories that might otherwise be stranded, while leaving the prohibition on newly mined Russian diamonds in place.

OFAC’s September 9 guidance refresh has practical consequences for sanctions compliance: the agency expressly states that it will not confirm screening matches or false positives, placing emphasis on firms’ documented, risk-based decisions, and recommends seeking specific-license renewals at least 60 days before expiration.

Carriers, freight forwarders and other logistics providers face greater exposure in China when declining or interrupting shipments over U.S. sanctions and export-control concerns, according to a recent alert from Morrison Foerster.

The United Kingdom will impose additional sanctions on Iran’s energy, metals, gold and software sectors beginning Sept. 29, extending restrictions to related shipping, insurance and banking activity.

The action raises compliance risks for MRO companies, freight forwarders, aircraft brokers and parts suppliers in the UAE, Türkiye, Malaysia and other transit markets.

Treasury alleges Türkiye-based Golden Global Bank and two subsidiaries were established to help an Iranian financial network transfer oil revenue from China to Türkiye for conversion into cash and gold.