Sanctions Watch | Weekly Vol. 176

Sanctions Watch Vol 176

In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

EU Clarifies Ban on Exporting Refined Petroleum Products to Russia

The European Commission has clarified that European Union operators are prohibited from exporting, selling, transferring or supplying refined petroleum products, including diesel, to Russia or for use in Russia. The clarification was issued on 23 October 2026 through updated frequently asked questions concerning Articles 3k and 3c of Council Regulation (EU) No 833/2014, which sets out restrictive measures adopted in response to Russia’s military aggression against Ukraine.

Under Article 3k, refined petroleum products falling under Combined Nomenclature (CN) code 2710 are included in Annex XXIII of the Regulation and are therefore subject to an export prohibition. The restrictions apply to transactions involving any natural or legal person, entity or body in Russia, as well as products intended for use within Russia.

The Commission also highlighted separate restrictions under Article 3c and Annex XX covering the export of jet fuel and certain fuel additives.

In addition to the direct supply of covered energy products, EU sanctions prohibit related services. These restrictions extend to the direct or indirect provision of technical assistance, brokering services, financing and financial assistance connected with refined petroleum products supplied to persons or entities in Russia or intended for use in the country.

Norway Implements EU’s 21st Sanctions Package Against Russia

Norway has implemented a new sanctions package against Russia aligned with the European Union’s 21st sanctions package, with the measures entering into force on 21 October 2026. Norway had politically endorsed the EU package on 11 August 2026. The measures target several areas, including the energy, financial and crypto sectors, Russia’s military-industrial complex, and vessels associated with the so-called shadow fleet.

The package expands transaction restrictions to additional financial institutions and extends prohibitions to certain refineries, Russian ports and airports. It also introduces new restrictions concerning crypto-asset service providers and expands export controls on dual-use goods and technologies, including certain metals, aerospace and defence materials, drone-related equipment and interception systems.

Energy-related measures include new exceptions and reporting requirements concerning transfers of Russian liquefied natural gas, as well as amendments affecting restrictions on Russian crude oil and petroleum products. Import restrictions are also broadened to cover additional commodities, including copper, nickel, lead and precious-metal ores, unwrought zinc and selected industrial goods.

Norway has also expanded vessel-listing criteria to cover ships providing services to already listed vessels or conducting ship-to-ship transfers with them, further strengthening enforcement against sanctions circumvention.

OFAC Issues New Iran and Russia General Licenses, Updates Lukoil Sanctions Guidance

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new Iran- and Russia-related general licenses on 21 October 2026, alongside amendments to Russia sanctions FAQs.

For Iran, General License GG authorizes, through 20 November 2026, transactions ordinarily necessary to wind down dealings involving Karnakis and Karnakis and entities it owns 50 percent or more. General License HH permits limited wind-down, safety, environmental, vessel-management and cargo-offloading activities involving specified blocked persons and vessels, also through 20 November 2026, subject to stated conditions and restrictions.

OFAC also issued Russia-related General License 131K, replacing General License 131J. GL 131K authorizes negotiations and entry into contingent contracts concerning the potential sale, disposition or transfer of Lukoil International GmbH and its majority-owned entities through 21 November 2026. It also permits certain maintenance and wind-down activities. However, the actual completion of any sale requires separate OFAC authorization, and funds may not be transferred to persons or accounts located in Russia.

Updated FAQs 1224 and 1225 further clarify permitted negotiations, due diligence, ordinary-course transactions and conditions OFAC may consider when reviewing a potential divestment of Lukoil International assets.

OFAC Issues PAIPA Sanctions Licenses and Wind-Down Authorization for Designated Chinese Investment Entities

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two general licenses on 19 October 2026 under the Protecting American Intellectual Property Act of 2022 (PAIPA), alongside related updates to the Non-SDN Menu Based Sanctions List.

PAIPA General License 1 authorizes transactions otherwise prohibited under PAIPA to the extent they are already authorized or exempt under the Cyber-Related Sanctions Regulations, including activities permitted through existing general or specific licenses. The authorization does not extend to transactions prohibited under other applicable sanctions authorities unless separately authorized.

PAIPA General License 2 provides a temporary wind-down authorization through 19 January 2027 for transactions involving five specified Chinese investment entities, including Qiji Chuangtan Beijing Investment Management Co Ltd, also known as MiraclePlus, and related venture capital and management entities. The authorization also applies to entities owned 50 percent or more, directly or indirectly, by the listed parties.

Any payment to a person subject to PAIPA blocking prohibitions must be placed in a blocked account located in the United States. The license does not authorize activities prohibited under other OFAC-administered sanctions programs unless separately licensed.

Know more about the product: PreScreening.io

Click here to book a free demo. 

Sanctions Watch is a weekly recap of events and news related to sanctions around the world.