Sanctions Watch | Weekly Vol. 165

Sanctions Watch Vol 165

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

OFSI Expands Russia Sanctions Exemptions, Adds Kurdistan Export Pipeline to Protected Energy Projects

The UK Office of Financial Sanctions Implementation (OFSI) has amended General Licence INT/2025/5635700, expanding sanctions exemptions for specified international energy projects under the Russia (Sanctions) (EU Exit) Regulations 2019.

Effective 31 July 2026, the amendment adds the Kurdistan Export Pipeline to the list of Exempt Projects, allowing qualifying business operations and related payments from that date until 14 October 2027. The licence facilitates certain transactions involving relevant subsidiaries connected to sanctioned Russian energy companies, including Gazpromneft-Sakhalin, LUKOIL, Rosneft and Transneft, where those activities relate specifically to an exempt project.

The licence also covers several strategically significant energy projects, including the Caspian Pipeline Consortium, TengizChevroil, Shah Deniz, South Caucasus Pipeline, Azerbaijan Gas Supply Company, Karachaganak, Zohr and Druzhba Pipeline, with their current exemptions running until 14 October 2027.

UK financial institutions may process payments permitted under the licence, while businesses can undertake specified operations and exercise certain shareholder rights. However, the exemption does not permit the sale of shares in Exempt Project companies. Parties using the licence must maintain accurate and complete records of relevant activities for at least six years.

New Zealand Unveils 36th Russia Sanctions Package, Targeting Cyber Actors and Ukrainian Child Abductions

New Zealand announced its 36th round of sanctions against Russia, designating 33 individuals and entities linked to activities supporting Russia’s war against Ukraine.

The latest package places particular emphasis on malicious cyber actors and individuals and entities involved in the forced relocation, abduction, and re-education of Ukrainian children through state-directed programmes. Foreign Minister Winston Peters highlighted New Zealand’s concern over the use of children in the conflict and the growing role of cyber actors in intelligence gathering, sanctions, evasion and disruption.

The sanctions also target individuals involved in creating and disseminating anti-Ukraine propaganda, as well as actors contributing to Russia’s military-industrial complex and Russian political figures. In addition, the package covers actors from North Korea (DPRK) and Iran accused of providing support to Russia’s invasion.

Since the Russia Sanctions Act entered into force in March 2022, New Zealand has imposed sanctions on more than 2,000 individuals, entities and vessels, alongside various trade restrictions. The latest measures reinforce New Zealand’s continuing coordination with international partners in applying economic and diplomatic pressure on Russia.

Isle of Man FIU Updates SAR Guidance, Strengthening Financial Sanctions Breach and Frozen Asset Reporting Requirements

The Isle of Man Financial Intelligence Unit (FIU) has updated its guidance for Suspicious Activity Reports (SARs) and other disclosures in August 2026, providing clearer requirements for reporting financial sanctions breaches, frozen assets and other financial crime concerns.

Under the updated guidance, businesses and professionals in the Isle of Man must check whether they hold or control funds or economic resources belonging to sanctioned individuals or entities. Where such assets are identified, they must be frozen and reported to the FIU through the Themis reporting system. Suspected and attempted sanctions breaches must also be reported as soon as practicable.

The FIU clarifies that suspected breaches of Isle of Man, UK or UN sanctions should be reported through the dedicated sanctions-breach option in Themis, while frozen assets should be reported separately under the “Sanctions – Frozen Assets” category. Matters involving other sanctions regimes, including OFAC designations, should generally be disclosed under Section 24 of the FIU Act where there is no suspicion of money laundering or terrorist financing.

The guidance also confirms that the FIU is responsible for receiving and analyzing intelligence concerning suspected sanctions breaches, while Customs and Immigration retains responsibility for investigating potential violations.

China Tightens Exit and Entry Rules with Stronger Verification, Fraud Penalties and Sponsor Accountability

China’s State Council has issued new Regulations on Exit and Entry Administration (State Council Decree No. 841), scheduled to take effect on 15 September 2026. The regulations strengthen the compliance framework governing Chinese citizens travelling abroad, foreign nationals entering and residing in China, and immigration service providers.

The new rules give immigration and visa authorities greater scope to verify applicants’ identities and travel purposes, request supporting documents and electronic information, and conduct additional reviews. Organizations and individuals issuing invitation letters or supporting documentation will also face explicit responsibility for ensuring that information provided is authentic and accurate.

Enforcement against immigration fraud and misrepresentation is strengthened, including false documents, declarations and fraudulently obtained immigration documents. Foreign nationals may face visa or entry refusals and, depending on the circumstances, entry bans of one to five years.

The regulations also introduce a nationwide regulatory framework for immigration service providers, requiring filing procedures, internal compliance controls, qualified personnel and protection of clients’ personal information.

Employers are encouraged to strengthen document verification, maintain supporting records and ensure invitation letters accurately reflect travel purposes. Further national and local implementation guidance is expected, meaning businesses and foreign nationals should monitor how the requirements are applied across different Chinese provinces and municipalities.Know more about the product: PreScreening.io

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