Sanctions Watch | Weekly Vol. 169

Sanctions Watch Vol 169

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

OFAC Expands Venezuela Coal, Minerals and Gold Authorizations While Issuing 2026 Blocked Property Reporting Guidance

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced major sanctions actions affecting Iran and Syria, marking sharply contrasting policy shifts toward the two countries.

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) updated three Venezuela-related general licenses covering coal, minerals and gold. General License (GL) 51D authorizes established U.S. entities to conduct certain transactions involving the export, sale, purchase, storage, delivery and transportation of Venezuelan-origin coal and minerals, including gold, subject to specified payment, contracting, counterparty and reporting conditions. GL 51D also requires transaction and supply-chain due-diligence reporting, initially within 10 days and every 30 days thereafter.

GL 54C authorizes U.S. persons to supply goods, technology, software and services supporting Venezuelan coal and minerals operations, including exploration, mining, processing, refining, production, logistics, insurance and maintenance. Transaction reports are required within 10 days of the first transaction and every 90 days thereafter.

GL 55A permits negotiations and entry into contingent contracts for new investment, expansion and joint ventures in Venezuela’s coal and minerals sectors, including gold. However, actual performance of such contracts remains subject to separate OFAC authorization. The licenses retain restrictions involving specified jurisdictions, blocked property and blocked vessels.

Separately, OFAC issued guidance for the 2026 Annual Report of Blocked Property (ARBP). Holders must report property blocked as of June 30, 2026, through the OFAC Reporting System by September 30, 2026, using the current reporting template. The guidance emphasizes accurate sanctions targets, program tags, valuations, asset details and Blocked/Rejected Report IDs to reduce incomplete or returned submissions.

OFAC Issues Iran General License CC Authorizing Limited Wind-Down Transactions with Golden Global Entities

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) CC under Executive Order 13902, which targets additional sectors of Iran. The license authorizes transactions ordinarily incident and necessary to wind down dealings involving certain people blocked on September 4, 2026.

The authorization remains valid through 12:01 a.m. EDT on September 19, 2026, and covers Golden Global Yatirim Bankasi Anonim Sirketi, Golden Global Varlik Kiralama Anonim Sirketi, and Golden Global Portfoy Yonetimi Anonim Sirketi, as well as entities in which one or more of these people directly or indirectly own, individually or collectively, a 50% or greater interest.

Any payment made to a covered blocked person during the wind-down period must be deposited into a blocked, interest-bearing account located in the United States.

GL CC does not broadly lift sanctions under Executive Order 13902. Transactions involving other persons blocked pursuant to the order remain prohibited unless separately authorized. Accordingly, organizations dealing with the identified entities should use the temporary authorization solely for permitted wind-down activities and ensure transactions are concluded within the specified authorization period.

OFAC Expands and Updates Sanctions Authorizations Covering Venezuela’s Oil, Gas, Minerals, and Telecommunications Sectors

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 4A under Executive Order 14404, which imposes sanctions on persons responsible for repression in Cuba and threats to U.S. national security and foreign policy.

GL 4A authorizes transactions involving persons blocked under E.O. 14404 when such transactions are ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in Cuba.

The license also authorizes transactions necessary for processing funds transfers and maintaining accounts for personal expenditures of employees, grantees and contractors of third-country diplomatic or consular missions, as well as people who share a common dwelling with them as family members.

However, GL 4A does not authorize the unblocking of any property or interests in property blocked pursuant to E.O. 14404.

Effective September 3, 2026, GL 4A replaces and supersedes General License 4, which was issued on July 23, 2026. The updated authorization therefore allows specified diplomatic and related personal financial activities involving blocked people while maintaining restrictions on previously blocked property.

Argentina Strengthens Sanctions Framework Against Unauthorized Oil and Gas Activities Around the Falkland/Malvinas Islands

Argentina issued Decree 868/2026, published in the Official Gazette on September 4, 2026, strengthening enforcement of Law No. 26.659 against unauthorized hydrocarbon exploration and exploitation on areas Argentina considers part of its continental shelf, including waters surrounding the Falkland/Malvinas, South Georgia and South Sandwich Islands.

Under the existing sanctions framework, individuals and companies that engage in prohibited hydrocarbon activities without authorization from Argentine authorities, participate directly or indirectly in companies conducting such activities, or provide related commercial, financial, logistical, technical, consulting or other services may face administrative sanctions. Violators can be disqualified from operating in Argentina for five to 20 years, while relevant hydrocarbon concessions may also be reverted to the national or provincial governments.

The decree designates Argentina’s Ministry of Foreign Affairs, International Trade and Worship as the enforcement authority and establishes an expedited administrative procedure. Alleged offenders generally receive 10 administrative business days to respond, after which authorities may impose applicable sanctions.

The measure also introduces compliance declarations for certain investment and hydrocarbon permits, requiring applicants and related parties to confirm compliance with Law No. 26.659.

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