Sanctions Watch | Weekly Vol. 173

Sanctions Watch Vol 173

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

U.S. Treasury Broadens Venezuela Sanctions Authorizations for Oil, Petrochemicals, Electricity and New Investment

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three updated Venezuela General Licenses—46E, 48D and 49B—effective September 28, 2026, expanding authorized activity across Venezuela’s energy and petrochemical sectors.

General License 46E authorizes established U.S. entities to conduct transactions involving the lifting, export, sale, storage, marketing, purchase, delivery, transportation and refining of Venezuelan-origin oil and petrochemical products, subject to specified payment, contracting and reporting conditions. It excludes dealings involving certain Russia-, Iran-, North Korea-, Cuba- and China-linked parties, blocked property and blocked vessels.

General License 48D permits U.S. persons to supply goods, technology, software and services supporting Venezuelan oil, gas, petrochemical and electricity operations. It also covers related shipping, insurance, port services, maintenance and repairs, while imposing reporting obligations and restrictions on certain counterparties, payment structures, blocked vessels, new joint ventures and diluent exports.

General License 49B separately authorizes negotiations and entry into contingent contracts for new investment in Venezuela’s oil, gas, petrochemical and electricity sectors, including potential new joint ventures, provided actual performance remains subject to separate OFAC authorization.     venezuela_gl49b

All three licenses expressly include fertilizer products and precursor chemicals within the definition of petrochemical products.

OFAC Expands Cuba Sanctions Framework, Updates Iran Regulations and Streamlines Federal Sanctions Rules

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of regulatory and guidance updates affecting Cuba, Iran and OFAC’s broader sanctions framework.

OFAC is removing more than 100 duplicative subparts from its chapter of the Code of Federal Regulations and reorganizing provisions covering delegations of authority, recordkeeping, reporting requirements and the Paperwork Reduction Act to make it easier to locate.

OFAC is also amending the Iranian Transactions and Sanctions Regulations to incorporate Executive Order 13902, which authorizes sanctions targeting additional sectors of Iran’s economy.

For Cuba, OFAC is publishing regulations implementing Executive Order 14404 of May 1, 2026, concerning persons responsible for repression in Cuba and threats to U.S. national security and foreign policy. It is also amending the Cuban Assets Control Regulations, 31 C.F.R. Part 515, to implement elements of the President’s Cuba policy.

The regulatory changes are scheduled to take effect upon publication in the Federal Register on September 30, 2026. OFAC also issued five new Cuba-related FAQs (1271–1275), amended 29 existing Cuba FAQs, and published an alert titled “Expanded Sanctions Against Cuba,” highlighting heightened sanctions risks associated with Cuba-related transactions.

UK OFSI Amends Iran Sanctions General Licence for Shah Deniz Project

The UK Office of Financial Sanctions Implementation (OFSI) has amended General Licence INT/2025/7363752, which supports the continued operation of the Shah Deniz Project under the UK’s Iran nuclear sanctions framework. The licence was originally issued on 29 September 2025 under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019, allowing persons and relevant UK financial institutions to carry out activities necessary for the project’s continued operation.

Under the licence, permitted activities can include the provision of goods, services, financing and other support. However, no direct payment may be made to Naftiran Intertrade Company (NICO), identified as the designated person, or to any other designated person. Payments due to NICO must be handled so that funds or economic resources are not made directly available to the sanctioned entity.

Effective 29 September 2026, OFSI amended the licence to cover additional prohibitions relating to investments in Iran and insurance and reinsurance services under Regulations 17A and 17C. The licence does not permit conduct that would otherwise breach the Iran Nuclear Regulations beyond the activities specifically authorized by this or another applicable licence.

UK OFSI Extends Sakhalin-2 Exemption Under Russia Sanctions General Licence

The UK Office of Financial Sanctions Implementation (OFSI) has extended the Sakhalin-2 exemption under General Licence INT/2025/5635700, with the latest amendment taking effect on 1 October 2026. The licence, originally issued on 10 January 2025 under the Russia (Sanctions) (EU Exit) Regulations 2019, allows continued business operations with Gazpromneft-Sakhalin LLC and other relevant subsidiaries where activities relate to specified exempt projects.

The licence permits payments to or from relevant subsidiaries and third parties under new or existing obligations or contracts, provided those transactions relate to exempt projects.

The scope of the licence has expanded significantly since 2025. Following UK designations, entities owned or controlled by Lukoil, Rosneft and later Transneft were brought within the definition of relevant subsidiaries. Exempt projects have also been expanded to include the Caspian Pipeline Consortium, TengizChevroil, Shah Deniz, South Caucasus Pipeline, Azerbaijan Gas Supply Company, Karachaganak, Zohr, Druzhba Pipeline and, most recently before the October amendment, the Kurdistan Export Pipeline.

On 1 October 2026, OFSI further extended the Sakhalin-2 exemption. The licence does not authorise activities that would otherwise breach the Russia sanctions regulations unless separately permitted under an applicable licence.

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