Sanctions Watch | Weekly Vol. 175

Sanctions Watch Vol 175

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

1. OFAC Updates Russia and Iran Sanctions Licensing, Extending Lukoil Authorizations and Setting Iraq Development Bank Wind-Down Deadline

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three general licenses affecting sanctions-related transactions involving Russia-linked Lukoil entities and Iraq Development Bank.

Under Russia General License 130B, OFAC authorized transactions involving specified Lukoil entities in Bulgaria—including Lukoil Neftohim Burgas JSC, Lukoil Bulgaria EOOD, Lukoil Aviation Bulgaria EOOD, and Lukoil Bulgaria Bunker EOOD—through April 24, 2027. The license supersedes General License 130A.

Separately, General License 128D permits certain transactions involving Lukoil International GmbH and its majority-owned entities that are necessary for purchasing goods and services from, maintaining, operating, or winding down physical retail service stations outside Russia. This authorization also runs through April 24, 2027, while excluding, among other things, transfers of funds to persons or accounts located in Russia.

For Iran-related sanctions, General License FF authorizes transactions ordinarily incident and necessary to wind down dealings involving International Development Bank for Investment and Finance, also known as Iraq Development Bank, through October 30, 2026. Payments to blocked people must be placed in blocked accounts. Together, the measures provide targeted, time-limited licensing relief while maintaining broader sanctions restrictions.

2. OFAC Extends Venezuela Earthquake Relief Authorization Through April 2027

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 60A, extending authorization for transactions related to earthquake relief efforts in Venezuela.

The license permits transactions that would otherwise be prohibited under the Venezuela Sanctions Regulations when they are connected to earthquake relief activities. The authorization remains effective through April 21, 2027. It also allows the processing or transfer of funds involving third-country persons to or from Venezuela when those transactions support authorized relief efforts.

U.S. financial institutions and registered money transmitters may rely on information provided by the originator of a funds transfer, provided they do not know or have reason to believe that the transaction falls outside the scope of the authorization.

The license does not permit the unblocking of property already blocked under the Venezuela Sanctions Regulations and does not authorize activities prohibited under other applicable U.S. sanctions authorities. General License 60A replaces and supersedes General License 60, effective October 16, 2026.

3. Canada Clarifies Deemed Ownership Rules, Confirming Aggregate 50% Threshold and Broader Control Tests Under Sanctions Regime

The Government of Canada has updated its guidance on deemed ownership under Canadian sanctions, clarifying how ownership and control are assessed under the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA).

Under the guidance, an unlisted entity may be treated as owned by a listed person where that person controls the entity directly or indirectly. Canada applies three principal control tests: holding 50% or more of shares, ownership interests, or voting rights; having the ability to change the composition or powers of the entity’s board; or being able, based on the circumstances, to direct the entity’s activities.

Importantly, Canada confirms that ownership interests held by multiple listed persons are aggregated. If listed persons collectively hold 50% or more of an entity, the entity may be deemed controlled and become subject to applicable dealings prohibitions.

The guidance also emphasizes that control can exist below the 50% ownership threshold where a listed person can influence board appointments or exercise de facto control. Indicators may include shareholder agreements, dominant influence, buyback arrangements, transfers to connected people, use of proxies, trusts, shell companies, or other structures designed to obscure control.

Canadian persons and businesses are therefore encouraged to conduct rigorous sanctions due diligence and assess both formal ownership and practical control when dealing with potentially sanctions-exposed entities.

4. Switzerland Updates Iran Sanctions Authorization Form for Money

Transfers Under Article 21
Switzerland’s Federal Department of Economic Affairs, Education and Research (EAER) announced an update to the authorisation form for money transfers under Article 21 of the Ordinance on Measures against the Islamic Republic of Iran. The update was issued through the State Secretariat for Economic Affairs (SECO) as part of Switzerland’s administration of sanctions and embargo measures concerning Iran.
According to the notice, the revised authorisation form became effective immediately on 13 October 2026, and SECO will accept only the updated version from that date onward.
The change is procedural and relates specifically to the documentation required for money-transfer authorisation requests under Article 21. Businesses, financial institutions, compliance teams, and other parties handling transactions connected to Iran should therefore ensure that any relevant submissions use the latest SECO form.
The update reinforces the importance of maintaining current sanctions-compliance documentation and reviewing administrative requirements when processing transactions that may fall within Switzerland’s Iran sanctions framework.

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