On June 22, 2026, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a new general license (Iran General License X or “GL X”) as the first step in implementing the US-Iran Memorandum of Understanding (“MOU”) to
Sanctions & Export Controls Update
The Sanctions & Export Controls Update blog, published by Baker McKenzie, focuses on legal developments and regulatory changes related to international sanctions and export control regimes. It covers topics such as updates on sanctions imposed by governments and international bodies, compliance requirements for businesses, enforcement actions, licensing procedures, and the impact of sanctions on cross-border trade and transactions. The blog also addresses specific country sanctions, dual-use goods regulations, and coordinated international sanctions efforts, providing insights relevant to multinational corporations, legal practitioners, and compliance professionals navigating complex sanctions landscapes.
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UK Expands Russia Sanctions to Further Target Shadow Fleet, Military Procurement, and Financial Networks
On 16 June 2026, the UK announced a new package of sanctions under its Russian sanctions regime. The package targets Russia’s shadow fleet, financial networks, military procurement channels, and broader support infrastructure. In total, 70 individuals and entities have been…
OFAC Updates Venezuela General Licenses and Issues New Venezuela FAQs
On June 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a suite of updated Venezuela-related general licenses (“GLs”) that slightly ease certain licensing conditions related to governing law and dispute resolution clauses in…
OFAC Publishes List of Medical Devices Excluded From the General License for Non-US Agricultural Commodities, Medicine, and Medical Devices Destined for North Korea
On June 11, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) published in the Federal Register the List of Medical Devices Requiring Specific Authorization under the North Korea Sanctions Regulations, 31 CFR Part 510 (“NKSR“).…
US Government Updates 1260H List of Chinese Military Companies
On June 8, 2026, the US Department of Defense (“DoD”) published an update to its list of “Chinese military companies” (“CMCs”) operating directly or indirectly in the United States (the “1260H List”), pursuant to Section 1260H of the National Defense…
OFAC Expands Guidance on Strait of Hormuz “Safe Passage” Restrictions
Since issuing its Frequently Asked Questions (“FAQ”) 1249 on April 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has updated its position with respect to “toll” payments to Iran for safe passage through the…
EU: Commission Announces 21st Sanctions Package against Russia Targeting Energy, Financial Sector and Trade
On 9 June 2026, European Commission President Ursula von der Leyen announced that the European Commission is preparing a 21st sanctions package against Russia, marking a further step in the EU’s ongoing effort to intensify economic pressure following Russia’s continued…
US Continues to Expand Cuba Sanctions: New SDN Designations and Secondary Sanctions Guidance
On June 4, 2026, the US Department of State announced a new round of designations under Executive Order 14404 (“EO 14404“) targeting five entities and five individuals for being “associated with developing, implementing, and funding the Cuban regime’s violent revolutionary
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Spain’s Export Controls Regime: Recent Developments and What Comes Next
Spain’s Secretaría General de Comercio (General Secretariat for Trade) recently held an informational briefing outlining significant developments in the country’s export control framework. The session addressed both recently implemented measures and upcoming regulatory changes that are expected to reshape the way…
BIS Clarifies That License Requirements for Advanced Computing Items to Country Group D:5- and Macau-Headquartered Entities Remain in Force Despite AI Diffusion Rule Non-Enforcement
On May 31, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance clarifying that a license continues to be required under the Export Administration Regulations (“EAR”) for exports of advanced computing items to entities located…