The UK’s Office of Financial Sanctions Implementation (OFSI) has published details of a £390,000 penalty it imposed on ADI, an Irish subsidiary of Apple Inc., on 19 March 2026. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. Although the
Eight Takeaways After Seven Weeks of OFAC’s Six, wait Seven, New and Updated General Licenses for Venezuela
Introduction
Over the last two months, OFAC has issued and updated a series of general licenses and Frequently Asked Questions (FAQs) that allow for a variety of activities in the Venezuela oil, gas, petrochemical products, electricity, and gold sectors when they involve persons sanctioned pursuant to the Venezuela sanctions regulations, including the Government of Venezuela
OFAC Sanctions Rwanda’s Military
In what amounts to a material expansion of its existing sanctions program arising out of the conflict in the Democratic Republic of the Congo (“DRC”), on March 2, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against the Rwanda Defence Force (“RDF”)—an organization described by OFAC as Rwanda’s
Altomare SA and Kallista Removed from OFAC’s SDN List
On January 21, 2026, the U.S. Office of Foreign Assets Control (OFAC) announced the removal of Greek maritime company Altomare SA and its vessel, Kallista, from the Specially Designated Nationals and Blocked Persons Lists (SDN List).
OFAC originally designated Altomare SA and Kallista in November 2025 as part of a counter terrorism sanctions action
Key Takeaways from a Consequential Month of Russia-Related Sanctions
The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions the past month, including the Trump Administration’s first sanctions directly imposed on Russia. These coordinated actions—which particularly target the Russian energy sector—indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those
EU Adopts 19th Sanctions Package Against Russia
- LNG Import Ban: The EU will prohibit the purchase, import, or transfer, directly or indirectly, of Russian liquified natural gas (LNG) from 25
UK Sanctions Lukoil, Rosneft in Major Russia Sanctions Expansion
On October 15, 2025, the UK announced a significant expansion of its Russia-related sanctions regime, designating Lukoil and Rosneft—Russia’s two largest oil companies—as asset freeze targets.
This is the first time Lukoil and Rosneft have been subjected to full asset freezing sanctions by any of the UK, U.S., or EU, and follows earlier UK measures
Client Alert: Impending Deadline for UN Action on Iran: What the “Snapback” of Iran Sanctions Could Mean for Global Business
On August 28, France, Germany, and the UK (the E3) initiated a “snapback” process that will reimpose UN sanctions on Iran on September 27 unless the Security Council acts. On September 19, a resolution to extend sanctions relief failed to receive sufficient votes at the Security Council and was not adopted. If snapback occurs, previously
Client Alert: U.S. Departments of State and Treasury Issue Immediate Sanctions Relief for Syria
On May 23, 2025, the U.S. Departments of State (“State”) and the Treasury (“Treasury”) took actions that resulted in immediate sanctions relief for Syria. Specifically, Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”) pursuant to the Syrian Sanctions Regulations (“SySR”), the Weapons of Mass Destruction Proliferators Sanctions Regulations (“NPWMD”), the
New UK Sanctions on Russia Targeting Technology, Software and Additional Strategic Goods
- Software Sanctions: The UK has introduced a new prohibition on the transfer and