Sanctions in a Snap: Developments in Sanctions

Hughes Hubbard’s “Sanctions in a Snap” provides a clear and concise summary of recent developments from the United States' Office of Foreign Assets Control (OFAC) and the European Union and its Member States.

The U.S. edition is designed to help you quickly assess U.S. economic sanctions compliance risks in light of current government designation and enforcement priorities. While the EU edition covers European economic sanctions and export controls risks against the current EU regulatory framework and enforcement priorities.

Monthly Newsletters

Sanctions in a Snap: Developments in Sanctions March 2026

Highlights from March 2026 include unprecedented authorizations involving Russian and Iranian oil, a sanctions advisory providing factors that will lead to aggressive enforcement, and a $1.1 million civil monetary penalty demonstrating the importance of the testing and auditing component of sanctions compliance programs.

Sanctions in a Snap: Developments in Sanctions February 2026

Highlights from February 2026 include the largest civil monetary penalty assessed against an individual, the first civil monetary penalty assessed against an academic institution unrelated to Cuba travel and designations of government officials that signal upcoming economic pressure on Nicaragua.

Sanctions in a Snap: Developments in Sanctions January 2026 (EU Edition)

Highlights from January 2026 include a continued focus on Russia-related sanctions, the adoption of broad sanctions against Iran, and updates to the Sudan, Guatemala, Hamas and Palestinian Islamic Jihad sanctions programs.

Sanctions in a Snap: Developments in Sanctions January 2026

Highlights from January 2026 include OFAC authorizations for certain downstream activities involving Venezuelan oil and negotiations for the eventual acquisition of Lukoil’s international assets and a counternarcotics designation announcement that should inform compliance controls for transactions with Costa Rica’s Puerto Moin.

Sanctions in a Snap: Developments in Sanctions December 2025 (EU Edition)

Highlights from December 2025 include the introduction of a new designation criterion under the Belarus sanctions regime for individuals undermining democracy, the rule of law, stability and security; the use of Article 122 TFEU to immobilize Russian Central Bank assets in the EU; and the gradual phaseout of EU imports of Russian gas. This edition also provides updates on member states’ implementation of EU Directive 2024/1226 seeking to criminalize and harmonize EU sanctions enforcement, as well as new EU and national guidance and enforcement actions.

Sanctions in a Snap: Developments in Sanctions December 2025

Highlights from December 2025 include the third-largest civil monetary penalty ever assessed against an individual, an enforcement action that demonstrates the limits of the advice of counsel defense, and a designation that significantly enhances Colombia-related risk and may portend coming actions targeting Colombia.

Sanctions in a Snap: Developments in Sanctions November 2025 (EU Edition)

Highlights from November 2025 include new Russia-related designations under the Russia Human Rights sanctions program, the entry into force of the EU's amended dual-use list, the implementation by Malta of the EU directive on the criminalization of EU sanctions breaches, updated Syria- and Ukraine-related sanctions FAQs, a new EU enforcement initiative, and individual enforcement actions by member states including France, Germany and the Netherlands.

Sanctions in a Snap: Developments in Sanctions November 2025

Highlights from November include the largest-ever OFAC civil monetary penalty issued against an individual, continued responses to the blocking of Lukoil and the Foreign Terrorist Organization (FTO) designation of the Venezuela-based Cartel de los Soles.

Sanctions in a Snap: Developments in Sanctions October 2025 (EU Edition)

Highlights from October 2025 include the EU’s adoption of its 19th sanctions package against Russia, updated guidance on (i) dual-use and advanced technology export controls, (ii) an import ban on refined oil originating from Russian crude, and select case law and enforcement actions, including the European Court of Justice’s (ECJ) confirmation of reporting obligations for individuals subject to asset-freezing measures, France’s detention of crew members aboard a Russian-linked oil tanker suspected of sanctions evasion, and Denmark’s issuance of its first fine under the Russia sanctions regime for an attempted export of dual-use goods.

Sanctions in a Snap: Developments in Sanctions October 2025

Highlights from October 2025 include the first Russia-related sanctions imposed by the second Trump administration; designations of the current Colombian president, first lady and minister of the interior; and U.S.-U.K. coordinated actions against an alleged international online scam network.

Sanctions in a Snap: Developments in Sanctions September 2025

Highlights from September 2025 include civil monetary penalties against a freight forwarder and a digital asset platform that set forth clear compliance expectations. Companies should also carefully consider the Mexican cartel and fentanyl-related designation actions described below, which portend significant OFAC focus on Rosarito, Mexico, and online pharmacies.