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OFAC Advisory Warns: Sham Transactions Do Not Evade Sanctions

OFAC issued an advisory clarifying that sham transactions designed to evade sanctions do not extinguish a sanctioned person's interest in blocked property. The advisory identifies seven red flag categories indicating potential sham transactions, including commercially unreasonable transfers, transfers to family members or close associates, and unduly complex corporate structures. The guidance supplements OFAC's '50 Percent Rule' and applies a functional, totality of circumstances approach to sanctions compliance due diligence.

U.S. Steel Producers File CVD Petition Against Algeria

Clark Hill PLC reports that U.S. steel producers (Charter Steel, Commercial Metals Company, Liberty Steel USA, Nucor Corporation, and Optimus Steel LLC) filed a countervailing duty petition with the U.S. Department of Commerce targeting carbon and alloy steel wire rod imports from Algeria. The petitioners allege that Algerian producers/exporters receive countervailable subsidies from the Government of Algeria warranting remedial duties under U.S. law. Because Algeria is not a 'Subsidies Agreement' country, the case proceeds before Commerce without a parallel injury determination by the ITC at the preliminary stage.

Trump Overhauls Section 232 Tariffs on Patented Pharmaceutical Products

President Trump issued a Section 232 proclamation imposing tariffs up to 100% on patented pharmaceutical products and ingredients. Generic drugs, biosimilars, and specialty pharmaceuticals including orphan drugs and cell therapies are excluded. Companies with approved onshoring plans receive reduced rates of 20% until 2030, while those with pharmaceutical pricing agreements pay 0% until January 2029.

100% Tariffs on Patented Pharmaceuticals and APIs Under Section 232

The Trump Administration issued a proclamation on April 2, 2026 imposing Section 232 tariffs on patented pharmaceuticals and active pharmaceutical ingredients for the first time in the statute's history. The default tariff rate is 100% ad valorem, with reduced rates of 20% for companies with approved onshoring plans and 0% for those with both onshoring plans and MFN pricing agreements with HHS. Trade-deal countries receive preferential rates of 10-15%. Compliance deadlines are July 31, 2026 for 17 large Annex III companies and September 29, 2026 for all others.

Section 232 Tariffs Restructured for Metals, Pharmaceuticals

President Trump issued two Section 232 proclamations on April 2, 2026, restructuring steel, aluminum, and copper tariffs (effective April 6) and imposing 100% tariffs on patented pharmaceuticals (effective July 31 for large companies, September 29 for others). Importers of metals must now pay duties on full customs value rather than metal content alone, while pharmaceutical imports face significant new cost burdens.

CIT Orders CBP Refund IEEPA Duties

Kelley Drye & Warren LLP reports that the U.S. Court of International Trade ordered U.S. Customs and Border Protection to refund all IEEPA duties for importers in the Euro-Notitions Florida case, regardless of whether entries have been liquidated. Judge Eaton consolidated this case with the dismissed Atmus Filtration matter, continuing the IEEPA refund mechanism. The government appeal deadline is June 8, 2026, and CBP must provide a status update by April 14.

CBP Louisville Seizes $9.2M Counterfeit Jewelry, 1,588 Pieces

U.S. Customs and Border Protection officers at Louisville Port seized 1,588 pieces of counterfeit jewelry from two express consignment shipments originating from Hong Kong, with an estimated MSRP of $9.2 million if genuine. The shipments contained earrings, bracelets, necklaces, and rings bearing trademarks of Cartier, Chanel, Dior, Fendi, Gucci, Louis Vuitton, Tiffany, Van Cleef & Arpels, and Yves St. Laurent. CBP trade experts verified the items as counterfeit through coordination with trademark holders, and the goods were seized pursuant to CBP's statutory and regulatory authorities.

Rubio Meets Rutte, Discusses Ukraine War, NATO

Secretary of State Marco Rubio met with NATO Secretary General Mark Rutte on April 8, 2026. The two leaders discussed Operation Epic Fury, ongoing U.S.-led diplomatic efforts to negotiate an end to the Russia-Ukraine war, and increasing coordination and burden sharing with NATO Allies.

Norway's 18th Sanctions Package - Shadow Fleet Vessels, Petroleum Import Ban, Nord Stream Restrictions

Norway's DEKSA announced implementation of the 18th sanctions package against Russia, listing 14 individuals and 41 entities, adding 105 vessels to the shadow fleet annex, and introducing petroleum import restrictions. New provisions include Nord Stream 1 and 2 transaction prohibitions and a six-month delayed ban on importing refined petroleum products made from Russian crude oil.

Pre-2020 Export Licenses Won't Renew After January 2026

Norwegian export control authority DEKSA announced that export licenses issued before January 1, 2020 cannot be renewed after January 2026. Renewal applications must be submitted before February 1, 2026 to be processed. Companies with expiring pre-2020 licenses must apply for new licenses with full documentation if they wish to continue exporting controlled goods, services, or technology.

Export Deadline February 15 for Defense Material Q4 2025

DEKSA announces February 15, 2026 as the deadline for reporting Q4 2025 exports of defense material and dual-use goods for military use. All licensed exporters must submit reports via the DEKSA portal, including reports of unused licenses. Portal improvements have been implemented to ease the reporting process.

Norway Implements 19th Sanctions Package Against Russia

Norway's DEKSA has implemented the EU's 19th sanctions package against Russia into Norwegian law, effective immediately. The package includes listing of 22 individuals and 42 entities under travel and asset freeze measures, 117 vessels linked to the shadow fleet under port and service bans, and prohibitions on Russian LNG imports with staggered effective dates.

DEKSA Processing Times Updated, Longer Wait

Norway's export control authority DEKSA has updated average processing times for various license applications. The agency reports longer wait times due to high case volume. Exporters and license applicants should anticipate extended processing periods.

JGB Liquidity Enhancement Auction, April 16, 2026

Japan's Ministry of Finance announced a liquidity enhancement auction of Japanese Government Bonds (JGBs) scheduled for April 16, 2026, with an offering amount of approximately 650 billion yen. The auction will cover eligible 10-year, 20-year, and 30-year outstanding JGBs.

Japan Revises End User List, 748 Entities Listed

Japan's METI has revised its End User List, adding 42 entities for a total of 748 listed entities from 15 countries. The list identifies foreign entities with potential involvement in weapons of mass destruction and missile development. Exporters must submit license applications when shipping goods to listed entities, effective February 5, 2025.

Carbon Dioxide Streams for CCS Added to Export Controls

Japan's METI has issued a cabinet order amending the Export Trade Control Order to add carbon dioxide streams for CCS (Carbon Capture and Storage) purposes to the list of goods requiring approval for export. The amendment implements Japan's obligations under the 1996 London Protocol, adding CO2 streams exported for disposal via sequestration to Appended Table 2. Exporters must obtain approval from the Minister of Economy, Trade and Industry, with enforcement beginning January 19, 2026.

Japan Extends North Korea Import/Export Ban for Two Years

METI extended the comprehensive ban on all Japanese exports to North Korea and imports from North Korea for two years, effective April 14, 2025 through April 13, 2027. Exporters must obtain approval from the Minister of Economy, Trade and Industry under Article 48(3) of the Foreign Exchange and Foreign Trade Act, and importers must obtain approval under Article 52. Intermediate trade transactions and payment of import bills for unapproved North Korean goods are also prohibited.

METI Reapplies UN Iran Sanctions, Freezes 78 Entities and 43 Individuals

METI announced the reapplication of UN Iran sanctions following UNSC Resolution 2231, reimposing measures from Resolutions 1737, 1747, 1803, and 1929 that had been lifted. The Government of Japan implemented asset freezes against 78 entities and 43 individuals designated by the Ministry of Foreign Affairs for involvement in Iran's nuclear proliferation activities and delivery systems development. Japanese businesses must now comply with payment restrictions, capital transaction prohibitions, and investment bans under FEFTA.

End User List Expands to 835 Entities with Conventional Weapons

METI has revised Japan's End User List, expanding it from 748 to 835 entities (an increase of 87) across 15 countries and regions. The list now includes entities involved in conventional weapons development in addition to WMDs and missiles. Exporters must verify transaction status against the list and submit export license applications when dealing with listed entities, effective October 9, 2025.

MID and IOR Required for US Exports Under Sugar-Containing Product TRQs

Global Affairs Canada requires exporters to provide Manufacturer Identification (MID) and Importer of Record (IOR) information when applying for export permits for sugar-containing products to the United States under WTO and CUSMA Tariff Rate Quotas, effective February 16, 2025. Applicants must use the updated form 1466.

Cloud Services Require Export Permits for Controlled Technology

Cloud Services Require Export Permits for Controlled Technology

EV Import Quota from China, 24,500 Vehicles

Global Affairs Canada issued Notice No. 1162 establishing an annual import quota of 24,500 electric vehicles from China under the Export and Import Permits Act. The quota year runs March 1 to February 28/29. Shipment-specific import permits issued by GAC are required for all covered EV imports. Eligible EVs are assessed at a 6.1% most-favoured-nation tariff rate, replacing the previously imposed 100% surtax.

2025-2026 Tariff Rate Quotas for Wheat, Barley and Products

Global Affairs Canada announced the 2025-2026 tariff rate quotas (TRQs) for wheat, barley, and their products, effective August 1, 2025. The quotas are wheat at 226,883 tonnes, barley at 399,000 tonnes, wheat products at 123,557 tonnes, and barley products at 19,131 tonnes, administered on a first-come, first-served basis through July 31, 2026.

Steel Goods Tariff Quotas and Import Permit Rules - Item 82

Global Affairs Canada issued Notice 1160 replacing Notice 1142, adjusting tariff-rate quotas for certain steel goods listed on the Import Control List. Effective December 12, 2025, the notice reduces TRQ volumes for goods originating from non-CUSMA FTA and non-FTA partners, removes one tariff classification number from the Structural Steel product class, and reassigns tariff classification numbers between Line Pipe, Large Diameter Line Pipe, and Standard Pipe product classes with corresponding volume adjustments.

EU Sanctions Eight Russians for Human Rights Violations and Repression

The Council of the EU imposed restrictive measures on eight individuals responsible for serious human rights violations, repression of civil society, and undermining democracy in Russia. The designations include judges, prosecutors, and penal colony administrators involved in politically motivated trials and detention of activists including Aleksei Gorinov and journalist Maria Ponomarenko. Listed individuals are subject to asset freezes and travel bans preventing entry or transit through EU territory.

EU Renews Guatemala Sanctions Until 13 January 2027

The Council of the EU renewed targeted restrictive measures against individuals and entities undermining democracy and rule of law in Guatemala until 13 January 2027. The sanctions currently apply to 8 individuals and 1 entity, imposing travel bans, asset freezes, and prohibitions on making funds available to listed parties. These measures support Guatemala's democratic transition following the 2023 general election.

EU Extends Hamas and PIJ Sanctions Until January 20, 2027

The Council of the EU extended restrictive measures against Hamas and the Palestinian Islamic Jihad until January 20, 2027. The sanctions include asset freezes and prohibitions on making funds available to 11 individuals and 3 entities. One deceased individual was removed from the list following an annual review.

EU Designates Islamic Revolutionary Guard Corps as Terrorist Organisation

The Council of the EU formally designated the Islamic Revolutionary Guard Corps (IRGC) of Iran on its terrorist list under Common Position 2001/931/CFSP. The designation triggers asset freezes and prohibits EU operators from making funds or economic resources available to the group. This brings the total to 13 persons and 23 groups and entities subject to EU counter-terrorism restrictive measures.

EU Expands Terrorist Sanctions Listing Criteria, Adds Travel Ban

The Council of the EU adopted Decision (CFSP) 2026/455 and Regulation (EU) 2026/456, expanding the scope of EU restrictive measures to combat terrorism. The amendments add travel bans for listed individuals and broaden listing criteria to include leading members of listed groups and entities involved in financing, training, or recruitment of terrorists. The periodic review concluded with all existing listings maintained unchanged.

Commission Report on Preparedness in the EU Financial Sector

The European Commission published a report assessing the resilience of the EU financial sector against various potential disruptions. The report is part of the EU's broader preparedness union strategy and covers the financial sector's ability to withstand systemic shocks.

Platform on Sustainable Finance Advises on ESRS-EU Taxonomy Alignment

The European Commission's Platform on Sustainable Finance published technical advice on aligning European Sustainability Reporting Standards (ESRS) with the EU Taxonomy Regulation. The advisory body recommends joint EFRAG-Platform mapping to reduce reporting duplication, integration of taxonomy-aligned metrics into climate transition plans, and improved consistency across ESRS, SFDR, and Benchmark Regulation. The Commission plans to adopt a Delegated Act revising ESRS before summer 2026 based on this input.

FSUG Opinions 2026: Payment Accounts Directive Revision Suggestions

The Financial Services User Group published its 2026 opinions containing suggestions for revising the EU Payment Accounts Directive. The document addresses transparency of fees, account switching procedures, and accessibility of basic payment accounts. Banks and payment service providers operating in the EU should monitor these expert recommendations as potential indicators of upcoming regulatory amendments.

FAQs on Provision of Payments Services Concerning Sanctions Against Russia and Belarus

The European Commission published FAQs clarifying payment services obligations under EU sanctions targeting Russia and Belarus following the military aggression against Ukraine. The guidance addresses how payment service providers must handle transactions affected by asset freezes, payment restrictions, and other restrictive measures. Regulated entities should consult these FAQs to ensure compliance with current sanctions requirements.

EU-UK Financial Forum Convenes Fifth Meeting in London

The European Commission and HM Treasury co-chaired the fifth EU-UK Joint Financial Regulatory Forum meeting in London on 11 March 2026. Participants from the Bank of England, FCA, ECB, ESAs, and SRB attended. The Forum covered six themes: policy priorities, macro-financial stability, banking, digital finance, markets reform, and sustainable finance. Both parties reaffirmed commitment to financial stability, market integrity, and international cooperation through the FSB and G20.

Hamidah Nabagala Added to ISIL/Al-Qaida Sanctions List

The European Commission published a notice in the Official Journal adding Hamidah Nabagala to the ISIL/Al-Qaida sanctions list under Council Regulation (EC) No 881/2002. The designation was made via Commission Implementing Regulation (EU) 2026/830. Financial institutions and entities holding assets belonging to the designated person must freeze those assets and report to the competent authorities.

EU Sanctions Syria: 32 Persons and Entity Listed Under Restrictive Measures

The Council of the European Union published Notice ST/7475/2026/INIT in the Official Journal C/2026/2138 of 10 April 2026, notifying 32 persons and entities of their designation under EU restrictive measures in view of the situation in Syria. The designations operate under Council Decision 2013/255/CFSP and Council Regulation (EU) No 36/2012, which impose asset freezes and transaction prohibitions on listed parties.

Al-Khatouni Added to ISIL Al-Qaida Sanctions List Under Regulation 881/2002

The European Commission added Abd El Hamid Salim Ibrahim Brukan al-Khatouni to the ISIL (Da'esh) and Al-Qaida sanctions list via Commission Implementing Regulation (EU) 2026/819. This designation subjects the individual to asset freezes and travel bans under Council Regulation (EC) No 881/2002. EU Member States must implement these restrictive measures immediately.

Sami Al-Jaburi Added to EU ISIL Al-Qaida Sanctions List

The European Commission published a notice adding Sami Jasim Muhammad Jaata Al-Jaburi to the EU ISIL/Al-Qaida sanctions list via Commission Implementing Regulation (EU) 2026/819. The designation subjects Al-Jaburi to asset freezes and travel bans under Council Regulation (EC) No 881/2002. EU nationals, entities, and financial institutions must freeze any funds or economic resources belonging to, owned, held, or controlled by the designated person.

356th Amendment to ISIL Al-Qaida Sanctions List

The European Commission published Implementing Regulation (EU) 2026/830, the 356th amendment to Council Regulation (EC) No 881/2002, updating the EU consolidated list of persons and entities subject to restrictive measures for association with ISIL (Da'esh) and Al-Qaida organisations. This implementing regulation amends the annex containing the consolidated list of designated persons, entities, and bodies.

OFSI Call for Evidence on Ownership and Control in Financial Sanctions Regulations

OFSI has launched a call for evidence seeking industry views on how UK financial sanctions ownership and control (O&C) regulations are applied in practice. The evidence call focuses specifically on the 'control' test, where firms report the greatest implementation challenges including legal uncertainty and conflicting interpretations. Responses will inform potential regulatory changes to clarify O&C obligations.

OFSI Analysis: Bank of Scotland £160k Penalty for Russia Sanctions Breach

OFSI published details of a £160,000 monetary penalty imposed on Bank of Scotland Plc (Lloyds Banking Group) for breaching UK Russia financial sanctions. The breach involved a spelling variation of a designated individual's name evading automated screening. OFSI highlighted that weaknesses in screening, escalation procedures and training contributed to the breach, offering lessons for all UK-regulated firms on sanctions compliance controls.

OFSI Publishes Seven-Criteria Framework for Prioritising Sanctions Licence Applications

OFSI published its licence prioritisation framework explaining how over 900 annual licensing decisions are categorised as high, medium, or low priority. Applications are assessed against seven criteria including humanitarian purpose, materiality, timing, UK economic impact, administrative burden, reputational/strategic factors, and complexity. The framework aims to provide transparency on how competing demands are managed.

OFSI Updates Licensing Guidance: CDPR Required Above £2M for Law Firms, £1M for Counsel

OFSI has updated its licensing guidance requiring independent Costs Draftsperson's Reports (CDPRs) for legal fees above specified thresholds. Law firms must submit CDPRs when total legal fees exceed £2,000,000 per six-month period per designated person; directly instructed Counsel must submit CDPRs when costs exceed £1,000,000. The thresholds apply cumulatively across all specific licences and applications for each designated person.

Director Shares OFSI Ten-Year Anniversary Reflections

OFSI marks its ten-year anniversary with a reflective statement from Director Giles Thomson. Since 2016, OFSI has developed the UK's financial sanctions framework through expanded industry engagement, enhanced general licensing flexibility, and strengthened enforcement capabilities. The office reports £37 billion in frozen assets reported across all regimes in 2024-2025. A new three-year strategy will be published in the coming weeks.

U.S. Person Settles Syria Sanctions for $3,777,000

OFAC announced a $3,777,000 settlement with a U.S. person for 20 apparent violations of Syrian Sanctions Regulations between January 2018 and December 2021. The individual provided managerial services to Syrian real estate companies as an executive and board member, including reviewing financial statements, approving expenses, and supervising fee collection. The settlement reflects OFAC's determination that the violations were egregious and not voluntarily self-disclosed.

TradeStation Securities Pays $1.1M OFAC Settlement for Sanctions Violations

TradeStation Securities, Inc. agreed to pay $1,110,661 to settle 481 apparent violations of multiple sanctions programs related to Iran, Syria, and Crimea region of Ukraine. The violations occurred during securities transactions between June 2021 and June 2022 due to failures in geo-blocking controls. The settlement reflects non-egregious violations that were voluntarily self-disclosed and significant remedial measures implemented.

14 OFAC Penalties Totaling $265.7M in 2025

OFAC published 2025 year-end enforcement summary documenting 14 civil penalties and settlements totaling $265,725,344 against entities including Exodus Movement, Inc. ($3.1M), Gracetown, Inc. ($7.1M), IPI Partners, LLC ($11.5M), ShapeShift AG ($750K), and Fracht FWO Inc. ($1.6M). The enforcement actions target sanctions violations across cryptocurrency, trading, and logistics sectors.

Additional Select Settlement Agreements Index 2009-2025

OFAC published an index of select settlement agreements spanning 2009-2025, listing 20+ enforcement settlements including those with Binance Holdings, Wells Fargo Bank, State Street Bank and Trust, 3M Company, British American Tobacco, Berkshire Hathaway, and Haas Automation for apparent sanctions violations.

IMG Academy Settles OFAC Counternarcotics Sanctions Violations for $1.72M

IMG Academy, LLC agreed to pay $1,720,000 to settle potential civil liability for apparent violations of OFAC counternarcotics sanctions. Between 2018 and 2022, IMG Academy entered into annual tuition enrollment agreements with two Specially Designated Nationals sanctioned under the Foreign Narcotics Kingpin Designation Act for ties to a Mexican drug cartel and processed tuition payments for their children. The settlement reflects OFAC's determination that violations were non-egregious, absence of voluntary self-disclosure, but substantial cooperation and remedial measures.

Vizocom ICT Export Violation - PRC Military Antenna Technology

BIS has initiated an administrative proceeding against Vizocom ICT (El Cajon, CA) for allegedly exporting EAR-controlled military antenna technology specifications to a Chinese manufacturer in the PRC via the 'Made-in-China' portal without required authorization. The company faces potential penalties including denial of export privileges. Two Vizocom employees were separately indicted on federal fraud charges for their roles in the scheme.