Sanctions in a Snap: Developments in Sanctions June 2026

Hughes Hubbard’s “Sanctions in a Snap” is intended to provide a clear and concise summary of recent developments from the Office of Foreign Assets Control (OFAC). We hope you find it helpful in assessing U.S. economic sanctions compliance risk against current U.S. government designation and enforcement priorities.

Highlights from June 2026 include:

• The U.S.-Iran Memorandum of Understanding

• Russia-related sanctions removals

• A $1 million civil monetary penalty against FTI Consulting

As explained in our May edition, the Foreign Terrorist Organization designations of the Brazilian groups Primeiro Comando do Capital and Comando Vermelho took effect June 5.

• Please see our comments on what those designations mean for Brazilian banks, published by Bloomberg.

In total, OFAC added 129 individuals and entities to its Specially Designated Nationals and Blocked Persons List (SDN List) and identified six vessels as blocked property. OFAC also removed 27 individuals, entities and vessels from the SDN List.

The June designations reflect OFAC’s prioritization of Chinese targets pursuant to the Transnational Criminal Organizations, Counterproliferation and Iran oil-related authorities. OFAC also continued implementation of its modernized Cuba sanctions program with the addition of 17 Cuban entries to the SDN List. Those actions further enhance the risk exposure of companies connected to Cuba.

The graph at the end of this update provides a visual representation of the current targeting priorities reflected in the June designations.

U.S.-Iran Memorandum of Understanding

On June 17, the United States released the text of a memorandum of understanding (MOU) with Iran, which establishes a framework for negotiating a potential long-term agreement to resolve the armed conflict. The MOU memorializes an apparent commitment by the United States to “issue waivers” for Iranian oil.

On June 22, OFAC issued Iran General License X, which authorizes dealings involving both Iranian oil and petrochemicals. That authorization, which represents the only publicly announced U.S. sanctions action taken in furtherance of the MOU, was revoked on July 7.

• Please see our comments on the sanctions-related aspects of the MOU, published by Reuters and Arabian Gulf Business Insight.

Russia-Related Sanctions Removals

On June 30, OFAC announced the SDN List removal of four India-based entities previously designated under the Russia-related sanctions program.

Notably, with those delistings, the United States has removed 78 Russia-related designations during the second Trump administration. This means the United States has removed more than twice as many Russia-related sanctions designations than it has added since Trump’s return. OFAC has added 36 individuals and entities to the SDN List under the Russia sanctions program—all occurring on Oct. 22, 2025.

• Please see our suggestions as to how multinationals should approach these removals, published by Dow Jones Risk Journal.

$1M Civil Monetary Penalty Against FTI Consulting

On June 1, OFAC announced a $1.05 million settlement with FTI Consulting Inc. (FTI), a Washington, D.C.-based international consulting and advisory firm, to resolve potential civil liability arising from apparent violations of the Ukraine-/Russia-related sanctions program. According to OFAC, between April 2019 and May 2021 FTI allegedly engaged in six apparent violations when it indirectly dealt in debt of VTB Bank by issuing certain invoices to an unidentified law firm that the bank was ultimately responsible for paying.

OFAC found that the apparent violations were not voluntarily self-disclosed and were non-egregious. Based on those findings, OFAC assessed the base penalty equivalent to the applicable schedule amount of $525,000.

OFAC increased the base penalty amount based on several aggravating factors: recklessness by senior managers, harm to the objectives of the sanctions program and the status of FTI as a commercially sophisticated entity with an extensive global presence.

The root cause of the violations was FTI’s failure to understand the full scope of OFAC’s regulations, which prohibit direct or indirect dealings in debt of Sectoral Sanctions Identification List sanctioned entities beyond the applicable tenor.

Additional Sanctions Actions in June

In addition to the OFAC actions summarized above, the U.S. government announced the following in June:

• Designations (additions to the Specially Designated Nationals and Consolidated Sanctions Lists)

  • June 2 – Counterterrorism and Iran-related designations targeting four Iranian individuals and four Iran-based digital asset exchanges. OFAC described the action as directed at digital asset exchange infrastructure allegedly used to facilitate illicit Iranian financial activity.

  • June 2 – Two commanders of the Democratic Forces for the Liberation of Rwanda and the Rwanda-backed March 23 Movement, groups that allegedly contribute to violence and instability in eastern Democratic Republic of the Congo (DRC).

  • June 4 – Five Cuban individuals, including senior Cuban government and Communist Party officials, and five Cuban entities.

  • June 5 – Two Iranian individuals, one Afghan individual, one Turkish individual, 12 entities and six vessels tied to alleged Iranian liquid petroleum gas (LPG) smuggling and shadow banking networks. The sanctioned individuals and entities and identified vessels allegedly shipped hundreds of millions of dollars’ worth of Iranian LPG to South and East Asia, intentionally disguised as Omani LPG. The sanctioned entities are primarily based in the United Arab Emirates and the Marshall Islands.

  • June 10 – Two Iranian individuals, four Chinese individuals and four Chinese entities allegedly connected to foreign procurement networks in support of Iran’s military and weapons programs.

  • June 11 – The State Department designated Unión Cuba-Petróleo, Cuba’s state-owned oil and gas company. The designation targets a central Cuban revenue-generating enterprise and further expands the reach of the modernized Cuba sanctions program.

  • June 18 – Three Lebanese individuals, one Syrian entity, one Iraqi entity, one Omani entity and two Lebanese entities allegedly connected to Hizballah.

  • June 22 – Three individuals and six entities alleged to support ISIS and ISIS-West Africa financial networks. The targeted individuals include nationals of the Netherlands, France and Nigeria, and the targeted entities are based in Türkiye, Syria and Nigeria. The entities include money transfer and digital asset exchange actors in Türkiye and Syria.

  • June 23 – OFAC announced additional sanctions against the Prince Group Transnational Criminal Organization, a group allegedly responsible for conducting overseas scam operations targeting Americans. The designations included nine individuals and 26 entities allegedly linked to Prince Group TCO. The individuals include nationals of Burma, Cambodia, China, and Saint Kitts and Nevis, and the sanctioned entities are primarily based in Cambodia, the United Kingdom, China and the British Virgin Islands.

  • June 23 – One Cuban individual and five Cuban entities, all allegedly affiliated with the previously designated Grupo de Administración Empresarial S.A.

  • June 25 – Two Rwandan individuals and four Rwanda-based mining and refining entities, allegedly connected to eastern DRC conflict-minerals networks.

  • June 26 – Five individuals and three entities, including individuals from India, Panama, Colombia and Sudan, allegedly connected to the ongoing conflict in Sudan.

  • June 30 – Two Mexican individuals, eight Mexico-based entities and one UK-based entity allegedly involved in cartel fuel smuggling and tax evasion schemes.

• Sanctions List Removals

  • June 11 – One Russian individual and one Russian-Israeli individual previously designated under the Russia-related program.

  • June 23 – Three Russian individuals previously designated under the Russia-related program.

  • June 24 – Six Russian individuals, one Russian-Cypriot individual, two Turkish entities and two Russia-flagged vessels, all previously designated under the Russia-related program.

  • June 29 – Five Türkiye entities and two Türkiye nationals previously designated under the Russia-related program.

• General Licenses

  • Venezuela General License 46C (June 10), “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products.”

  • Venezuela General License 47A (June 10), “Authorizing the Sale of U.S.-Origin Diluents to Venezuela.”

  • Venezuela General License 48B (June 10), “Authorizing the Supply of Certain Items and Services to Venezuela.”

  • Venezuela General License 50B (June 10), “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities.”

  • Venezuela General License 51B (June 10), “Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold.”

  • Venezuela General License 52A (June 10), “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.”

  • Venezuela General License 54A (June 10), “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela.”

  • Russia-Related General License 55F (June 11), “Authorizing Certain Services Related to Sakhalin-2.”

  • Russia-Related General License 115D (June 11), “Authorizing Certain Transactions Related to Existing Civil Nuclear Energy Projects.”

  • Venezuela General License 5X (June 18), “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After August 4, 2026.”

  • Venezuela General License 24A (June 18), “Authorizing Certain Transactions Involving Telecommunications and Mail.”

  • Venezuela General License 59 (June 18), “Authorizing Certain Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.”

  • TCO General License 2 (June 23), “Authorizing the Wind Down of Transactions Involving CCU Commercial Bank Plc.”

  • Venezuela General License 60 (June 25), “Authorizing Transactions Related to Earthquake Relief Efforts in Venezuela.”

  • Russia-Related General License 131G (June 25), “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.”

• Regulations and Guidance

  • Frequently Asked Questions

    • On June 2, OFAC issued new Iran-related FAQ 1257 relating to the risk exposure arising from dealings involving the Iran-based digital asset exchanges Nobitex, Wallex, Bitpin and Ramzinex.

    • On June 4, OFAC issued Cuba-related FAQ 1258 relating to the risk exposure arising from dealings involving the Cuban entities GAESA, MININT and MINFAR.

    • On June 10, OFAC issued Venezuela-related FAQs 1259 and 1260 regarding the scope of certain Venezuela general licenses.

    • On June 11, OFAC issued technical amendments to Russia-related FAQs 967, 978, 999, 1011, 1117, 1182, 1203 and 1216.

    • On June 18, OFAC issued technical amendments to Venezuela-related FAQ 595.

    • On June 25, OFAC issued technical amendments to Russia-related FAQs 1224 and 1225.

    • On June 29, OFAC amended FAQ 897 and issued FAQ 1261 to include references to the agency’s newly launched Reconsideration Portal.

  • Guidance:

    • On June 1, OFAC published “Introduction to the Office of Foreign Assets Control” to provide a foundational understanding of the OFAC licensing, petition and enforcement processes.

• Miscellaneous

  • On June 23, OFAC published a featured story on its enhanced partnership with the United Kingdom’s Office of Financial Sanctions Implementation and released a joint OFAC-OFSI comparative overview addressing sanctions lists, licensing, and recordkeeping and reporting requirements.

  • On June 29, OFAC launched its Reconsideration Portal “to streamline the petitions process by guiding submitters to provide necessary information upfront, rather than through a series of questionnaire/answer exchanges that can delay efficient adjudication of a delisting petition.”

    The most noteworthy aspect of the portal is the emphasis on encouraging petitioners to have established remedial measures at the time the initial petition is submitted.

U.S. Targeting Priorities