Welcome to the newest edition of newsletter on Sanctions powered by ECOVIS ProventusLaw, dedicated to those who want to stay informed about the latest trends and developments, receive expert tips, and deepen their knowledge.
EU Sanctions Expanded for Russian Hybrid Activities
The Council added four individuals to the EU sanctions list under the regime targeting Russia’s destabilising and hybrid activities, particularly Foreign Information Manipulation and Interference (FIMI):
- Sergey Klyuchenkov
- Ernest Mackevičius
- Graham Phillips
- Adrien Bocquet
All listed persons are subject to asset freezes and travel bans, and EU persons and companies are prohibited from making funds or economic resources available to them.
The EU sanctions list under this regime now covers 69 individuals and 17 entities.
EU financial institutions and companies should update their screening processes to reflect the four newly listed individuals. Given the expanding scope of this sanctions regime, institutions should ensure their FIMI-related designations are monitored on an ongoing basis alongside other Russia-related restrictive measures.
EU Expands Iran Human Rights Sanctions
The Council imposed restrictive measures on 16 additional individuals and 3 entities for serious human rights violations in Iran, bringing the total to 263 individuals and 53 entities.
The new listings target persons involved in the violent suppression of January 2026 protests, including senior security officials, IRGC commanders, judiciary representatives, and the head of Iran’s prison organisation.
Newly listed entities include:
- Mohammad Rasulullah Corps
- Imam Reza IRGC (Khorasan Razavi Province)
- Naji Research and Development Company (NRDC), linked to surveillance technology.
All listed persons are subject to asset freezes and travel bans, while EU persons and companies are prohibited from making funds or resources available to them.
EU export bans on equipment for internal repression and telecommunications monitoring remain in force.
EU financial institutions and companies should immediately update their screening processes to reflect the 16 newly listed individuals and 3 entities. Particular attention should be paid to any potential exposure to Iranian IT and technology-sector counterparties, given NRDC’s listing. Ongoing monitoring of this rapidly expanding sanctions list is strongly advised.
EU Cyber Sanctions Target New Entities Linked to Attacks on Member States
The Council imposed restrictive measures on three entities and two individuals under the EU horizontal cyber sanctions regime, which now covers 19 individuals and 7 entities.
New listings include:
- Integrity Technology Group (China) – linked to cyber operations compromising over 65,000 devices across six EU Member States;
- Anxun Information Technology (China) and its co-founders – involved in hacking activities targeting critical infrastructure;
- Emennet Pasargad (Iran) – linked to data breaches, disinformation activities, and attacks affecting EU digital services.
All designated persons are subject to asset freezes and travel bans, and EU persons and companies are prohibited from making funds or economic resources available to them.
EU financial institutions and companies should update their screening processes to reflect the five newly listed parties. Given that two of the three listed entities are Chinese-based technology and IT services companies, institutions with exposure to the Chinese tech sector should apply enhanced due diligence. The listings also serve as a reminder of the growing intersection between sanctions compliance and cybersecurity risk management.
EU Sanctions Target Russian Military Officials Over Bucha Atrocities
The Council imposed restrictive measures on nine individuals linked to the Bucha massacre (Feb–Mar 2022), marking the fourth anniversary of the events.
The listings include senior Russian military officials, led by Colonel General Aleksandr Chayko, former Commander of the Eastern Military District, as well as eight other commanders involved in operations in Bucha and surrounding areas, including Hostomel, Irpin, and Borodianka.
The individuals are associated with killings of civilians, looting, torture, and forced deportations during Russia’s invasion of Ukraine.
All designated persons are subject to asset freezes and travel bans, with EU persons and entities prohibited from making funds available to them.
The EU’s Russia-related sanctions regime now covers approximately 2,600 individuals and entities.
Institutions should update their screening processes to reflect the nine newly listed individuals. Given the now very large scale of Russia-related sanctions (approximately 2,600 designated parties), institutions are reminded of the importance of maintaining robust, up-to-date and automated screening systems capable of handling frequent list updates across multiple sanctions regimes simultaneously.
EU Extends Russia-Related Sanctions Targeting Ukraine’s Territorial Integrity
The Council extended individual restrictive measures for a further six months, until 15 September 2026, targeting those responsible for undermining Ukraine’s territorial integrity, sovereignty, and independence.
The sanctions regime includes travel bans, asset freezes, and prohibitions on making funds or economic resources available to listed persons, and continues to apply to approximately 2,600 individuals and entities.
As part of the review, two individuals were delisted, and five deceased persons were removed from the sanctions list.
Institutions should note the updated validity period and ensure their screening systems reflect the delisting of two individuals and the removal of five deceased persons. Sanctions compliance programmes should be calibrated to capture such periodic list updates, which occur routinely at each extension cycle.
EU Extends Bosnia and Herzegovina Sanctions Framework
The Council extended the EU restrictive measures framework in view of the situation in Bosnia and Herzegovina for a further 12 months, until 31 March 2027.
The framework enables the EU to impose asset freezes, travel bans, and funding prohibitions on individuals or entities that undermine Bosnia and Herzegovina’s sovereignty, territorial integrity, constitutional order, or the Dayton/Paris Peace Agreement, or that threaten its security.
No individuals or entities are currently listed under this regime.
While no parties are currently designated, institutions should ensure this framework is captured in their sanctions monitoring systems, as listings could be activated at short notice should the situation in Bosnia and Herzegovina deteriorate.
EU Extends Iran Human Rights Sanctions
The Council extended EU restrictive measures in response to serious human rights violations in Iran until 13 April 2027.
The sanctions include:
- travel bans and asset freezes;
- a ban on exports of equipment used for internal repression or telecommunications monitoring;
- a prohibition on making funds or economic resources available to listed persons.
The regime currently applies to 262 individuals and 53 entities.
EU financial institutions and companies should ensure their screening processes reflect the updated list and extended validity of the regime. Particular attention should be paid to the prohibition on making funds available to listed individuals and entities. Source:
OFAC Advisory on Sham Transactions and Sanctions Evasion
The U.S. Office of Foreign Assets Control (OFAC) issued an advisory clarifying that nominal transfers of property by blocked persons do not extinguish a blocked interest.
The advisory highlights key red flags, including:
- transfers to family members or close associates;
- commercially unreasonable or poorly documented transactions;
- complex, multi-layered structures in high-risk jurisdictions;
- continued involvement of the blocked person after transfer;
- transfers occurring close in time to designation.
OFAC also referenced enforcement actions, including penalties against GVA Capital Ltd. (approximately $215.99 million) and IPI Partners, illustrating the liability risks posed by proxy structures used to circumvent sanctions.
The guidance reinforces OFAC’s position that substance, not form, determines whether sanctions evasion has occurred.
Financial institutions should update their sanctions due diligence frameworks to reflect the identified red flags, with particular attention to structures involving trusts, multi-layered entities, or intermediaries closely tied to designated persons. Existing portfolios and client relationships should be reassessed for potential exposure to sham structures, especially in the context of Russia-related designations.
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