Export Control & Sanctions Watch: Edition 33

3 hours ago

8 min read

🔐 Iran wind-down licences have expired, an Iranian crypto channel has been sanctioned, and EU Russia asset freezes now run to 2029.

Export Control & Sanctions Watch

Summary: The sanctions and export-control landscape shifted sharply this week, with the United States closing two remaining Iran wind-down routes, sanctioning an Iranian crypto exchange reportedly linked to Hormuz transit payments, and expanding enforcement across Cuba-related nickel and defence supply chains. The EU has extended more than 3,000 Ukraine-related individual listings for three years, while the UK removed one vessel from its Russia sanctions list. At the same time, OFAC delistings, the termination of the Ethiopia sanctions programme, a further Lukoil licence extension and changes to ITAR create important screening and licensing implications for businesses operating across multiple jurisdictions.

Iran Wind-Down Licences Have Expired

Two important OFAC wind-down authorisations expired at 12:01 a.m. EDT on 23 September 2026 with no replacement identified in the source material. General License DD covered the wind-down of certain civil aviation-related and other transactions previously authorised under the Iranian Transactions and Sanctions Regulations.

Counter Terrorism General License 37 covered the wind-down of certain transactions involving persons blocked on 8 September 2026.

Any activity still relying on either licence should now be treated as unauthorised unless covered by a specific licence. The source also notes that Iran-related specific licence applications now face a presumption of denial, subject to applicable exceptions.

👉 Download this week's edition of Export Control & Sanctions Watch to access the full technical analysis, licensing implications and compliance guidance.

OFAC Sanctions Iranian Crypto Exchange Linked to Hormuz Payments

On 17 September 2026, OFAC designated BitBank, its developer Pishtaz Simorgh Electronic Trade Company, and three individuals linked to the Zanjani network under the Iran sanctions programme and E.O. 13902. The designations carry a "Subject to Secondary Sanctions" flag, meaning non-U.S. businesses may also face exposure.

According to the source, Treasury says the previously designated Hormuz Safe Marine Services Authority had used BitBank to route payments, creating a potential sanctions issue for carriers, charterers and other businesses settling Hormuz transit-related charges through linked channels.

Businesses with Iran, Gulf shipping or logistics exposure should review payment channels, counterparties and screening data for the newly designated entities and associated names.

👉 Download this week's edition for the full entity analysis, payment-channel implications and department-level compliance guidance.

EU Extends Ukraine-Related Asset Freezes to 2029

On 22 September 2026, the EU Council extended individual sanctions under Regulation (EU) No 269/2014 for 36 months, until 22 September 2029. The measures cover more than 3,000 individuals and entities and include asset freezes, restrictions on making funds or economic resources available and travel bans for individuals.

The Council also did not renew several listings, including Alisher Usmanov, Mikhail Fridman and Andrey Falaleev, while three deceased persons were removed. Businesses should therefore update screening systems and conduct ownership and control checks where counterparties may have been affected by the changes.

👉 Download this week's edition to understand the practical screening implications of the three-year renewal cycle and recent delistings.

Cuba: Nickel and Defence R&D Supply Chains Sanctioned

OFAC designated eight Cuban state-owned enterprises and three individuals on 17 September under E.O. 14404.

The measures include four entities connected with the nickel sector around Moa and Nicaro, as well as four defence research and development centres.

The source highlights potential exposure for non-U.S. businesses involved in nickel joint ventures, equipment supply and offtake arrangements.

👉 Download this week's edition of Export Control & Sanctions Watch to access the full entity analysis, supply-chain implications and compliance guidance.

U.S. Annual Blocked Property Report Due 30 September

U.S. persons holding property blocked under OFAC sanctions as of 30 June 2026 must file the Annual Report of Blocked Property by 30 September 2026.

The reporting obligation can cover frozen funds, goods held in warehouses and payments suspended during transactions.

👉 Download this week's edition to access the full reporting requirements, affected property categories and practical compliance considerations.

Lukoil International Licence Extended to 22 October

OFAC General License 131J extends certain divestment negotiations, maintenance and wind-down activities involving Lukoil International GmbH and its majority-owned subsidiaries until 22 October 2026.

The licence does not itself authorise the closing of a sale. Separate OFAC authorisation is required, and funds may not flow to Russia.

👉 Download this week's edition to access the full analysis of what GL 131J permits, what remains prohibited and the key October deadlines.

OFAC Removes Three SDN Listings

OFAC removed three entries from the SDN List on 16 September 2026, including two Russia-related parties and one Mexican counter-narcotics listing.

One of the Russia-related delistings concerns Turkish machine-tool manufacturer Modulsan Makina Kesici Takim ve Disli Sanayi Ticaret Limited Sirketi.

Businesses should refresh screening systems, while remembering that OFAC delisting does not automatically remove a party from EU, UK or BIS lists.

👉 Download this week's edition to access the full delisting analysis, affected entities and cross-jurisdiction screening considerations.

Belarusian Timber and Paint Companies Delisted

OFAC removed Lakokraska OAO and Kontsern Bellesbumprom from the SDN List on 17 September.

The change may affect U.S.-side trade, but the source specifically notes that EU and UK restrictions on Belarusian goods remain relevant.

👉 Download this week's edition to access the full entity details and the analysis of the continuing EU and UK restrictions.

U.S. Ethiopia Sanctions Programme Terminated

The national emergency under E.O. 14046 expired without renewal, resulting in the removal of all parties blocked solely under the programme.

The source notes that this includes Eritrean entities and individuals, including Red Sea Trading Corporation, while separate U.S., EU and UK restrictions remain relevant and should be checked independently.

👉 Download this week's edition to access the full delisting analysis and the remaining U.S., EU and UK restrictions that businesses should consider.

UK Removes One Vessel from Russia Sanctions List

The UK FCDO revoked one vessel specification under the Russia sanctions regime on 21 September 2026.

The vessel's identity is not specified in the source material provided. Businesses should therefore update vessel-screening systems using the official UK notice and continue checking the vessel against EU and U.S. lists before re-engagement.

👉 Download this week's edition to access the full vessel-screening analysis and the cross-jurisdiction checks businesses should complete before re-engagement.

Venezuela: PDVSA 2020 Bond Licence Delayed Again

OFAC General License 5Z moves the relevant authorisation for the PDVSA 2020 8.5% bond to 5 November 2026.

Until then, the sale or transfer of CITGO Holding shares pledged as collateral remains blocked unless specifically authorised.

👉 Download this week's edition to access the full GL 5Z analysis, key dates and implications for affected financing and restructuring arrangements.

ITAR Changes Affect Ethiopia, Saudi Arabia, Peru and Canada

A U.S. State Department final rule published on 18 September 2026 formally removes Ethiopia from ITAR §126.1, moving applicable defence exports from a policy of denial to case-by-case licensing.

The rule also adds Saudi Arabia and Peru to the Major Non-NATO Ally list and corrects an ITAR §126.5 provision concerning certain Canadian transfers and the DSP-83 requirement.

Exporters should also monitor whether BIS aligns the relevant EAR Country Group treatment for Ethiopia.

👉 Download this week's edition to access the full ITAR analysis, country-specific implications and related EAR considerations.

Overview of This Week's Edition Changes

Topic	Why It Matters
Iran Wind-Down Licences	Two key wind-down authorisations expired with no replacement identified
Iranian Crypto Exchange	New SDN designations create potential secondary-sanctions exposure
Cuba Nickel & Defence	New designations affect mineral, equipment and defence-related supply chains
EU Ukraine Listings	More than 3,000 listings extended to September 2029
Annual Blocked Property Report	U.S. persons face a 30 September reporting deadline
Lukoil International	Licence extended only to 22 October, creating another near-term review date
OFAC Delistings	Screening databases need updating across several jurisdictions
Belarusian Delistings	U.S. restrictions changed, but EU and UK measures remain relevant
Ethiopia Sanctions	U.S. sanctions programme terminated, requiring screening-rule updates
UK Vessel Delisting	Vessel-screening systems need to reflect the UK revocation
PDVSA 2020 Bond	Relevant authorisation delayed until 5 November 2026
ITAR	Ethiopia moves to case-by-case licensing; Saudi Arabia and Peru added as MNNAs

🔐 Unlock the Full Technical Analysis

Edition 33 provides detailed technical analysis of this week's sanctions and export-control developments, including:

The expiry of OFAC General Licenses DD and 37
The new Iranian crypto-related SDN designations
Secondary sanctions exposure and Hormuz payment channels
The newly designated Cuban nickel and defence entities
The 30 September Annual Blocked Property Report deadline
OFAC's latest SDN delistings
The termination of the Ethiopia sanctions programme
Lukoil International General License 131J
The EU's three-year extension of Ukraine-related listings
Recent UK Russia sanctions changes
PDVSA General License 5Z
ITAR changes affecting Ethiopia, Saudi Arabia, Peru and Canada
Department-level compliance implications and source links

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Author

Ann Karen | Head of Growth

Updated: 24 September 2026

Disclaimer

This publication provides general information and trade intelligence based on developments available during the period covered. It does not constitute legal, sanctions, export-control, customs, tax or other professional advice. Businesses should assess the application of specific measures to their own circumstances and obtain appropriate professional advice where required.

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