Export Control & Sanctions Watch: Edition 30

Welcome back to the Export Control & Sanctions Watch. We took August off. Washington, Brussels and London did not.

🔐 Syria comes off the terror list, the UK targets banks and tankers, a UAE bank faces a potential dollar-clearing cut-off, and Washington blocks the President of the International Criminal Court.

Export Control & Sanctions Watch

Summary: Five weeks brought 24 significant regulatory developments across the United States, United Kingdom and European Union, with sanctions lists moving in both directions. This edition examines the removal of Syria from the U.S. State Sponsor of Terrorism list and the delisting of Hay'at Tahrir al-Sham (HTS) and numerous associated entries, alongside new UK sanctions targeting Russian banks, shadow-fleet tankers and critical-material supply chains. It also covers the proposed U.S. action against Banque Misr UAE, new Iran-related designations, the designation of ICC officials, changes to UK Lukoil licences and new compliance deadlines affecting companies relying on sanctions authorisations.

The key compliance message this month is simple: screening is no longer only about who has been added to a list. It is increasingly about who has been removed, what licences have changed and whether your data is current enough to reflect both. Stale sanctions information can now create two different risks: failing to block a newly designated party or continuing to reject business that has become lawful.  

Read the latest edition here (PRO Subscription required).

A rapidly shifting sanctions landscape demands more than routine screening. From major delistings to new financial restrictions, businesses must keep pace with every change.

Syria Comes Off the Terror List & Screening Systems Need to Catch Up

One of the most consequential developments of the period is a removal rather than a designation. On 24 August 2026, the United States rescinded Syria's designation as a State Sponsor of Terrorism. The action was accompanied by the revocation of the SDGT designation of al-Nusrah Front/Hay'at Tahrir al-Sham (HTS) and the removal of HTS and a substantial number of associated individuals from the SDN List.

The development matters because many sanctions compliance systems are designed around identifying additions. Delistings can receive less operational attention, leaving businesses with outdated screening data that continues to block transactions involving persons or organisations that are no longer designated.

This does not, however, mean that Syria is suddenly an unrestricted market. Other Syria-related restrictions and export controls administered by BIS continue to require separate analysis before transactions or shipments are planned.

This week's Export Control & Sanctions Watch explains:

• What Syria's removal from the State Sponsor of Terrorism list changes

• Why HTS and associated delistings require screening data to be refreshed

• Why General Licence 25 was revoked

• Which restrictions and export controls remain relevant

• How companies can avoid both under-blocking and unnecessary over-blocking

👉 Download this week's Export Control & Sanctions Watch to access the full analysis, practical guidance and expert commentary.

New UK Sanctions Target Banks, Tankers and Critical Materials

The United Kingdom has introduced a significant new Russia sanctions package targeting 19 persons, entities and vessels. The package includes six Russian banks, six shadow-fleet tankers and four Russian companies involved in importing tantalum and niobium, alongside one individual. The additions mean that companies involved in trade, finance, shipping and commodities should refresh sanctions screening and vessel checks before new charters, port calls or transactions proceed.

The focus on companies importing tantalum and niobium is particularly notable. By targeting businesses involved in the supply of critical materials rather than only manufacturers or military end users, the sanctions pressure moves further upstream into raw-material supply chains and intermediary relationships.

At the same time, businesses relying on UK licences relating to Lukoil and its subsidiaries face new notification requirements. In several cases, licence extensions have been accompanied by a requirement to notify OFSI within 14 days of the relevant activity or amendment, creating a compliance obligation separate from the underlying transaction authorisation.

This week's Export Control & Sanctions Watch explains:

• Which sectors and supply chains are affected by the new UK package

• Why vessel screening should be refreshed before chartering or port calls

• How critical-material supply chains are becoming a sanctions target

• What the new Lukoil notification requirements mean for licence users

• Why a general licence notification does not itself confirm that activity is lawful

👉 Download this week's Export Control & Sanctions Watch to access the full analysis, practical guidance and expert commentary.

Washington Expands Financial and Secondary-Sanctions Pressure

The United States has also increased pressure on financial networks supporting sanctioned activity. FinCEN has proposed a Section 311 special measure against Banque Misr UAE, finding the institution to be of primary money-laundering concern. If implemented, the measure would restrict U.S. financial institutions from maintaining correspondent accounts for the bank and require enhanced measures relating to transactions processed through foreign correspondent accounts. The action is specifically focused on the UAE operation rather than Banque Misr's wider international operations—a distinction compliance systems need to preserve.

The period also saw new designations involving Iranian financial networks and crypto-linked businesses operating through jurisdictions including the UAE, Hong Kong and Singapore, alongside additional SDN actions affecting organisations and individuals in Europe and the Americas.

Another major development was the designation of the President of the International Criminal Court and a senior trial lawyer, with a limited wind-down authorisation running until 17 September 2026. The action demonstrates how sanctions exposure can now arise in professional, legal, technology and service relationships that may not resemble traditional high-risk trade transactions.

This week's Export Control & Sanctions Watch explains:

• What a Section 311 action could mean for payment and correspondent-banking routes

• Why entity-level distinctions matter when screening multinational banking groups

• How secondary-sanctions exposure can affect foreign financial institutions

• The operational implications of new SDN designations in non-sanctioned jurisdictions

• What businesses need to consider before applicable wind-down deadlines expire

👉 Download this week's Export Control & Sanctions Watch to access the full analysis, practical guidance and expert commentary.

Overview of What We Cover in This Week's Edition

Topic	Why It Matters
Syria Removed from Terror List	Major U.S. delistings mean outdated screening systems may now over-block lawful transactions.
HTS and Associated Delistings	Numerous names and aliases have been removed or re-anchored, requiring precise screening updates.
UK Russia Sanctions Package	Six banks, six tankers and critical-material supply chains are among the new targets.
Shadow-Fleet Vessels	Newly listed vessels may require immediate re-screening before charters and port calls.
Lukoil Licence Extensions	Extended permissions are accompanied by new notification requirements for some licence users.
Sakhalin-2 Permission Lapse	Previous UK licence cover has expired, requiring project-specific review of continuing activity.
Banque Misr UAE	Proposed Section 311 action could disrupt correspondent-banking and dollar-clearing routes.
Iran Financial Networks	New designations affect businesses operating through the UAE, Hong Kong and other trading hubs.
ICC Designations	New U.S. sanctions affect ICC officials, with a limited wind-down period.
SDGT Listings	New designations include organisations operating in Europe and the Americas, creating non-traditional service-provider exposure.
EU Crypto Services Restrictions	Russian and Belarusian ownership restrictions have expanded to cover nearly all crypto-asset services.
Russian Defence Industry Listings	The EU has listed additional individuals linked to Russia's military-industrial complex.
Diamond Import Authorisation	Certain grandfathered Russian diamonds remain eligible for U.S. entry until 2027, subject to strict documentary conditions.
Venezuela Licensing Changes	Revised licences create new commercial opportunities but introduce reporting and contractual conditions.
Export Control Enforcement	Recent BIS and OFAC settlements highlight risks involving end users, subsidiaries, distributors and HTS-code controls.

This is the value of the Export Control & Sanctions Watch: filtering a rapidly changing sanctions and export-control environment into the developments most likely to affect cargo, payments, counterparties and compliance decisions.

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Whether your business exports, imports, manages global supply chains, processes international payments or works with overseas customers and suppliers, The Export Control & Sanctions Watch helps you monitor the regulatory changes that can affect transactions.

Our coverage brings together developments involving:

• Economic sanctions

• Restricted-party designations and delistings

• Export controls

• General licences and wind-down periods

• Secondary sanctions

• Financial sanctions

• Shipping and vessel restrictions

• End-use and end-user controls

• Enforcement actions and compliance lessons

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Author

Ann Karen | Head of Growth

Updated: 4 September 2026

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