The Export Control & Sanctions Watch Edition 26
- Annkaren Wambui
- 2 days ago
- 5 min read
š Iran's Oil Window Closes | Russia Sanctions Expand | National Export Controls Go EU-Wide
The Export Control & Sanctions WatchSummary:Ā The sanctions landscape continues to evolve at pace. The United States has abruptly revoked General License X for Iranian oil, the European Union is preparing its 21st Russia sanctions package, Member States' national export control lists are becoming more influential across Europe, and both the EU and UK have expanded sanctions linked to the Navalny poisoning. This week's Export Control & Sanctions WatchĀ provides practical intelligence to help businesses anticipate compliance risks before they become enforcement issues. š„ Read the latest edition here (PRO Subscription required) |
š®š· OFAC Closes the Window on Iranian Oil
The United States has revoked General License X, replacing it with a wind-down-only licence that expires on 17 July 2026.
For companies trading in Iranian-origin crude oil, petrochemicals or petroleum products, this is one of the most time-sensitive sanctions developments of the year. Businesses must ensure that no new transactions are initiated and that existing authorised activities are completed before the deadline.
This week's Export Control & Sanctions WatchĀ explains the implications of the revocation, the wind-down requirements, and the practical compliance actions organisations should take immediately.
š Download this week's Export Control & Sanctions Watch to read the full analysis.
šŖšŗ Europe's 21st Russia Sanctions Package Is Almost Here
The European Union's 21st sanctions packageĀ has moved a step closer to adoption, with implementation expected shortly.
The package is expected to introduce additional asset freezes, new export controls, expanded banking restrictions, and measures affecting companies across several third countries.
Businesses trading with Russia or with supply chains involving China, TĆ¼rkiye, Kazakhstan, Kyrgyzstan, the UAE or India, should begin assessing exposure now rather than waiting for the measures to enter into force.
š Download this week's Export Control & Sanctions Watch to discover what is changing and how to prepare.
ā ļø National Export Control Lists Are Becoming More Important
The European Commission has published its first compilation of Member States' national control lists under Article 9(4) of the EU Dual-Use Regulation.
This confirms that exporters can no longer rely solely on the EU's Annex I Dual-Use List. National controls are becoming an increasingly important part of export licensing and compliance across Europe.
For businesses dealing in semiconductors, advanced computing, AI technologies and other emerging technologies, export control compliance is becoming a continuous intelligence exercise rather than a once-a-year legal review.
š Download this week's Export Control & Sanctions Watch to understand what this means for your organisation.
š¬š§šŖšŗ Chemical Weapons Sanctions Continue to Expand
The European Union and the United Kingdom have both introduced new sanctions linked to the poisoning of Alexei Navalny.
The measures include new asset freezes and designation updates, reinforcing the importance of regularly refreshing sanctions screening systems and reviewing research, scientific and supply chain relationships that may create indirect exposure.
š Download this week's Export Control & Sanctions Watch to explore the latest enforcement developments and recommended compliance actions.
Overview of This Week's Changes
Topic | Why It Matters |
OFAC Revokes General License X | Iranian oil transactions now enter a short wind-down period ending 17 July 2026. |
EU 21st Russia Sanctions Package | Businesses should prepare for expanded banking, export control and asset freeze measures. |
National Control Lists Published | Exporters must monitor Member State controls alongside the EU Dual-Use List. |
Navalny Sanctions Expanded | EU and UK designation updates require immediate sanctions screening. |
OFAC Clarifies Russia Exit Tax | Russia exit taxes require a specific OFAC licence and are not covered by GL 13R. |
Maritime Mutual Licence Extended | UK wind-down licence extended until October 2026. |
GL 13R Renewed | Routine Russia administrative payments remain authorised through October. |
Khan Appeal Opinion | Important legal development for businesses monitoring EU sanctions litigation. |
Summer Break Notice
As a reminder to our readers, The Export Control & Sanctions WatchĀ will publish its final edition before the summer break on 31 July 2026.
There will be no editions published between 3 August and 31 August, with publication resuming on 1 September 2026.
We look forward to returning after the break with the latest customs, trade and regulatory developments.
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Author
Ann Karen | Head of Growth ā Customs Manager Ltd
Updated:Ā 10 July 2026
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