Tabla de contenidos
European Union
Russia
As part of the sanctions against Russia, the European Union published, in early March 2026, Council Decision (CFSP) 2026/490 of 26 February 2026, amending Decision 2014/119/CFSP concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine, and Council Implementing Regulation (EU) 2026/489 of 26 February 2026, implementing Regulation (EU) No 208/2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine, by which this regime of restrictive measures is extended until 6 March 2027.
Furthermore, the information contained in the annexes to the relevant instruments concerning the rights of defence and effective judicial protection of certain designated Russian citizens is updated. The Council, on the basis of information provided by the Ukrainian authorities, considers that criminal proceedings for the misappropriation of public funds or assets are still ongoing and that, in their conduct, fundamental procedural guarantees have been respected, including the right to be heard by an independent and impartial court within a reasonable time. The Council further emphasises that the duration of those proceedings has been partially conditioned by the conduct of the defendants themselves, in particular by their evasion of the investigation or their status of being declared in default by the court.
Sudan
Also at the beginning of the month, the European Union adopted Council Implementing Decision (CFSP) 2026/529 of 5 March 2026, implementing Decision 2014/450/CFSP concerning restrictive measures in view of the situation in Sudan, and Council Implementing Regulation (EU) 2026/531, implementing Article 15(1) of Regulation (EU) No 747/2014 concerning restrictive measures in view of the situation in Sudan, with the aim of updating the regime of restrictive measures concerning Sudan, in accordance with the decision adopted on 24 February 2026 by the Sanctions Committee of the United Nations Security Council. Pursuant to these acts, the Union added four members of the Rapid Support Forces (RSF) to its list of persons subject to restrictive measures.
The inclusion is based on their alleged involvement in actions threatening the peace, security and stability of Darfur, including serious human rights violations committed in El Fasher on 26 October 2025. According to information gathered by the United Nations, these acts reportedly included the killing of civilians, ethnically motivated executions, widespread sexual violence and the taking of healthcare workers hostage, which have led to the displacement of some 70,000 people.
ISIL (Daesh) and Al-Qaeda
On 9 March 2026, the European Union adopted the Commission Implementing Regulation (EU) 2026/561, amending for the 354th time Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against persons and entities associated with ISIL (Da’esh) and Al-Qaida. The amendment follows the decision by the United Nations Security Council Sanctions Committee to remove an entry from the list of persons and entities subject to the freezing of funds and economic resources.
Specifically, the Regulation removes from Annex I the entry relating to the Al-Nusra Front for the People of the Levant, also known by various names, including Hay’at Tahrir al-Sham (HTS).
Sanctions against cyberattacks
On 16 March 2026, the EU decided, by means of Council Decision (CFSP) 2026/588 of 16 March 2026 amending Decision (CFSP) 2019/797 concerning restrictive measures against cyber-attacks threatening the Union or its Member States, and Council Implementing Regulation (EU) 2026/589 implementing Regulation (EU) 2019/796 concerning restrictive measures against cyber-attacks threatening the Union or its Member States, to add two natural persons and three entities to the sanctions list, for their responsibility in committing, facilitating or participating in cyberattack activities with a cross-border dimension, including unlawful access to information, the exploitation of digital infrastructure, interference in democratic processes and the provision of hacking-as-a-service.
Iran
On 16 March 2026, the European Union adopted Council Implementing Decision (CFSP) 2026/645 implementing Decision 2011/235/CFSP concerning restrictive measures directed against certain persons and entities in view of the situation in Iran, as well as Council Implementing Regulation (EU) 2026/648 implementing Regulation (EU) No 359/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran.
This action forms part of, and must be read in conjunction with, the statement issued on 9 January 2026 by the High Representative of the Union for Foreign Affairs and Security Policy, Kaja Kallas, in which she referred to reports on victims and condemned the use of violence, arbitrary detentions and intimidation tactics by Iranian security forces during the demonstrations that have taken place since December 2025. In this context, and in application of this legal framework, the Union agreed to include sixteen individuals and three entities in the sanctions list set out in the Annex to Decision 2011/235/CFSP.
In the same vein, on 30 March 2026, the Council decided to extend until 13 April 2027 the restrictive measures under this regime relating to human rights violations in Iran, while also removing one listed individual and updating the entries concerning four individuals and two entities, pursuant to Council Decision (CFSP) 2026/779 amending Decision 2011/235/CFSP concerning restrictive measures directed against certain persons and entities in view of the situation in Iran and Council Implementing Regulation (EU) 2026/776 implementing Regulation (EU) No 359/2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran.
In addition, on 30 March 2026, the Council adopted a series of measures aimed at updating the EU sanctions regime against Iran in light of the current situation in the Middle East and the reimposition, on 29 September 2025, of United Nations sanctions relating to nuclear activities, in accordance with United Nations Security Council Resolution 2231 (2015).
In particular, Council Decision (CFSP) 2026/762 amending Decision 2010/413/CFSP concerning restrictive measures against Iran and Council Regulation (EU) 2026/759 amending Regulation (EU) No 267/2012 concerning restrictive measures against Iran and repealing Regulation (EU) No 961/2010 revise the export control framework by amending Article 1(1)(e) of Decision 2010/413/CFSP to include the prohibition on the export of goods and technology, including software, which qualify as dual-use items within the meaning of Regulation (EU) 2021/821, except for those listed in Part A of Annex I to Regulation (EU) 2026/759. Furthermore, the Member State concerned is required to notify the other Member States and the Commission, within four weeks, of any authorisations granted by its competent authorities pursuant to Regulation (EU) 2021/821 in respect of such Annex I items, which shall be valid throughout the Union.
Finally, Council Decision (CFSP) 2026/774 of 30 March 2026 amending Decision 2010/413/CFSP concerning restrictive measures against Iran and Council Implementing Regulation (EU) 2026/775 of 30 March 2026 implementing Regulation (EU) No 267/2012 concerning restrictive measures against Iran provided for the removal of six individuals and two entities from the list, as well as the updating of the information relating to five further entries included in Annex II.
Bosnia and Herzegovina
The Council of the European Union has decided to extend until 31 March 2027 the legal framework allowing for the adoption of restrictive measures in relation to the situation in Bosnia and Herzegovina. This extension maintains the EU’s ability to impose specific sanctions against natural or legal persons who undermine the country’s sovereignty, territorial integrity, constitutional order or international personality, as well as against those who seriously threaten its stability or undermine the Dayton Agreements.
Although, at the time of publication of this newsletter, the relevant CFSP Decision and its implementing regulation have not yet been published in the OJEU, the measure forms part of the continuation of the regime established by Council Decision 2011/173/CFSP of 21 March 2011 concerning restrictive measures in view of the situation in Bosnia and Herzegovina.
United States
Russia
On 12 March, OFAC issued General Licence No 134 and, subsequently, on 19 March, General Licence No. 134A, which authorise, until 11 April 2026, the transactions necessary for the sale, delivery or unloading of crude oil and petroleum products of Russian origin loaded onto vessels prior to 12 March 2026, including where such vessels are blocked under applicable sanctions regimes. These authorisations include logistical operations and services necessary for the safe management of vessels, but do not extend to transactions prohibited by other sanctions regimes, in particular those relating to the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba and the regions of Ukraine subject to restrictive measures.
Belarus
On 26 March, OFAC adopted various measures relating to the sanctions regime applicable to Belarus, issuing General Licence No. 14, which authorises certain transactions involving Belinvestbank (the Development and Reconstruction Bank of Belarus) and other additional entities.
Furthermore, in coordination with the Department of State, it concluded that the circumstances justifying the restrictions imposed on the Ministry of Finance of the Republic of Belarus and the Development Bank of Belarus under Directive 1 issued pursuant to Executive Order 14038 no longer exist, and consequently proceeded to revoke them.
Furthermore, it updated its list of Specially Designated Nationals (SDN), removing various entities, including Belaruskali and the Belarusian Potash Company, as well as other affiliated companies, thereby rendering General Licence No. 13 null and void due to loss of purpose.
Democratic Republic of the Congo
On 2 March 2026, OFAC sanctioned the Rwandan Defence Forces (RDF) and four senior military commanders under the sanctions regime relating to the Democratic Republic of the Congo. According to the Treasury Department, the RDF is alleged to have provided operational, logistical and military support to the M23 armed group, which is subject to sanctions by the United States and the United Nations, thereby facilitating its control of territories and strategic mining areas in the east of the country and contributing to the destabilisation of the region.
In parallel, OFAC issued General Licence No. 1, which authorises, until 1 April 2026, certain transactions necessary for the orderly winding-up of operations involving the RDF or entities in which the RDF holds, directly or indirectly, a 50% or greater stake. The authorisation is limited to those transactions that are ordinarily incidental and necessary to terminate existing commercial relationships and stipulates that any payment to blocked persons must be made into blocked accounts, in accordance with the provisions of the applicable sanctions regulations.
Venezuela
OFAC published new FAQs (1240–1244) on 4 March, relating to the sanctions regime against Venezuela, in which it clarifies the scope of several general licences applicable to the oil and gas sector, in particular General Licences Nos. 48, 49 and 50A, concerning the supply of goods and services, the negotiation of contingent investment contracts and certain oil-related transactions with authorised entities. It further adds that the performance of contracts entered into under General Licence No. 49 will require a specific licence assessed on a case-by-case basis.
It also issued General Licence No. 51 on 6 March, as well as Nos. 51A, 54 and 55 on 27 March, authorising certain activities relating to gold of Venezuelan origin. The licences allow US-based entities to export, sell, transport, refine or resell Venezuelan gold in the United States, even where the transactions involve the Venezuelan Government or the state-owned mining company Minerven, provided certain conditions are met. Key conditions include that contracts be governed by US law, that payments to sanctioned individuals be deposited into funds designated by the Treasury, and that periodic due diligence reports on the gold supply chain be submitted. The authorisation excludes transactions with certain sanctioned countries, payments in cryptocurrencies, transactions involving sanctioned vessels, or gold mining and production activities on Venezuelan territory.
Furthermore, the US continues to adjust its sanctions regime on the Venezuelan energy sector through the updating and issuance of new General Licences by OFAC, notably Nos. 46B, 48A, 49A, 52 and 5V, which introduce authorisations to progressively permit certain operations and investments, previously restricted, in the field of hydrocarbon exploration, production and marketing in the country.
Finally, OFAC issued General Licence No. 53 on 24 March, authorising certain transactions necessary for the provision of goods and services in the United States to official missions of the Government of Venezuela and its representations to international organisations, as well as to their staff and dependants, provided that they are intended for the performance of official duties or for personal use, do not involve commercial activities or real estate transactions, and are not prohibited by other applicable regulations; it also permits US financial institutions to maintain accounts, extend credit and process transfers related to these activities. In practice, this licence aims to facilitate the day-to-day operations of Venezuelan diplomatic missions on US territory, as a preliminary step towards the potential reopening of the embassy in Washington and consular offices in the United States.
Sudan
On 9 March, OFAC adopted new measures under the counter-terrorism regime, designating the Sudanese branch of the Muslim Brotherhood as a Specially Designated Global Terrorist and adding it to the SDN list. Furthermore, the State Department announced its intention to designate the organisation as a Foreign Terrorist Organisation (FTO) with effect from 16 March 2026. According to US authorities, the group is alleged to have participated in acts of violence against civilians in the context of the conflict in Sudan and to maintain links with Iran’s Islamic Revolutionary Guard Corps.
In parallel, the designation of the previously sanctioned armed group Al-Baraa Bin Malik Brigade was updated to reflect its links to the Muslim Brotherhood in Sudan.
Democratic People’s Republic of Korea (DPRK)
On 12 March 2026, OFAC added six individuals and two entities to the SDN list for their involvement in international networks facilitating the North Korean regime’s cyber labour schemes, used to defraud foreign companies and generate revenue to fund the country’s weapons of mass destruction and ballistic missile programmes.
OFAC also sanctioned the North Korean company Amnokgang Technology Development Company and the Vietnamese company Quangvietdnbg International Services Company Limited, which are used to facilitate payments, currency conversions and cryptocurrency transactions linked to these activities.
Counter-terrorism designations
Also on 12 March, OFAC designated four purportedly charitable organisations for their involvement in an international network financing Hamas. According to US authorities, these entities allegedly channelled funds and material support to the group’s military wing, the Izz ad-Din al-Qassam Brigades, by using humanitarian structures that masked activities intended to finance terrorist operations. The designated organisations are Ghazi Destek Dernegi, Hayat Yolu, Palestinian White Hands Assistance and Solidarity Association and Komite Nasional Untuk Rakyat Palestina, based mainly in Turkey and Indonesia.
United Kingdom
Russia
During March 2026, there have been no substantial changes to the sanctions regime against Russia following the comprehensive package approved at the end of February. The updates recorded consisted mainly of specific adjustments, notably two revocations of designations (on 2 and 17 March) and a more extensive update on the latter date, which included four amendments and one additional change. The remaining actions consisted of technical changes to existing entries on 6, 12 and 16 March.
ISIL (Daesh) and Al-Qaeda
On 2 March 2026, the United Kingdom updated the Sanctions List under the regime relating to ISIL (Daesh) and Al-Qaeda, in order to reflect the removal of the entity Al-Nusra Front for the People of the Levant from the list of sanctioned persons and entities. The removal followed a decision adopted by the United Nations Security Council.
The organisation, historically linked to Al-Qaeda and active in the Syrian conflict, had been included due to its involvement in terrorist activities and its cooperation with fighters affiliated with international jihadist networks.
On 27 March, it also designated two further individuals in accordance with the decision adopted on 26 March by the United Nations Security Council Sanctions Committee.
Afghanistan
On 11 March 2026, OFSI made 22 amendments under the sanctions regime against Afghanistan. These amendments involve updating the identifying and location details of individuals already subject to restrictive measures, such as dates of birth, aliases, passport numbers, positions, addresses and other personal or documentary details.
Human Rights
On 26 March 2026, OFSI updated the sanctions list under the Global Human Rights regime, adding ten new designations, including both natural and legal persons. The measures are based on the direct or indirect involvement of the designated entities in serious human rights violations, in particular due to their alleged participation in the operations, financing or support of scam centres in Southeast Asia, where practices constituting cruel, inhuman or degrading treatment, as well as situations of slavery, servitude and forced labour, have been documented.
United Nations
Afghanistan
The United Nations Security Council Sanctions Committee, established pursuant to Resolution 1988 (2011), approved on 10 March the amendment of 22 entries on its sanctions list relating to the Taliban, subject to an asset freeze, travel ban and arms embargo. The amendments relate exclusively to individuals already included on the list and consist mainly of updates to identifying and biographical details, such as passports, addresses, aliases, dates of birth and other supplementary information.
Among those whose records were updated are several senior officials and prominent members of the Taliban regime and its political, military and financial structures.
ISIL (Da’esh) and Al-Qaeda
On 26 March 2026, the United Nations Security Council Sanctions Committee agreed to add two new individuals (SC/16323 and SC/16324) to the sanctions list targeting ISIL (Da’esh) and Al-Qaeda, pursuant to Resolutions 1267 (1999), 1989 (2011) and 2253 (2015). The decision is based on their links to the organisation, in particular their involvement in the management of resources and financial support activities within its structure.
.
*******************************************
In Madrid, 31 March 2026
International Trade and Sanctions Department
Lupicinio International Law Firm
