Tabla de contenidos
European Union
Russia
Among the most relevant developments in the field of restrictive measures against Russia, the European Union adopted, at the end of April 2026, its twentieth package of sanctions, in continuity with its strategy since the outset of the conflict in Ukraine and following several months of deadlock resulting from divergences in political decision-making among the Member States. This is a far-reaching package, both in its material scope and in its qualitative orientation, which has a cross-cutting impact across various sectors, including energy, financial services, trade and the military sphere.
Furthermore, noteworthy is the publication, on 21 April 2026, of Council Decision (CFSP) 2026/884, as well as Council Implementing Regulation (EU) 2026/885, which add two legal persons to Annex I, in view of their alleged involvement in information manipulation and interference activities affecting the stability and security of the Union and of third countries. The designated entities comprise a media platform and a foundation linked to Russia’s external projection, both considered by the Council as instruments contributing to the dissemination of certain narratives and support for the Russian Government.
ISIL (Daesh) and Al-Qaeda
Commission Implementing Regulation (EU) 2026/819 of 1 April 2026 and Commission Implementing Regulation (EU) 2026/830 of 7 April 2026 jointly introduce three new designations to Annex I of Regulation (EC) No 881/2002, imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Daesh) and Al-Qaida organisations, in implementation of the decisions adopted on 26 and 30 March 2026 by the UN Security Council Sanctions Committee.
Two natural persons of Iraqi nationality are included, who are understood to have held relevant roles within the financial and operational structure of ISIL (Da’esh), including responsibilities in resource management, revenue supervision and participation in terrorist activities. In addition, a third individual of Ugandan nationality is designated, who is understood to have acted as an intermediary in the group’s financing channels in Central Africa, and is allegedly involved in the financing of an attack in Kampala in 2021, as well as in activities relating to the recruitment and forced transfer of minors to areas under the organisation’s control.
Republic of Moldova
The European Union adopted two new instruments under the sanctions regime applicable to the Republic of Moldova, namely Council Decision (CFSP) 2026/897 of 21 April 2026, amending Decision (CFSP) 2023/891 concerning restrictive measures in respect of actions destabilising the Republic of Moldova, and Council Implementing Regulation (EU) 2026/898 of 21 April 2026, implementing Regulation (EU) 2023/888 on restrictive measures in respect of actions destabilising the Republic of Moldova, with the aim of extending the validity of the measures until 29 April 2027.
Similarly, both instruments introduce adjustments to the list of sanctioned persons by updating the information relating to seven individuals already designated, who are considered by the Council to be linked to activities such as the illegal financing of political actors, interference in electoral processes, or the dissemination of disinformation.
Myanmar/Burma
As regards the situation in Myanmar/Burma, the European Union adopted, on 27 April 2026, Council Decision (CFSP) 2026/927, amending Decision 2013/184/CFSP concerning restrictive measures in view of the situation in Myanmar/Burma, together with Council Implementing Regulation (EU) 2026/926, implementing Regulation (EU) No 401/2013 concerning restrictive measures in view of the situation in Myanmar/Burma, by means of which the sanctions are extended until 30 April 2027, due to the continuing situation in the country, characterised by the erosion of democratic order following the 2021 coup d’état.
Both instruments also include updates to the entries concerning thirty-three natural persons and nine entities, as well as the removal of one deceased individual. The grounds for designation focus primarily on direct or indirect participation in the military coup, the exercise of functions within regime structures, the adoption of decisions restricting fundamental rights (such as freedom of expression, assembly or access to information), and involvement in serious human rights violations, including repression of the civilian population, arbitrary detentions and the use of violence by security forces. In the case of entities, emphasis is placed on their role in generating revenue and in providing economic and operational support to the Armed Forces, thereby contributing to the maintenance of the current regime.
United States
Russia
With regard to the Russian Federation, the activity undertaken during April 2026 by the Office of Foreign Assets Control (OFAC), under the US Department of the Treasury, has focused primarily on the issuance of new General Licences and the updating of their interpretative criteria through FAQs.
In this context, General Licence No. 13Q was published on 8 April 2026, within the framework of the sanctions regime relating to Russia’s harmful foreign activities (31 CFR Part 587). This licence authorises, until 9 July 2026, the performance of certain administrative operations by US persons or entities under their control, such as the payment of taxes, fees or import duties, as well as the obtaining of permits, licences or certifications, provided that such operations are necessary for the conduct of ordinary business in Russia and are subject to the restrictions set out in Directive 4 of Executive Order 14024. Some transactions are expressly excluded, in particular those involving debits to accounts held with US financial institutions belonging to the Central Bank of the Russian Federation, the National Wealth Fund or the Russian Ministry of Finance.
On the same day, OFAC also updated its FAQs 999 and 1118, clarifying that the so-called exit tax required by Russia in divestment processes could involve transactions with entities also subject to Directive 4 of Executive Order 14024. Consequently, the payment of this tax by US persons generally requires the prior obtaining of a specific licence, as these are transactions prohibited in the absence of authorisation. Furthermore, OFAC clarifies that the aforementioned General Licence No. 13Q does not cover this type of payment, as they are not considered ordinary transactions or necessary for day-to-day business in Russia.
As regards General Licence No. 128C (31 CFR Part 587), issued on 14 April 2026, authorises certain transactions relating to Lukoil’s retail service stations located outside the Russian Federation. Specifically, until 29 October 2026, transactions that are ordinary and necessary for the purchase of goods and services, as well as for the maintenance, operation or closure of such stations, are permitted where they involve Lukoil International GmbH and its controlled subsidiaries (including Lukoil North America LLC and Lukoil Americas Corporation).
Finally, it is also worth noting the publication, on 17 April 2026, of General Licence No. 134B, temporarily authorising certain operations relating to crude oil and petroleum products of Russian origin already loaded onto vessels prior to that date. Specifically, until 16 May 2026, transactions that are ordinary and necessary for the sale, delivery or unloading of such cargoes are permitted, including ancillary activities such as berthing, crew services, maintenance, insurance or safety and environmental protection measures. The authorisation expressly prohibits, as is customary, transactions involving certain sanctioned countries or territories (i.e. Iran, North Korea or Cuba).
Venezuela
On 1 April 2026, OFAC agreed to remove Delcy Eloína Rodríguez Gómez from the Specially Designated Nationals List (SDN List) under the sanctions regime relating to Venezuela. Similarly, on 14 April 2026, OFAC removed Reinaldo Enrique Muñoz Pedroza following his departure from office at the Venezuelan Attorney General’s Office. Consequently, the asset freezing measures and restrictions on transactions under US jurisdiction that resulted from their designation no longer apply to either of them.
At the same time, OFAC continues to adopt various General Licences with the aim of resuming economic relations with Venezuela. Of particular note is the approval, on 14 April 2026, of General Licences Nos. 56 and 57, which introduce specific authorisations that partially relax the current sanctions regime against the Government of Venezuela and selected associated entities.
Iran
Among the numerous actions taken by the United States during April 2026 in relation to sanctions against the Iranian regime, it is first worth noting the announcement of a new package of restrictive measures on 15 April. These measures target a network involved in the illicit trade of Iranian oil, covering more than two dozen individuals, entities and vessels engaged through maritime transport, commercial brokerage and the use of front companies. Their objective is to circumvent sanctions and channel substantial revenues to the Iranian regime and its affiliated structures. The designations were adopted pursuant to Executive Order 13902, relating to key sectors of the Iranian economy, and Executive Order 13224, as amended, concerning counterterrorism.
In parallel, on 15 April 2026, OFAC also sanctioned a financial network linked to Hezbollah and the Islamic Revolutionary Guard Corps’ Quds Force (IRGC-QF), based on the exchange of Iranian oil for gold sourced from Venezuela. This scheme, structured through international operators and front companies, is understood to have enabled the financing of terrorist activities through money laundering and sanctions evasion mechanisms.
In the same vein, on 21 April 2026, OFAC added 14 individuals, entities and aircraft based in Iran, Turkey and the United Arab Emirates to its lists, due to their involvement in networks for the procurement and transport of arms and military components on behalf of the Iranian regime. The measures, adopted pursuant to Executive Orders 13382 and 13224, focus on the structures used to support ballistic missile and unmanned aerial vehicle (UAV) programmes, including Shahed-type drones, as well as on the use of front companies and international financial channels to circumvent sanctions and rebuild military capabilities. In addition, pressure has been intensified on actors linked to Mahan Air, identified for its role in transporting weapons and UAV systems, through the designation of related entities, executives and aircraft under its control. The action also targets intermediaries involved in the acquisition of missile propellant precursors and in illicit financing operations.
In addition, approximately 40 entities and vessels belonging to the Iranian shadow fleet, responsible for the covert transport of crude oil, liquefied gas and other products to Asian markets, have been added to the list.
Finally, on 24 April 2026, the independent Chinese refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd., one of the world’s leading buyers of Iranian crude oil, was designated. According to the Treasury Department, this refinery is said to have purchased significant volumes of Iranian oil and petroleum products, including supplies linked to entities affiliated with the Iranian armed forces, generating substantial revenue for the regime. In this regard, it is worth noting the OFAC’s issuance of an alert to financial institutions regarding the sanctions risks associated with dealing with independent Chinese refineries, known as ‘teapot refineries’, particularly in Shandong province. According to OFAC, these facilities continue to play a significant role in the import and refining of Iranian crude, in the context of the renewed “maximum pressure” policy. The alert recalls that several of these refineries have been designated since March 2025 and that their assets under US jurisdiction are blocked, with transactions involving them generally prohibited unless specifically authorised. Both US and non-US persons, including financial institutions, may face sanctions exposure (including secondary sanctions) if they facilitate transactions involving such refineries or the Iranian oil supply chain.
Nicaragua
With regard to the Nicaraguan regime, OFAC imposed new restrictive measures against five individuals and seven entities linked to the country’s gold sector, for their role in generating revenue for the regime of Daniel Ortega and Rosario Murillo and in maintaining their political control. The designated parties include senior public officials, including two children of the presidential couple, as well as companies involved in the extraction, processing and export of gold through opaque structures aimed at channelling foreign currency, circumventing sanctions and financing repressive activities.
The measures also target individuals and entities involved in the forced confiscation of assets with US ownership, in particular through the occupation of mining facilities without compensation.
Sudan
On 17 April 2026, OFAC announced the imposition of sanctions against five individuals and entities involved in an international recruitment network facilitating the deployment of former Colombian military personnel to fight in Sudan in support of the Rapid Support Forces (RSF). This structure is understood to have contributed to intensifying the ongoing armed conflict, characterised by human rights violations, mass displacement and a humanitarian crisis. According to OFAC, the network operated through employment agencies and intermediary companies that recruited specialised personnel, including snipers and drone operators, and channelled funds and contracts to conceal their involvement in the conflict.
Sanctions against drug trafficking
On 14 April 2026, the US adopted new restrictive measures against six individuals and entities linked to the Cartel del Noreste (CDN), a criminal organisation designated as a foreign terrorist organisation. The measures target an alleged network engaged in money laundering and cash smuggling in the border area between the United States and Mexico, including three individuals with significant roles in the cartel’s operations in Nuevo Laredo, as well as two casinos used to channel illicit funds into the formal financial system. The designations were made pursuant to Executive Orders 14059 and 13224 and also extend to facilitators who, under the guise of legitimate professional activities, are understood to have supported the cartel’s operations and influence in the region.
Furthermore, on 23 April 2026, sanctions were imposed on 23 individuals and legal entities involved in a global network dedicated to supplying chemical precursors for the production of synthetic opioids in support of the Sinaloa Cartel, which has been designated as a foreign terrorist organisation. The action targets all stages of the supply chain, from chemical suppliers in Asia, particularly India, to intermediaries and logistics operators in Latin America, who are understood to be facilitating the illicit manufacture of substances such as fentanyl and methamphetamine through the use of international trade routes and concealment mechanisms.
Sanctions against cyberattacks
On 23 April 2026, OFAC designated Cambodian Senator Kok An, as well as 28 individuals and entities linked to his network, for their involvement in a network of fraud centres that is alleged to have defrauded US citizens of millions of dollars. These structures, operating in complexes linked to casinos and business parks, are understood to rely on digital fraud schemes, including fraudulent crypto-asset investments, as well as money laundering networks, with alleged political protection and, in some cases, the use of trafficking victims. The measures, adopted pursuant to Executive Order 13694, form part of a coordinated strategy with US law enforcement and judicial authorities to dismantle transnational cybercrime networks.
United Kingdom
Afghanistan
On 14 April 2026, the UK’s Foreign, Commonwealth and Development Office (FCDO) introduced amendments to the consolidated sanctions list under the Afghanistan regime, updating the designations of four senior officials linked to the Taliban regime.
Furthermore, on 16 April 2026, the FCDO further updated this list to introduce three changes to existing designations, relating to information concerning an entity noted for its role in channelling funds to the Taliban leadership and Al-Qaeda, as well as regarding two other individuals believed to be linked to the Haqqani network, terrorist activities, suicide operations and their financing.
United Nations
Sudan
On 28 April 2026, the United Nations Security Council Sanctions Committee, established pursuant to Resolution 1591 (2005) concerning Sudan, agreed to include four new individuals on its sanctions list, adopted under Chapter VII of the United Nations Charter. The designations include a senior procurement official of the Rapid Support Forces, as well as three individuals linked to recruitment and logistical support structures with an international reach, including officials from the International Services Agency (A4SI).
On 28 April 2026, the United Nations Security Council Sanctions Committee, established pursuant to Resolution 1591 (2005) concerning Sudan, approved the addition of four individuals to its sanctions list, adopted under Chapter VII of the Charter of the United Nations. The designations include a senior procurement official of the Rapid Support Forces, as well as three individuals linked to recruitment and logistical support structures with an international dimension, including persons associated with the entity International Services Agency (A4SI).
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In Madrid, 30 April 2026
International Trade and Sanctions Department
Lupicinio International Law Firm
