Sanctions and Enforcement Ledger: 17 to 23 October 2026

Three actions in the week from 17 to 23 October 2026 named a company, bank or vessel from an emerging market, all of them by the US Office of Foreign Assets Control (OFAC), and a fourth OFAC action renewed a licence for the sale of Lukoil International GmbH. This ledger records every action by OFAC, the UK's sanctions authorities and the Council of the European Union that names a company, bank or vessel registered, flagged or based in an emerging market, with the notice linked. It follows the first edition, which covered 1 to 16 October.

The UK and the EU published no new listing in the period. The Foreign, Commonwealth and Development Office's collection of regime pages showed no notice dated after 16 October when read on 24 October, and OFSI's enforcement page showed no monetary penalty after the one of 2 September. The Council's press release listing for 19 to 23 October contains no restrictive measures. With three qualifying actions from one authority, this edition draws no pattern.

The ledger, 17 to 23 October

Notes on the rows

The 21 October Iran action follows the 15 October listings in Iran's financial networks, covered in our report on the Iraqi bank designation. General License GG covers the law firm, entities it owns 50 per cent or more and individuals acting solely for them, and General License HH covers Roxette, entities it owns 50 per cent or more and its seven vessels. Neither names Amigoz Singapore, Whales Shipping Line or the UAE-flagged vessels. The individuals in that row are named only through their link to the listed firm, as the notice links them.

The 19 October entities are on the Non-SDN Menu-Based Sanctions List rather than the SDN List. The notice sets out the menu applied to each: blocking of property except for the import of goods, a cap of $10 million in loans or credits from US financial institutions in any 12-month period, and bans on foreign exchange and banking transactions under US jurisdiction and on US persons investing in or buying significant amounts of the entities' equity or debt.

The North Korea removals concern two Shanghai animation studios and one individual, linked in the listing to SEK Studio or to Lu Hezheng. A removal is recorded as a row because it changes the screening result for the names concerned. The Lukoil licence is a renewal of an existing authorisation and is counted as a licence row, not as a new listing. It does not authorise performance of any sale, which needs separate OFAC authorisation.

Also in the period

OFAC amended two frequently asked questions, numbers 1224 and 1225, in the 21 October action; the notice does not give the amended text.

Method: entries come from OFAC's recent actions, the FCDO's regime pages, OFSI's enforcement collection and the Council's press releases, read on 24 October 2026. Counts are as stated in each notice. A renewal is not counted as a new listing. The next edition covers 24 to 30 October.