US And UK Memorialize Cooperation On Economic Sanctions Enforcement

Western countries are increasingly focussed on the effective implementation of their sanctions regimes.

Partner John Binns and Principal Associate Alex Gorst examine significant developments in UK and international sanctions law, including new sectoral measures against Iran, proposed Israeli settlement sanctions, OFSI's £4.7 million Citibank penalty, and the US Treasury's intensified Operation Economic Outcast targeting Iranian networks.

Recent enforcement actions by the UK's FCA and OFSI emphasize the need for businesses to implement effective financial crime and sanctions controls. Starling Bank was fined £28.9M for control failures, while ICSL faced penalties for sanctions breaches.

The Solicitors Regulation Authority for England and Wales has, in its Annual Report for Money Laundering covering 2023/2024, has stated that it has required 9 law firms to report themselves...

The UK has dramatically expanded its sanctions regime against Iran through new regulations that came into force on 29 September 2026, introducing sweeping sectoral measures across finance, energy, shipping...

The UK Government has codified the annual "Frozen Assets Review" under its sanctions regimes, through the Sanctions (EU Exit) (Miscellaneous Amendments) (No 2) Regulations 2024 ("Amending Regulations").

The UK government has announced new Russia-related energy sanctions measures targeting LNG tankers and shipping networks, while simultaneously introducing trade licences for Sakhalin-2 LNG shipments to Japan and South Korea.

Welcome to BCL’s latest sanctions and export controls round-up, highlighting the key developments in UK and international sanctions

It is a pernicious feature of sanctions laws that they affect far more people than they target.

In this post, we summarise recent developments regarding the UK sanctions imposed on Russia. On 19 May, the UK announced the addition of 86 further entries to its asset freeze list.

The U.S. Department of State has released the October 2026 Visa Bulletin, marking the start of fiscal year 2027 with significant changes to employment-based immigrant visa categories. How will the advancement of priority dates, particularly the substantial four-year leap for mainland China-born EB-5 investors in the Dates for Filing chart, impact eligible applicants seeking adjustment of status benefits?

The Department of Homeland Security has not issued formal determinations for Temporary Protected Status designations for Ukraine and Sudan despite the October 19, 2026 expiration date, creating uncertainty for employers navigating Form I-9 compliance and employment authorization documentation. USCIS states that affected individuals retain TPS protections and work authorization, but has not updated operational guidance to explain how employers should document continued employment eligibility or handle

U.S. consulates across India have begun cancelling and automatically rescheduling H-1B and H-4 visa appointments (often 90 to 120 days later)...

Following a federal court order in Medani v. Trump, the U.S. Department of State has resumed issuing Diversity Immigrant Visas after a nine-month pause that began in December 2025. DV-2026 selectees now face a critical deadline of September 30, 2026, to complete their visa processing or permanently lose their opportunity for permanent residence through the diversity visa lottery program.

The Federal Trade Commission is exploring whether digital platforms should bear greater responsibility for preventing impersonation ads that falsely pose as legitimate businesses or government agencies. Through an Advance Notice of Proposed Rulemaking, the agency seeks public input on potential amendments to its existing Impersonation Rule, examining how ad-optimization tools and platform practices...

The U.S. Department of State's November 2026 Visa Bulletin brings forward movement in several family-sponsored and employment-based immigrant visa categories, with significant advances for certain countries and preference levels. USCIS has confirmed that applicants in all preference categories may use the Dates for Filing chart to determine eligibility for adjustment of status applications, potentially allowing earlier filing for those whose priority dates fall before the applicable cut-off dates.

California's Climate Corporate Data Accountability Act (SB 253) establishes a November 10, 2026 deadline for Scope 1 and Scope 2 greenhouse gas emissions reporting, affecting U.S.-formed entities with over $1 billion in revenue that meet California's "doing business" test—regardless of physical presence in the state. The law carries penalties up to $500,000 per reporting year for non-compliance, with mandatory program fees and future Scope 3 reporting requirements on the horizon.

The European Commission has published draft guidelines interpreting the AI Act's transparency obligations, establishing when and how organizations must disclose AI-generated content, deepfakes, and automated interactions. These guidelines clarify that deepfake labeling applies regardless of intent to deceive, that AI systems must identify themselves at the point of interaction, and that the editorial review exception for AI-generated text requires substantive human oversight with clear accountability.

On Oct. 7, 2026, at 18:00 UTC, the Internet Corporation for Assigned Names and Numbers (ICANN) will publish every new generic top-level domain (gTLD) application proceeding in the 2026 new gTLD Round, including who applied...

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp