Weekly · Global Sanctions Surge & Banking Shifts · August 24–30, 2026

Rapidly shifting restrictions on Iran and terrorism

The final week of August has seen a concentrated wave of sanctions activity across the US and EU, requiring immediate updates to compliance screening and the cessation of specific trade flows. On August 26, the European Commission published the 360th amendment to Council Regulation (EC) No 881/2002. This update expands the list of persons and entities associated with ISIL (Da'esh) and Al-Qaida who are subject to restrictive measures. For businesses operating in the EU, this is an immediate requirement to update internal sanctions lists to prevent any funds or economic resources from being made available to these newly designated parties.

Simultaneously, the US Treasury’s Office of Foreign Assets Control (OFAC) has tightened the perimeter of prohibited transactions. On August 26, OFAC indefinitely suspended five general licenses that had previously allowed certain activities under the Iranian Transactions and Sanctions Regulations. The suspension of a general license is a critical event for business operations; it means that activities which were previously permitted without specific government authorization are now prohibited unless a firm obtains a specific license. Companies involved in Iranian trade or financial services must immediately audit their current authorizations to ensure they are not operating under a now-defunct general license.

Further US actions were published on August 27 and August 28. OFAC published a sector determination pursuant to Executive Order 13902, affecting entities subject to that order. Additionally, on August 28, OFAC updated the Specially Designated Nationals and Blocked Persons List (SDN List) to include new persons and vessels. The addition of vessels to the SDN list is particularly significant for shipping, logistics, and insurance firms, as any interaction with a blocked vessel can lead to severe secondary sanctions.

Our read: The simultaneous tightening of Iranian and terrorism-related lists across the Atlantic suggests a coordinated effort to close loopholes and increase the velocity of sanctions enforcement.

Credit oversight and operational risk overhaul

US and EU regulators are rethinking how financial institutions manage risk and how credit is administered. In a high-significance move published on August 25, the US Office of the Comptroller of the Currency (OCC) rescinded the Interagency Statement on Special Purpose Credit Programs (SPCPs) under the Equal Credit Opportunity Act and Regulation B. This statement, originally dated February 22, 2022, provided guidance on how creditors could establish programs to extend credit to disadvantaged groups. The rescission of this guidance removes a key interpretive framework that creditors relied upon to ensure their special credit programs remained compliant with non-discrimination laws. Creditors must now re-evaluate their SPCPs without the benefit of this specific interagency guidance, which may increase the legal risk of implementing targeted credit initiatives.

In Europe, the European Banking Authority (EBA) is targeting the structural and operational stability of institutions. On August 26, the EBA opened a consultation on draft technical standards concerning operational risk management for institutions. This focuses on how banks and financial firms identify, monitor, and mitigate risks arising from internal failures or external events. For managers, this signals a move toward more prescriptive requirements on how "operational resilience" is documented and tested.

Additionally, the EBA published a consultation on August 25 regarding the reclassification of investment firms as credit institutions. This is a pivotal shift for firms looking to expand their business models; moving from an investment firm license to a credit institution license typically involves significantly higher capital requirements and a different supervisory regime. Firms currently operating as investment firms that intend to take deposits or offer traditional banking products must assess these revised standards to determine the feasibility of a license upgrade.

In the US, the Commodity Futures Trading Commission (CFTC) is proposing a move toward greater flexibility for Swap Execution Facilities (SEFs). In a proposal published on August 26, the CFTC seeks to remove the requirement for SEFs to provide an order book for certain swap transactions that are not subject to the trade execution requirements of the Commodity Exchange Act. If adopted, this would allow SEFs to facilitate certain trades without the transparency and rigidity of a public order book, potentially allowing for more bespoke or bilateral-style negotiations within the SEF environment.

Our read: Regulators are moving toward more flexible operational requirements for swaps while removing previous guidance on credit programs, effectively shifting more risk-assessment responsibility onto the firms themselves.

Enforcement crackdown on fraudulent credentials

Regulators in the US and UK are increasingly targeting the "front door" of the industry—the filings and licenses that allow a firm to claim legitimacy in the first place. On August 27, the SEC charged 38 entities with making material misrepresentations in their Form ADV filings between 2025 and 2026. Form ADV is the primary disclosure document used by investment advisers to describe their business practices, fees, and disciplinary history to clients and the SEC. The SEC alleges these entities falsely portrayed themselves as legitimate advisory firms to lure retail investors. For business founders and managers, this highlights the extreme scrutiny now placed on regulatory filings; any discrepancy between a firm's marketed image and its official SEC filings is being treated as a potential fraud.

Across the Atlantic, the UK's Financial Conduct Authority (FCA) focused on the "fitness and propriety" of senior management. On August 26, the FCA announced it had banned three former senior figures at Dolfin Financial (UK) Limited and imposed fines on the former chief executive and finance director. The enforcement action stemmed from a scheme designed to bypass UK visa rules. This is a significant reminder that the FCA's oversight extends beyond financial misconduct to include general integrity and adherence to national laws. Using regulatory or immigration loopholes to staff a firm is now being viewed as a breach of the standards required to hold a senior management function.

Our read: Enforcement is shifting from focusing solely on market abuse to targeting the fundamental legitimacy of firms, making accurate regulatory filings and personal integrity of executives a primary target for auditors.

Easing frictions in US-EU Treasury markets

There is a small but notable movement toward reducing administrative hurdles for EU-linked debt in the US. On August 28, the SEC proposed amendments to Rule 3a12-8 under the Securities Exchange Act of 1934. The goal is to add the debt obligations of the European Union to the list of foreign government debt obligations that are designated as "exempted." In practical terms, this would treat EU debt instruments similarly to those of individual sovereign nations, potentially reducing reporting requirements and registration burdens for US-based entities dealing in these securities. For asset managers and treasury departments, this proposal suggests a path toward smoother operational handling of EU-issued debt.

Our read: This proposal likely aims to lower the administrative burden for US markets dealing with EU sovereign-backed instruments, signaling a desire for greater capital fluidity between the two jurisdictions.

Technical product assessment updates

Finally, on August 27, the European Commission published technical systems for the assessment and verification of product families and categories. This publication supplements Regulation (EU) 2024/3110 and reflects a decision made on June 11, 2026. This is largely a procedural update establishing the mechanisms by which products are verified for compliance with EU standards before they enter the market.

This overview is informational, not legal or compliance advice. Consult your lawyer or compliance specialist on specific decisions.

Sources

This overview is based on official regulator publications for the period:

CH (4)

EU (29)

HK (11)

UK (18)

US (47)