Executive Summary
This week demonstrated that sanctions policy is entering a new phase.
While the United States has begun implementing temporary sanctions relief for certain Iran-related activities as negotiations continue, Western governments have simultaneously increased pressure on Russia through new designations, expanded enforcement measures and continued action against sanctions circumvention networks.
For compliance professionals, this creates an increasingly challenging environment.
The headline may be sanctions relief.
The operational reality is greater compliance complexity.
Understanding where restrictions are being eased is becoming just as important as understanding where enforcement continues to intensify.
Featured Analysis
Sanctions Relief Does Not Mean Compliance Relief
Much attention this week focused on the United States issuing temporary authorisations linked to ongoing negotiations with Iran.
Some businesses may interpret this as signalling a broader return to commercial activity.
That would be a mistake.
Temporary licences and sanctions waivers are not the same as wholesale sanctions removal.
Even where certain transactions become authorised:
• Many SDN designations remain unchanged.
• Counter-terrorism measures continue to apply.
• Human rights sanctions remain in force.
• Proliferation-related restrictions remain largely unaffected.
• Secondary sanctions risks continue to exist.
• Many international banks will continue adopting a cautious approach.
Perhaps more importantly, the United States, European Union and United Kingdom are unlikely to move at exactly the same pace.
Compliance teams should therefore avoid treating sanctions relief as a global event.
Instead, firms should assess each transaction against the specific sanctions regimes that apply to their business.
The greatest compliance risk over the coming months may not be breaching sanctions intentionally.
It may be incorrectly assuming restrictions have disappeared.
Russia: Enforcement Continues to Accelerate
While attention shifted towards Iran, Russia enforcement continued to move in the opposite direction.
During the past week regulators continued advancing measures aimed at:
• Shadow fleet operators
• Military procurement networks
• Third-country financial institutions
• Cryptocurrency platforms
• Oil traders facilitating sanctions evasion
• Banks supporting Russian financial activity
• Companies involved in procurement through intermediary jurisdictions
The proposed EU 21st sanctions package remains one of the most significant packages considered since 2022, demonstrating that Russia remains firmly at the centre of Western sanctions policy.
At the same time, the European Union confirmed the renewal of key Russia sanctions for a further 12 months, reinforcing expectations that restrictions will remain a long-term feature of the international sanctions landscape.
Emerging Theme: Facilitation Risk Has Become the Enforcement Priority
Across both Russia and Iran developments, one trend continues to emerge.
Regulators are increasingly focused on the organisations that enable sanctions evasion rather than only those directly subject to sanctions.
Increasing attention is being given to:
• Financial intermediaries
• Payment processors
• Trading companies
• Logistics providers
• Maritime service providers
• Cryptocurrency exchanges
• Corporate service providers
For many organisations, indirect exposure now represents a greater regulatory risk than direct exposure.
What Compliance Teams Should Be Reviewing
Iran
Review internal guidance to ensure staff understand the difference between:
• General licences
• Temporary sanctions relief
• Full sanctions removal
Authorised activity in one jurisdiction does not automatically mean activity is permitted elsewhere.
Russia
Continue reviewing exposure to:
• Third-country counterparties
• Shadow fleet indicators
• High-risk trade corridors
• Cryptocurrency transactions
• Financial intermediaries
• Maritime services
Governance
Ensure decision-making is properly documented.
Regulators increasingly expect firms to demonstrate not only the outcome reached, but also the rationale behind that decision using the information available at the time.
Key Takeaway
The sanctions environment is no longer moving in one direction.
Some restrictions are beginning to soften.
Others are becoming significantly tougher.
That means compliance programmes must become increasingly dynamic.
The question organisations should now be asking is not simply:
“Is this transaction sanctioned?”
It is:
“Which sanctions regimes apply, what relief (if any) exists, and can we demonstrate why our decision was appropriate?”
That is rapidly becoming the defining compliance challenge of 2026.
Comply Sphere Advisory
Sanctions Intelligence | Advisory | Risk Assessment
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