Trump’s sanctions concessions to Russia and Iran

Russian oil sales authorised, dollar payments permitted for Iran, exemptions negotiated by Washington’s partners: decisions by the Trump administration have opened several gaps in US sanctions. Some remain in force. Others closed within weeks. Treasury licences show their legal reach, but they do not tell us how much money was ultimately received.

Document review completed on 6 September 2026. Period covered: Donald Trump’s second term, from 20 January 2025.

The pivotal passage occupies three lines on the second page of a US Treasury document. In June 2026, Washington authorised dollar settlement for certain purchases of Iranian oil and petrochemicals, including payments owed to Tehran’s government or a blocked person. The licence was called X. Dated 21 June and published the following day, it was meant to run through 21 August. A second licence revoked it on 7 July. Little more than two weeks separated the commercial opening from its withdrawal. OFAC, General License X. OFAC, 22 June publication. OFAC, General License X1.

The Russian concessions have a different geography. A nuclear plant in Hungary, refineries in Germany, an oil company in Serbia and petrol stations abroad all reflect the energy dependencies of countries trading with Moscow. Their governments or companies secured permission to continue operations that sanctions would otherwise have obstructed. Several authorisations remained valid in early September 2026. OFAC, General License 132. OFAC, General License 129A. OFAC, General License 128C. NIS, 28 August statement.

These are two different patterns. Russia has received targeted exemptions, some with no stated expiry date. Iran briefly obtained a much wider oil and payment opening in June than the limited relief granted in March. Oil-market pressure helps explain some decisions; diplomacy and the protection of foreign energy supplies explain others. The licences alone cannot quantify any additional revenue for Moscow or Tehran.

Maximum pressure meets an oil shortage

The Trump administration also tightened sanctions on both countries. On 4 February 2025, the president signed the memorandum restoring “maximum pressure” on Iran, including an instruction to drive Iranian oil exports to zero. On 20 March, Treasury sanctioned the Chinese independent refiner Luqing Petrochemical, accusing it of buying Iranian crude. The foreign customer had itself become a target of US pressure. White House, Iran memorandum. Treasury, Luqing Petrochemical.

Washington sanctioned Rosneft and Lukoil on 22 October 2025. Both groups were designated under Executive Order 14024, with restrictions extending under OFAC’s 50 Percent Rule to companies they own by at least half. The decision targeted companies at the centre of Russia’s oil economy. Trump’s second term therefore cannot be reduced to the dismantling of sanctions inherited from Joe Biden. Treasury, Rosneft and Lukoil.

Then the war with Iran changed oil availability. In its report published on 14 April 2026, the International Energy Agency estimated that global supply had fallen by 10.1 million barrels per day in March from February. Attacks on infrastructure and restrictions through the Strait of Hormuz curtailed supply. This was an April estimate for March, not a measure of conditions in September. It establishes the scale of the shock to which Washington was responding. IEA, April 2026 Oil Market Report.

Reuters reported that the administration presented the Russian and Iranian exemptions issued in March as measures to ease the market. The trade-off had shifted: cutting an adversary’s revenue remained the objective, but keeping available cargoes outside legitimate trade imposed costs on consumers and US partners. Reuters, Russian-oil exemption. Reuters, Iranian-oil exemption.

General licences issued by OFAC, Treasury’s sanctions-enforcement office, make those adjustments possible. Each authorises a category of transactions defined by a product, participant, destination or date. A company may remain sanctioned while part of its business is permitted. Unloading a cargo, producing new oil, making a payment and removing a name from a sanctions list are distinct acts. OFAC, Russia programme. OFAC, Iran programme.

India wins relief, then Russian oil gets a wider opening

The sequence concerning India shows how quickly policy changed. In August 2025, Trump imposed an additional 25% tariff on Indian goods because of the country’s Russian-oil purchases. An order signed on 6 February 2026 removed the penalty from 7 February. The president said New Delhi had committed to stop importing Russian oil and to buy US energy. The order provided for monitoring and the possible reinstatement of the tariff. Presidential order of 6 February 2026.

Washington presented that trade concession as the result of pressure on a Russian outlet. The order records an Indian commitment; it does not show that imports had stopped. Less than a month later, allowing some of those purchases had become the priority.

On 5 March, General License 133 authorised transactions involving Russian crude or petroleum-product cargoes already loaded by the cut-off stated in the document. The buyer had to be established in India and unloading had to occur at an Indian port. Necessary services and transactions involving certain blocked vessels were also covered. The licence expired on 4 April. OFAC, General License 133.

General License 134 widened the scheme on 12 March by removing the India-only restriction. Cargoes had to have been loaded by 12:01 a.m. Eastern Time that day, and transactions were authorised through 11 April at the same time. Access to maritime services mattered as much as permission to sell: a tradeable cargo still required an insurer, carrier, port and intermediaries willing to handle it. OFAC, General License 134.

Later versions granted new windows, with interruptions. General License 134B was issued on 17 April, moved the loading cut-off to that date and expired on 16 May. General License 134C, issued on 18 May, retained that loading cut-off and allowed transactions through 17 June. The public texts do not describe a continuous spring authorisation: there was a gap from 11 to 17 April and another from 16 to 18 May. OFAC, General License 134B. OFAC, General License 134C.

The legal benefit to Russian trade was tangible: sales and services that would otherwise have been prohibited became possible. Its scope remained confined to cargoes meeting a loading condition. By 6 September, the last of these licences appeared in OFAC’s official archive of expired authorisations. This review found no later equivalent general licence supporting a claim that the spring opening was still in force. OFAC, revoked and expired licence archive.

Iran moves from cargoes at sea to production and dollars

Iran’s first 2026 exemption resembled the Russian scheme. General License U, issued on 20 March, authorised for 30 days certain sales, deliveries and unloading operations involving Iranian crude and petroleum products already loaded. It covered necessary services and blocked vessels designated under the sanctions programmes it listed. It expired at 12:01 a.m. Eastern Time on 19 April. The text did not grant a general right to produce additional oil. OFAC, General License U.

Reuters reported Scott Bessent’s estimate that about 140 million barrels could be returned to the market. It was an estimate announced by the Treasury secretary, not a record of completed deliveries, extra Iranian production or revenue repatriated to Iran. A cargo already at sea may have been sold earlier, redirected or sold on better terms because of the relief. Those outcomes have different consequences for Tehran’s revenue. Reuters, Iranian-oil exemption.

The June opening went further. General License X covered the production, sale, delivery and unloading of Iranian crude, petroleum products and petrochemicals. It was no longer limited to cargoes loaded by an earlier date. It also authorised their import into the United States, subject to the licence’s conditions. That legal possibility is not evidence that a shipment reached a US port. OFAC, General License X.

The dollar clause added a financial dimension. It permitted payments for covered purchases to be denominated in US dollars even when owed to Iran, its government or a blocked person. In an analysis published on 23 June, Holland & Knight noted that the licence did not expressly require those proceeds to enter a blocked or escrow account. The concession therefore affected the terms of settlement, not merely permission to move a cargo. Holland & Knight, analysis of X.

Iran did not regain general access to the US banking system. Prohibitions under sanctions programmes outside the licence remained in force, including those involving foreign terrorist organisations. Holland & Knight also noted that X did not generally unblock property already frozen. Permission for certain dollar transactions and access to any Iranian asset remained separate questions. Holland & Knight, analysis of X.

Banks still had to decide whether to participate. Norton Rose Fulbright highlighted the operational barriers: residual banking restrictions, anti-money-laundering controls, uncertainty over counterparties and the short life of the licence. A transaction can fall within a licence without every bank that might finance or settle it being willing to proceed. Norton Rose Fulbright, analysis and revocation of X.

The opening accompanied US-Iran negotiations in June. Treasury supplied an immediately usable commercial channel while talks continued. For Tehran, it was relief in a sector Trump had pledged to deprive of outlets. Its economic value nevertheless depended on transactions being agreed, executed and paid before the next policy change.

Washington withdraws the Iranian authorisation on 7 July

X was scheduled to run through 21 August. X1 revoked it on 7 July and allowed only the wind-down of transactions previously authorised, through 12:01 a.m. Eastern Time on 17 July. New purchases or loading were no longer covered except as necessary to complete that wind-down. OFAC, General License X1.

The payment treatment also tightened. During the wind-down, any amount owed to a blocked person had to be paid into a blocked, interest-bearing account in the United States. The funds could enter the account without becoming freely available to the sanctioned beneficiary. The difference from the June opening appears in the terms of the licence itself. OFAC, General License X1.

The chronology rules out treating the planned August expiry as though it had been reached. Reporting at the time of the announcement could describe a 60-day window; a September review has to record its early termination.

That reversal also matters commercially. A buyer, bank or shipowner may spend much of a short licence window preparing a transaction. X establishes a substantial concession in principle, but its brief life limits what can be inferred about the transactions that benefited.

Frozen Iranian assets are a separate file

Announcements about Iranian funds held abroad accompanied the sanctions talks. They cannot be added to the oil proceeds authorised under X as if they were one transfer.

In a CNBC interview on 24 June, Scott Bessent said Treasury would oversee the use of Iranian funds after their release and that a significant share should finance US food and medicine. He referred to a mechanism in Qatar but did not state either the amount to be released or every control. CNBC also reported the Iranian officials’ opposing view that Washington did not get to decide how Iran used its assets. CNBC, Bessent interview.

Qatar’s foreign ministry supplied firmer detail on 30 June. Its spokesperson tied the funds to the 2023 humanitarian arrangement between the United States and Iran. Qatar administers the accounts as a financial intermediary; it does not own the money. Any transfer depended on agreement between the parties and progress in negotiations, conditions that had not yet been met, the ministry said. Qatar Ministry of Foreign Affairs.

That statement establishes the position on 30 June, not every later bank movement. Research through 6 September found no sufficiently strong public confirmation of an amount transferred under the June announcements. What is documented is a prospective route to the funds and announced conditions; the financial outcome remains unverified.

The publicly described escrow arrangements for older assets must not be read backwards into General License X, which contained no such express requirement. Conversely, permission for certain dollar-denominated oil payments does not show that already frozen Iranian accounts were released. Conflating the two files can both exaggerate the sums returned to Tehran and understate the breadth of the June commercial opening.

Hungary protects its energy ties with Russia

The most durable Russian exemptions often emerge from Washington’s negotiations with other capitals. Viktor Orbán’s White House visit on 7 November 2025 provides a clear example. A US official cited by Reuters said Hungary received a one-year exemption for purchases of Russian oil and gas. Trump publicly cited the supply constraints facing a landlocked country. The official also described Hungarian commitments to buy US liquefied natural gas under contracts worth about $600 million. The exemption therefore came with commercial prospects for US suppliers. Reuters, Trump-Orbán meeting.

Budapest nevertheless described the exemption as unlimited. The BBC reported the disagreement with the one-year duration stated by the US side. The text of this specific authorisation was not obtained for this investigation, so its detailed conditions cannot be reconstructed from political statements alone. The one-year term remains information attributed to the White House, not a clause checked in a public licence. BBC, duration of the Hungarian exemption.

A second Hungarian case has a public text. On 21 November 2025, OFAC issued General License 132 for the Paks II nuclear-power project being built by Rosatom. It authorises certain project-related transactions involving Gazprombank, Sberbank, VTB, other designated institutions and Russia’s central bank. It contains no expiry date. OFAC, General License 132. Reuters, Paks correction.

The exemption protects the financing and operation of one project. Restrictions remain on correspondent accounts and debits from Russian sovereign assets at US banks. The named banks therefore do not regain freedom to act for all customers. Yet a licence without an expiry date is materially different from a short period to finish unloading a cargo. OFAC, General License 132.

Foreign refineries remain in operation

In Germany, General License 129A of 5 March 2026 authorises transactions with Rosneft Deutschland, RN Refining & Marketing and subsidiaries owned by them by at least 50%, with no stated expiry. Other blocked entities in the Russian group remain outside its scope unless separately authorised. Reuters notes that the German entities had been under state trusteeship since 2022. OFAC, General License 129A. Reuters, Rosneft Germany.

Keeping those assets operating can preserve their value. It does not establish that earnings can be transferred freely to Moscow. Trusteeship, financial restrictions and ownership must be examined separately. The immediate, documentable effect is that the German entities can continue necessary transactions despite sanctions on their parent.

Serbia announced another extension on 28 August 2026. NIS said it had received a specific licence allowing it to operate through 30 September, including refining, crude imports, contracts, maintenance and financial settlements. Reuters also reported the Serbian energy minister’s announcement and placed the extension in negotiations to sell the Russian majority stake to Hungary’s MOL. NIS, 28 August statement. Reuters, NIS licence.

The full text of this specific licence was not public among the documents obtained. Its scope is described by the beneficiary and Serbian officials, whose statements Reuters reported. Continuing sale negotiations did not prove that a transaction had closed. The immediate effect was additional operating time for the company running Serbia’s only refinery.

Other licences protect energy chains tied to Russian partners. General License 124B covers operation of the Caspian Pipeline Consortium, Tengizchevroil and Karachaganak, including certain dealings involving Rosneft or Lukoil, but not sales of project stakes. General Licences 55F and 115D, renewed in June, preserve certain Sakhalin-2 operations and bank transactions for older civil-nuclear projects. They extend pre-existing arrangements; Trump did not create their whole architecture. OFAC, General License 124B. OFAC, General License 55F. OFAC, General License 115D.

The general licences above expire at 12:01 a.m. US Eastern Time on the stated date; they do not cover the whole day. That timing has not been confirmed for the NIS specific licence. A licence with no stated expiry can still be amended or revoked.

Lukoil gets time, with restrictions on the money

Lukoil shows why every exemption cannot be reduced to a financial gift to the Kremlin. General License 131I, issued on 20 August 2026, authorised through 19 September negotiations and conditional contracts involving Lukoil International, the holding structure for foreign assets. It also permitted maintenance or wind-down of certain operations. A completed sale required separate OFAC approval, and transfers of funds to a person or account in Russia were prohibited. OFAC, General License 131I.

In guidance updated on 20 August, OFAC listed minimum conditions it would consider for a sale. Lukoil International had to sever all ties with Lukoil. Amounts owed to the Russian group had to remain blocked in a US-jurisdiction account until sanctions were lifted. The structure could not give Lukoil immediately available value through an asset or share exchange. OFAC, conditions for selling Lukoil International.

The window prevented an immediate shutdown and gave possible buyers time. It could also reduce value destruction. At the same time, Treasury’s stated conditions sought to prevent the Russian parent from converting the asset into usable cash. Negotiating a sale and receiving its price are not the same event.

Compared with the June Iranian licence, the difference is instructive. X permitted some dollar oil payments without itself requiring escrow. The stated conditions for a Lukoil International sale expressly blocked amounts owed to the group. That does not place every Russian and Iranian measure on a single scale of leniency; it shows why the payment destination is essential to evaluating each concession.

KleptoCapture disappears, prosecutions continue

Part of the Russian policy change involved the organisation of US enforcement. On 5 February 2025, Attorney General Pam Bondi ordered the dissolution of Task Force KleptoCapture, the Kleptocracy Team and the Kleptocracy Asset Recovery Initiative. Lawyers were to return to previous posts and resources were redirected towards cartels and transnational crime. Justice Department, Bondi memorandum.

KleptoCapture had been created in March 2022 to coordinate enforcement of measures imposed after Russia’s invasion of Ukraine. Removing a specialist structure signalled a change in institutional priorities. It does not reveal how many investigations were abandoned or what assets consequently escaped seizure. Justice Department, creation of KleptoCapture.

One prosecution cautions against going further than the record. On 18 August 2025, the Justice Department announced that Vadim Yermolenko had been sentenced to 30 months in prison for his role in a procurement network supplying ammunition and dual-use electronic components to Russian services. He had pleaded guilty in November 2024. The case, begun before Trump’s return, continued after KleptoCapture was dissolved. Export restrictions, financial offences and every Russia-related prosecution did not disappear with the reorganisation. Justice Department, Yermolenko sentence.

There were also individual removals. OFAC removed Mikhail Zadornov from the sanctions list on 3 April 2026; Reuters reported Washington’s description of the decision as the result of an ordinary delisting process. DuLac Capital was removed on 3 September without a detailed reason in the public notice. The delistings are verifiable. Attributing them to personal intervention by Trump for Putin’s benefit would require additional evidence. OFAC, Zadornov removal. Reuters, Zadornov petition. OFAC, DuLac Capital removal.

Diplomatic commitments did not all become exemptions

After Black Sea talks in Riyadh, the White House said on 25 March 2025 that the United States would help restore Russia’s access to agricultural and fertiliser markets, lower maritime-insurance costs, and improve access to ports and payment systems for those transactions. Washington had agreed to work on economic obstacles raised by Moscow. The statement was not itself an executable banking authorisation and did not reconnect Russian banks generally to SWIFT. White House, Black Sea outcomes.

Washington also declined to join the lower Russian-oil price cap adopted by the United Kingdom and European Union in July 2025, according to a House of Commons Library briefing. This was a tightening in which the United States did not participate, not the repeal of an existing US measure. House of Commons Library, Russia sanctions. UK government, oil-price cap.

Statements on Iran require the same distinction. Trump suggested in June 2025 that China could continue to buy Iranian oil. Reuters then reported the White House clarification that his words did not amount to a formal lifting of sanctions. Rhetoric can change buyers’ expectations; it does not have the legal force of a Treasury licence. Reuters, Trump’s Iran-oil remarks.

Chabahar, by contrast, was an identified exemption. India’s foreign ministry confirmed on 30 October 2025 that Washington had granted a six-month waiver for Indian activity at the Iranian port. In early September 2026, CNBC-TV18 reported that it had expired on 26 April and that New Delhi was seeking a way to preserve the project; the quoted Indian statements were dated 31 August. This review found no publicly confirmed renewal. Indian Ministry of External Affairs. CNBC-TV18, Chabahar.

Chabahar shows that Iran, too, can obtain an exemption tied to a third country’s interests. India wants access to Afghanistan and Central Asia without crossing Pakistan. The logic resembles some Russian exemptions, but it does not guarantee the same duration or tolerance from Washington.

By September, Iran faces renewed tightening

By the end of the period reviewed, the June oil opening had closed. On 24 August, Treasury launched Operation Economic Outcast, with new designations and several broader sectoral bases for sanctioning foreign actors linked to Iran’s economy. It also suspended certain licences involving personal remittances, and academic and cultural exchanges. General License BB only allowed affected transactions to wind down through 12:01 a.m. Eastern Time on 8 September. Treasury, 24 August campaign. OFAC, General License BB.

On 4 September, OFAC added Turkey’s Golden Global Bank and two subsidiaries to its sanctions list. Treasury accused them of facilitating Iran-related financial activity; Reuters reported the bank’s rejection of the allegations. The designation is an effective administrative act. Washington’s stated grounds remain allegations, distinct from a judicial finding. OFAC, 4 September designations. Treasury, Golden Global Bank. Reuters, Golden Global Bank response.

Our analysis of how far Bessent can still close the dollar to Iran separates the new legal grounds announced on 24 August, the designations already in effect and the systemic risk of pressure on partner-country banks.

On 6 September, several exemptions involving Russian projects and foreign assets continued to soften sanctions, some without stated expiry dates. Some preserved commercial outlets or financial operations; others maintained activity while trying to prevent a Russian owner from receiving sale proceeds. In Iran’s case, Washington had already withdrawn the June oil and payment opening before beginning a new tightening. Both countries received concessions, but the current position and the authorised transactions differ.

The record reveals the constraint that energy markets and partner-country supplies place on US policy. Economically isolating Russia and Iran shifts costs onto buyers, refiners and banks elsewhere. Exemptions appear where the administration chooses to limit or negotiate those costs. Measuring their financial effect now requires tracking cargoes, accounts and contracts: the licences establish what became legally possible, not the final amount reaching Moscow or Tehran.

Sources

This review relies on public OFAC licences and notices, presidential acts, US Justice Department documents and official statements from the governments concerned. Reuters, the BBC and CNBC add context and record conflicting accounts. The IEA report supplies a dated estimate of oil supply. Holland & Knight and Norton Rose Fulbright are used to cross-check the reach of the Iranian authorisations.

View the 54 cited documents

• NSPM-2: restoring maximum pressure on Iran. White House; 4 February 2025.
• Sanctions on Rosneft and Lukoil. US Treasury; 22 October 2025.
• Total Elimination of Cartels and Transnational Criminal Organizations. US Justice Department; 5 February 2025.
• Outcomes of US-Russia Black Sea talks. White House; 25 March 2025; talks held 23-25 March.
• Sanctions against Russia: What has changed since January 2025?. House of Commons Library, Claire Mills; 3 August 2026.
• Lower oil-price cap adopted by the UK and EU. UK government; 18 July 2025.
• Russia General License 132 · Paks II. OFAC; 21 November 2025.
• Russia General License 55F · Sakhalin-2. OFAC; 11 June 2026; expiry 18 December 2026 at 12:01 a.m. EST.
• Russia General License 115D · civil nuclear. OFAC; 11 June 2026; expiry 18 December 2026 at 12:01 a.m. EST.
• Russia General License 129A · Rosneft Germany. OFAC; 5 March 2026.
• Russia General License 124B · Caspian projects. OFAC; 14 November 2025.
• Russia General License 128C · Lukoil petrol stations outside Russia. OFAC; 14 April 2026; expiry 29 October 2026 at 12:01 a.m. EDT.
• Russia General License 130A · Lukoil in Bulgaria. OFAC; 14 April 2026; expiry 29 October 2026 at 12:01 a.m. EDT.
• Russia General License 131I · Lukoil International sale. OFAC; 20 August 2026; expiry 19 September 2026 at 12:01 a.m. EDT.
• FAQ 1224 · conditions for a sale of Lukoil International. OFAC; 19 November 2025; updated 20 August 2026.
• Russia General License 133 · cargoes bound for India. OFAC; 5 March 2026.
• Russia General License 134 · wider oil window. OFAC; 12 March 2026.
• Russia General License 134B · new loading date. OFAC; 17 April 2026.
• Russia General License 134C · last extension located. OFAC; 18 May 2026.
• Archive of revoked and expired licences. OFAC; evolving page checked 6 September 2026.
• Waiver for Russian oil already at sea. Reuters; 12 March 2026; updated 13 March.
• 30-day waiver for Iranian oil already at sea. Reuters; 20 March 2026; updated 21 March.
• Iran General License U · oil already loaded. OFAC; 20 March 2026.
• Iran General License X · oil production and sales. OFAC; dated 21 June 2026 according to X1; published 22 June.
• Iran General License X announcement. OFAC; 22 June 2026.
• Iran General License X1 · revocation and wind-down. OFAC; 7 July 2026; wind-down through 17 July at 12:01 a.m. EDT.
• Bessent describes oversight of Iranian funds to be released. CNBC, Squawk Box interview; 24 June 2026.
• Qatar’s update on negotiations and Iranian assets. Qatar Ministry of Foreign Affairs; 30 June 2026.
• Trump suggests easing enforcement of Iran oil sanctions. Reuters, Jeff Mason; 25 June 2025.
• India confirms a six-month Chabahar exemption. Indian Ministry of External Affairs; 30 October 2025.
• India seeks a way to keep the Chabahar project. CNBC-TV18; 1 September 2026; statements dated 31 August.
• Launch of Operation Economic Outcast. US Treasury; 24 August 2026.
• Golden Global Bank and subsidiary designations. OFAC; 4 September 2026.
• US grounds for sanctions on Golden Global Bank. US Treasury; 4 September 2026.
• Mikhail Zadornov removed from the SDN List. OFAC; 3 April 2026.
• Zadornov: ordinary delisting, Washington says. Reuters, Andrea Shalal; 3 April 2026.
• DuLac Capital and related entries removed. OFAC; 3 September 2026.
• Sanctions on a Chinese refinery buying Iranian oil. US Treasury; 20 March 2025.
• Paks II licence and correction on the US nuclear contract. Reuters; 21 November 2025; later corrected.
• Legal reading of Iran General License X. Holland & Knight; 23 June 2026.
• Revocation of Iran General License X. Norton Rose Fulbright; initial analysis 23 June, updated after 7 July 2026.
• Open-ended exemption for Rosneft Germany. Reuters; 5 March 2026.
• Hungarian exemption lasts one year, White House says. BBC; 8 November 2025.
• Russia sanctions programme: licences and legal framework. OFAC; evolving page checked 6 September 2026.
• Iran sanctions programme: licences and legal framework. OFAC; evolving page checked 6 September 2026.
• Executive Order 14384 · removal of additional India tariff. US presidency/GovInfo; signed 6 February 2026; effective 7 February; Federal Register 11 February.
• NIS specific licence extension. NIS; 28 August 2026.
• Serbia obtains another NIS extension. Reuters, Aleksandar Vasovic and Angeliki Koutantou; Euronext republication; 28 August 2026.
• Oil Market Report · April 2026. International Energy Agency; 14 April 2026; estimate for March 2026.
• Vadim Yermolenko sentenced. US Justice Department; 18 August 2025; page updated 15 September 2025.
• Iran General License BB · wind-down after suspension of certain authorisations. OFAC; 24 August 2026.
• Turkish bank sanctioned and allegations contested. Reuters, Ismail Shakil, David Lawder and Andrea Shalal; 4 September 2026.
• Hungarian exemption after the Trump-Orbán meeting. Reuters, republished by CNBC; 7 November 2025 US time; updated 8 November.
• Creation of Task Force KleptoCapture. US Justice Department; 2 March 2022; page updated 6 February 2025.

Limitations

Signed texts and their replacement clauses take precedence over reports written at announcement time or older directory titles. The Hungarian and Serbian specific licences are identified as such because their full texts were not obtained. This article does not claim to inventory every designation or quantify an economic gain without transaction data. It is a review of public documents; no unpublished interview or confidential banking record is presented as having been obtained. The links in the article and the source list provide the underlying material.