EU: Update of the EU dual-use checklist for 2026
On 14 September 2026, the European Commission adopted a delegated regulation updating the EU dual-use checklist in Annex I to Regulation (EU) 2021/821. The amendment aligns EU rules with decisions taken in 2025 under international export control regimes, such as the Wassenaar Agreement, the Australia Group and the Nuclear Suppliers Group. The updated list introduces stricter controls on, among m.in, advanced semiconductor manufacturing and testing equipment, advanced computing integrated circuits (ICs) and digital processing units. From the perspective of compliance and international trade professionals, the new list requires an urgent review of internal procedures for verifying transactions and classifying exported goods. These changes are aimed at effectively controlling new technologies and protecting international security, while maintaining a level playing field for EU companies. The updated list will enter into force once it is published in the EU's Official Journal, at the end of the standard two-month scrutiny period by the Council and the European Parliament.
2026 Update of the EU Control List of Dual-Use Items
On 14 September 2026, the European Commission adopted a Delegated Regulation updating the EU dual-use export control list in Annex I of Regulation (EU) 2021/821. The update brings the list in line with decisions taken in the multilateral Export Control Regime’s Wassenaar Arrangement (WA), Australia Group (AG) and Nuclear Supplier Group (NSG) in 2025. The update also includes commitments that Member States have accepted as members of the Wassenaar Arrangement, to control additional items uniformly. The update ensures further effective EU-level controls of new technologies, thus contributing to security in the trade of dual-use items in line with the 2024 White Paper on Export Controls. Uniform EU-level controls guarantee effectiveness and transparency while maintaining the Union’s competitiveness and a level-playing-field for economic operators.
Specifically, this update of the EU control list provides for the addition of new dual-use items, including:
- Semiconductor manufacturing and testing equipment and materials (e.g. Atomic Layer Deposition equipment for molybdenum and Ruthenium, equipment for the development and the inspection of Extreme Ultra-Violet masks and reticles, and single wafer cleaning equipment);
- Advanced computing integrated circuits (ICs) and electronic assemblies such as ICs incorporating one or multiple Digital Processing Units;
- Ceramic Matric Composites (CMCs) reinforced with mullite, for high-temperature applications;
- Rotary encoders based on inductive sensing technology;
- Additive manufacturing equipment for energetic materials;
- Chemical Vapour Deposition equipment to produce silicon carbide (SiC) fibres;
- Technology for the development of axial compressors of gas turbine engines, and;
- Modification of certain control parameters and update of certain technical definitions and descriptions.
The updated EU control list enters into force upon publication in the Official Journal after the usual two-month scrutiny period for the Council and the European Parliament.
EU Sanctions Against Russia
Council Decision (CFSP) 2026/2103 of September 15, 2026, amending Decision 2014/145/CFSP, which extends the validity of the existing restrictive measures imposed in connection with the undermining of Ukraine’s territorial integrity and sovereignty until September 22, 2026. This short-term, technical extension of the legal framework is intended to provide the Council with additional time to conduct a comprehensive review and to ensure an orderly decision-making process without the risk of a regulatory gap. For companies in the electronics and ICT sectors, the continuation of the sanctions regime means that it remains absolutely necessary to block the supply of advanced technologies, semiconductors, and telecommunications equipment to entities linked to the Russian military-industrial complex. From the perspective of compliance specialists, this act imposes an obligation to maintain, at all times, end-user screening procedures, to continuously monitor EU lists of entities subject to asset freezes, and to audit counterparties in supply chains. For trade and international operations managers, this decision confirms the EU’s continued restrictive stance, requiring rigorous enforcement of sanctions clauses in foreign contracts and heightened vigilance against the risk of third countries circumventing the restrictions. This decision entered into force on September 15, 2026.
EU extends Burundi sanctions through October 2027
The European Union has extended its restrictive measures concerning Burundi by one year, preserving the existing sanctions framework through Oct. 31, 2027. The Council of the EU adopted Decision (CFSP) 2026/2197 after reviewing the measures established under Decision (CFSP) 2015/1763. The amendment replaces the previous Oct. 31, 2026, expiration date with Oct. 31, 2027. The renewal takes effect Sept. 30, the day after its publication in the Official Journal of the European Union. It maintains the measures rather than allowing them to expire at the end of October 2026. For sanctions compliance teams, the extension means screening and other controls tied to the Burundi regime remain relevant for another year. The decision does not provide changes to listed parties or identifying information; its stated amendment is limited to the framework’s end date.
Update on EU Sanctions Against Afghanistan – Tighter Verification Procedures
Council Implementing Regulation (EU) 2026/2138 of September 22, 2026, implementing amendments to Annex I to Regulation (EU) No. 753/2011 on restrictive measures in view of the situation in Afghanistan, has been published in the Official Journal of the EU. This act transposes the latest decisions of the UN Security Council Sanctions Committee and updates the detailed identifying information for 24 individuals (including high-ranking representatives of the Taliban regime and the Haqqani network) and one financial intermediary (Haji Khairullah Haji Sattar Money Exchange), including new passport numbers, identification numbers, aliases, and addresses. Although the regulation is of a political and security nature, it has key implications for the electronics and ICT sectors in terms of preventing the illegal transfer of dual-use technology, advanced communications equipment, navigation devices, and components that could be used to construct improvised explosive devices (IEDs). From the perspective of trade and international operations managers, the tightening of identification requirements calls for particular caution when conducting transactions in Central Asia and the Middle East (including re-exports via third countries such as the UAE or Pakistan) to rule out the risk of directly or indirectly supplying entities linked to the Taliban. For compliance departments, this publication constitutes a direct mandate to update internal lists in automated sanctions screening systems (Sanctions Screening) and to tighten customer and beneficial owner identification verification procedures (KYC/AML) within supply chains. The regulation entered into force on September 24, 2026; it is binding in its entirety and directly applicable in all EU member states.
Updates to the UN/EU sanctions lists targeting ISIL and Al-Qaeda
The Commission’s Implementing Regulation (EU) 2026/2143 of September 18, 2026, amending Annex I to Council Regulation (EC) No. 881/2002 imposing certain restrictive measures directed against persons and entities associated with ISIL (Daesh) and Al-Qaeda, has been published in the Official Journal of the EU. This amendment transposes into EU law the decision of the UN Security Council Sanctions Committee of September 4, 2026, clarifying the identifying information of two natural persons (including aliases, false identities, and Zambian identity documents associated with Abubakar Swalleh) subject to a mandatory freeze on funds and economic resources. For the electronics and ICT sectors, this announcement—despite its personal nature—is of significant importance in the area of controlling the trade in digital goods and services —in particular, networking equipment, encryption software, dual-use components, and cloud services, which may be targeted for illicit acquisition by terrorist entities (including IT experts linked to ISIL-K). From the perspective of compliance professionals, this act imposes an obligation to update algorithms and databases in systems for automated counterparty screening (Sanctions Screening) and end-user verification (End-User Screening). For trade and international operations managers, the tightening of identification requirements serves as a reminder of the absolute prohibition on directly or indirectly providing any technological or financial resources to entities listed on sanctions lists, under penalty of criminal and financial liability. The regulation entered into force on September 22, 2026; it is binding in its entirety and directly applicable in all EU member states.
Japan removes 16 Syrian entities from sanctions list
The Japanese government has approved the lifting of sanctions imposed on 16 organizations linked to Syria. The decision on Tuesday came after Tokyo lifted sanctions on four entities in May last year, leaving 59 individuals and 15 entities still subject to Syria-related sanctions. Japan began imposing sanctions in stages on the regime of then-Syrian President Bashar Assad in 2011, citing the regime’s suppression of antigovernment protests. Since the collapse of the Assad regime in 2024, Tokyo has eased its sanctions in light of steps taken by the new government of the Middle Eastern country.
UK sanctions
The UK Government has amended 1 entity designated under the Russia Sanctions Regime. The UK Government has amended the designations of 1 individual and 3 entities sanctioned under the Russia Sanctions Regime.
Amended Entities:
| Name: | Unique ID: |
| GLENBROOK CORPORATION LIMITED | RUS3245 |
| JOINT STOCK COMPANY TELEPORT BANK | RUS3714 |
| JSC ALTAY INSTRUMENT-MAKING PLANT ROTOR | RUS3490 |
Update of EU counter-terrorism sanctions: entries on ISIL/Al-Qaeda
Commission Implementing Regulation (EU) 2026/1965 of 25 August 2026 was published in the Official Journal of the EU, constituting the 360th amendment to Council Regulation (EC) No 881/2002 concerning restrictive measures directed against persons and entities associated with ISIL (Da'esh) and Al-Qaeda. The amendment implements the decision of the UN Security Council Sanctions Committee of 18 August 2026 and introduces updated identification data (including new aliases, passport numbers, identity cards, and revised addresses and link information) in 21 items of Annex I. For companies in the consumer electronics, components and ICT sectors, this act means an absolute need to update the reference databases in automatic counterparty verification systems (screening of sanctions lists). From the perspective of international trade and logistics, accurate data is crucial to prevent the inadvertent provision of economic resources, communication equipment, servers or dual-use components to entities subject to asset freezes. On the other hand, for compliance and financial audit departments, the regulation eliminates the risk of false positives and false negatives during transactional AML/CFT controls and verification of supply chains in high-risk regions. The Regulation enters into force on 28 August 2026, is binding in its entirety and is directly applicable in all EU Member States.
UK sanctions
Tuesday 29 September, the UK Government has amended 1 entity designated under the ISIL (Da’esh) and Al-Qaeda Sanctions Regime. This reflects an amendment made on 28 September by the UN Security Council Sanctions Committee pursuant to Resolutions 1267 (1999), 1989 (2011) and 2253 (2015).
Amended Entity:
| Name: | UN ID: | Unique ID: |
| Khatiba Jama’at Al-Tawhid Wal-Jihad (KTJ) | QDe.168 | AQD0377 |
Monday 21st September, the UK Government has revoked the specification of 1 ship sanctioned under the Russia Sanctions Regime.
Revoked Ship:
| Name: | IMO Number | Unique ID: |
| ASTRA | IMO 9273387 | RUS3003 |
UK sanctions
Friday 11 September, the UK Government varied the designation of one entity sanctioned under the Russia regime.
Entities varied:
| Name | Unique ID |
| S-MIKRON ELEKTRONIK | RUS3060 |
Ukraine: Switzerland adopts further EU sanctions against Belarus
On 18 September, the Federal Council decided to impose further sanctions on Belarus, aligning itself with the measures the European Union (EU) adopted against Belarus on 23 April. The changes will come into effect on 19 September.
UK sanctions
10 September, the UK Government varied the designation of one entity sanctioned under the Russia regime. Furthermore, one designation under the ISIL (Da'esh) and Al Qaeda sanctions regime and one designation under the Global Human Rights sanctions regime have been corrected.
New UK Iran sanctions regulations enter into force
The Iran (Sanctions) (Amendment) Regulations 2026 came into force on 29 September 2026, introducing a broad package of additional financial, trade and transport restrictions expanding controls across sectors including financial services, commodities, shipping and software. The measures follow the UK's implementation of the Iran sanctions "snapback" in 2025 and require businesses to perform a wider assessment of products, services, counterparties, supply chains and financial arrangements to ensure compliance.
What has changed?
The Regulations expand the UK's existing Iran sanctions regime and introduce new restrictions across a number of key sectors, extending controls over:
- gold, precious metals and diamonds;
- energy-related goods and technology;
- oil, petroleum products, natural gas and petrochemicals;
- specified categories of software and technology;
- financial services and trade-related services; and
- shipping and transport-related activities involving Iran.
The restrictions are not limited to the import or export of physical goods and depending on the relevant prohibition may also extend to connected services including technical assistance, financial services, brokering services and the transfer of technology. Equally the prohibitions may bite where no direct Iranian counterparty is involved and the relevant arrangements involve third-country intermediaries or other indirect connections to Iran. Businesses should therefore consider whether their compliance frameworks are capable of identifying indirect Iran-related exposure including through complex ownership and control structures, supply chains and intermediary counterparties. Vessels and aircraft connected with Iran are also subject to further restrictions, including strengthened Government powers to specify ships and prohibitions on certain activities involving vessels linked to sanctioned conduct. Separate restrictions also apply in relation to Iranian cargo aircraft.