Last Week's Major Developments in Sanctions - July 7, 2025, to July 11, 2025

---

You can now listen to the audio version of our weekly sanctions updates here.

---

Monday, July 7

• OFAC issued Venezuela-related General License 40D “Authorizing the Offloading of Liquefied Petroleum Gas in Venezuela”. The license authorizes the  delivery and offloading of liquefied petroleum gas in Venezuela, including deliveries to the Government of Venezuela and Petróleos de Venezuela, prior to September 5, 2025, provided the liquified petroleum gas was loaded on a vessel on or before July 7, 2025. (General License No. 40D)

• OFSI imposed asset freezing sanctions against two Russian individuals and one entity for their role in enabling, supporting, or promoting prohibited activities related to chemical weapons. Action taken under the Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/618). (Here) 

Tuesday, July 8

• OFAC announced a $1.5 M settlement with Harman International Industries. The company agreed to settle its potential civil liability for 11 apparent violations of OFAC sanctions on Iran enabled by Harman employees through its United Arab Emirates distributor. The settlement amount reflects OFAC's determination that the apparent violations were egregious and voluntarily self-disclosed. (Here, the Enforcement Release, and the Settlement Agreement)

• OFAC imposed blocking sanctions against Song Kum Hyok, a cyber actor associated with the sanctioned North Korean hacking group Andariel. Song facilitated an IT worker scheme in which individuals, often DPRK nationals working from countries such as China and Russia, were recruited and provided with falsified identities and nationalities to obtain employment at unwitting companies to generate revenue for the DPRK regime. Action taken pursuant of Executive Order 13694. In addition, blocking sanctions were imposed against four entities involved in the scheme. (Here, the Department of the Treasury press release, and the Department of State press release)   

• OFAC issued Russia-related General License 13N, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024." The license authorized U.S. persons or entities to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024. (General License 13N)

• Subsequently, OFAC published FAQ 999 and FAQ 1118 that provide guidance on General License 13N. (Here) 

Wednesday, July 9 

• The Secretary of State imposed blocking sanctions against Francesca Paola Albanese, the current UN Special Rapporteur on the Occupied Palestinian Territories. Sanctions imposed for Albanese's engagement with the International Criminal Court in efforts to investigate, arrest, detain, or prosecute nationals of the United States or Israel, without the consent of the two countries. Action taken pursuant of Executive Order 14203. (Here) 

• OFAC issued ICC-related General License 8, "Authorizing the Wind Down of Transactions Involving Francesca Paola Albanese." The license authorizes wind down transactions otherwise blocked until August 8, 2025. (General License No. 8)

• OFAC imposed blocking sanctions against 22 entities based in Hong Kong, the United States Emirates and Turkey for their roles in facilitating the sale of Iranian oil that benefits the Islamic Revolutionary Guard Corps-Qods Force, a designated Foreign Terrorist Organization. Action taken pursuant of Executive Order 13224 targeting Iran’s “shadow baking” infrastructure. (Here, the Department of the Treasury press release, and the Department of State press release)

• FinCEN extended the effective dates for orders issued on June 25, 2025 prohibiting certain transmittal of funds involving three Mexico-based financial institutions, CIBanco, Intercam, and Vector, by an additional 45 days. This extension reflects that the Government of Mexico has taken further steps to address the concerns raised in FinCEN’s orders, including by assuming temporary management of the affected institutions to promote regulatory compliance and the prevention of illicit finance. (Here) 

• The European Council imposed asset-freezing sanctions against the South-Sudanese Minister for Information and Broadcasting, Michael Makuei Lueth under Council Decision 2015/740. Sanctions imposed for his obstruction of the implementation of the Agreement on the Resolution of the Conflict in South Sudan and his involvement in the systematic curtailment of political and democratic space and in the repression of media. (Here)

• OFSI published guidance on a new exception which permits payments in respect to HM Treasury debt  to be made to or for the benefit of UN designated persons. (Here the Exception and the General Guidance)

• U.K. Revenue and Customs office published Notice to Exporters: NTE 2025/18 regarding the compound settlement with U.K. exporters which made goods available to Russia in breach of The Russia (Sanctions) (EU Exit) Regulations 2019. The settlement includes a £1.2 M settlement. (Here)

Thursday, July 10

• OFSI added FAQ 153 to its FAQ page that addresses how OFSI applies the term 'domiciled' in financial sanctions legislation. (Here)

• OFSI imposed asset freezing sanctions against two entities under the Haiti (Sanctions) Regulations 2022 (S.I. 2022/1281) following their designation by the UN as responsible for or complicit in, or having engaged in, directly or indirectly, actions that threaten the peace, security or stability of Haiti. (Here) 

Friday, July 11

• The founder and CEO of a Tehran-based engineering company who is a U.S. permanent resident was arrested and indicted on four-counts charging him with unlawfully exporting electronics used in railway signaling and telecommunications systems from the United States to Iran, in violation of the International Emergency Economic Powers Act and the Iranian Transactions and Sanctions Regulations. (Here)