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Last Two Weeks' Major Developments in Sanctions - July 14, 2025, to July 25, 2025

  • Writer: Christopher Roth
    Christopher Roth
  • Jul 30
  • 8 min read

Updated: Jul 30

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

(This week we cover the past two weeks, since we could not send last week's issue on time.)


Monday July 14

  • There was no major developments on this day.


Tuesday, July 15

  • OFAC announced a $11.8 M settlement with Interactive Brokers LLC. The company agreed to settle its potential civil liability violations arising from providing brokerage and investment services to persons in Iran, Cuba, Syria, and Crimea, processing trades in securities subject to the Chinese Military-Industrial Complex program, processing of transactions involving blocked persons, and engagement in new investment in Russia. The settlement amount reflects OFAC's determination that the apparent violations were non-egregious and voluntarily self-disclosed. (Here and the Enforcement Release)

  • The European Council imposed asset-freezing sanctions against:

    • Eight individuals and one entity linked to Iranian use of proxy agents, in particular involving criminals and organized crime networks targeting dissidents and human rights defenders across the world, including on Union territory. Action taken pursuant of Council Decision 2020/1999. (Here)

    • Five individuals for their role in human rights violations and repressions in Russia. Action taken pursuant of Council Decision 2024/1484. (Here)

    • Three individuals for their role in the deterioration of the political, economic, security and humanitarian situation in Haiti. Action taken pursuant of Council Decision 2022/2319. (Here) 

    • Seven individuals and three entities for committing activities to destabilize Moldova's security, stability, economy, and energy supply. Action taken pursuant of Council Decision 2023/891. (Here)

    • Nine individuals and six entities for their role in Russia’s continued hybrid campaign, including sabotage, disruption of critical infrastructure, cyber-attacks, information manipulation and interference, and attempts to undermine democracy, including in the electoral process in Union states. (Here)


Wednesday, July 16 

  • The European Council extended Council Decision 2022/2319, which addresses the deteriorating political, economic, humanitarian and security situation in Haiti until July 29, 2026. (Here)


Thursday, July 17

  • OFAC imposed blocking sanctions on the six individuals who are leaders and affiliates of Tren de Aragua, a Foreign Terrorist Organization originating in Venezuela as a prison gang that is now involved in extortion and bribery and threatens public safety throughout the Western Hemisphere through illicit drug trade, human smuggling and trafficking, extortion, sexual exploitation of women and children, and money laundering. Designation made pursuant of Executive Order 13581 and 13224. (Here, the Department of the Treasury press release, and the Department of State press release)


Friday, July 18

  • The European Council adopted its 18th sanctions package. (Here, and press release) If you want to know more, check out this alert put together by Nicolas Burnichon and his colleagues.

  • The European Council imposed asset freezing sanctions against two individuals and two entities for their involvement in the dramatic escalation of violence and the irreparable cost to human life in Darfur and throughout the Sudan, as well as violations of international human rights law and international humanitarian law. Action taken pursuant of Council Decision 2023/2135. (Here)

  • The UK, alongside the EU, lowered the Oil Price Cap on seaborne Russian crude oil from $60 to $47.60, reducing Russia’s income and ability to fund its war machine. The lowered Oil Price Cap of $47.60 per barrel comes into effect at 23:01 (BST), Tuesday, 2 September 2025. (Here the OFSI press release and the General License)

  • In addition, OFSI published FAQs 154 to 161 to support industry adaption to the lower price cap and explain the 45-day wind-down period. (Here the FAQ and the oil price gap guidance)

  • OFSI imposed asset freezing sanctions against 18 individuals and one entity under the Cyber Sanctions Regime for their responsibility for spreading chaos and disorder on Putin’s orders. (Here)

  • OFSI imposed asset freezing sanctions against three individuals and one entity involved in destabilizing Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine; or obtaining a benefit from or supporting the Government of Russia. Sanctions imposed under the Russia Sanctions Regime. (Here) 

  • OFSI issued General Licence INT/2025/6641960 under the Russia and the Belarus Regulations which allows non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker. This general licence only applies where the only designated party involved is the designated broker. (Here the General License)


Monday, July 21

  • A Lebanese national was sentenced to 44 months in prison for conspiring to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR), attempted unlawful export of goods from the United States to Iran without a license, attempted smuggling of goods from the United States, submitting false or misleading export information, and conspiracy to commit money laundering. (Here)

  • Two Mexican nationals were sentenced in federal court to 55 months each in prison for their roles in a two-year, multimillion-dollar trade-based money laundering conspiracy to move drug trafficking proceeds through Texas to Mexico. (Here)

  • FinCEN announced delaying the effective date and revisiting the scope of the Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule). The effective date is pushed back from January 1, 2026, until January 1, 2028. (Here, and the IA AML Rule)

  • The European Council imposed asset freezing sanctions against one individual under CFSP 2017/1775 concerning restrictive measures in view of the situation in Mali for their role and complicity, in actions or policies that threaten the peace, security or stability of Mali, or that obstruct or undermine the successful completion of Mali’s political transition. (Here)

  • OFSI published its Cryptoassets Threat Assessment Report that identifies key evasion threats, red flags that businesses should be aware of, and guidance on areas where compliance could be strengthened. (Here)

  • OFSI published INT/2025/6403704 that allows for the continuation of business operations of vessels owned or operated by, or on behalf of, the Government of Gabon. (Here) 

  • OFSI imposed asset freezing sanctions against two individuals and 135 vessels under the Russia (Sanctions) (EU Exit) Regulations 2019. The sanctions target Russia’s critical energy and oil sectors and aim to disrupt the flow of oil money into Russia’s war chest and strand more of its shadow fleet. (Here and the Office of Foreign Affairs press release) 

  • OFSI published General Licence INT/2025/6488808, Wind Down of Positions Involving Litasco Middle East DMCC. The General Licence allows for persons to wind down from any transactions involving the Designated Person to which that person is a party. (Here) 

  • OFSI published General Licence INT/2025/6397444, Intershipping Services LLC Wind-down. The General Licence allows for Persons to wind down from any transactions involving the Designated Person to which that Person is a party. (Here)

  • The U.K. Department for Business and Trade has updated F680 approval for classified and unclassified international traffic in arms regulations (ITAR) material. (Here) 

  • The Export Control Joint Unit published the general trade licence Russia sanctions – sectoral software and technology. The general licence permits the transfer of technology of business enterprise software and technology, the making available of business enterprise software and technology and ancillary services relating to business enterprise software and technology prohibited by Chapter 4N of the Russia (Sanctions) (EU Exit) Regulations 2019. (Here)


Tuesday, July 22

  • OFAC imposed blocking sanctions against two individuals and five entities located across Yemen and the United Arab Emirates. Sanctioned individuals and entities are involved in money laundering and petroleum smuggling into territory controlled by the Houthis. The Houthis gain hundreds of millions of dollars annually by working with Yemeni businessmen to tax petroleum imports, generating critical revenue that funds the Houthis’ destabilizing activities in the region. Sanctions imposed pursuant of Executive Order 13224. (Here, the Department of the Treasury press release, and the Department of State press release)

  • The Justice Department and the U.S. Attorney’s Office for the District of Columbia unsealed a civil forfeiture action against approximately $2 million dollars in digital currency connected with Buy Cash Money and Money Transfer Company, a Gaza-based money transfer business that was involved in financially supporting Hamas. (Here) 

  • OFSI launched a consultation to seek opinions on proposed changes to its enforcement policies and processes. The identified revisions to its enforcement processes could enable it to resolve cases more efficiently, improving the delivery of public enforcement actions and reducing burdens on OFSI and on subject firms or individuals. Consultations close by end of day October 13, 2025. (Here)


Wednesday, July 23 

  • The European Commission amended 17 FAQs on its asset freezing sanctions on Russia and Belarus. FAQs focus on imports, purchase and transfer of listed goods (Here) and enhanced due diligence for operators manufacturing and/or trading with CHP items (Here). 

  • OFSI amended General Licenses INT/2025/5632740, that addresses Interim Basic Necessities for Designated Persons, and INT/2022/1679676, that addressed Law Enforcement and Regulatory Authorities Asset Recovery, to include the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025. The Regulations provide for the imposition of financial sanctions, namely the freezing of funds and economic resources of persons who are or have been involved in people smuggling, human trafficking or the instrumentalisation of migration. (Here) 

  • OFSI General Guidance was updated to include Designated Money Service Businesses in section 6.6 for OFSI's approach to licensing grounds. (Here) 

  • OFSI imposed asset freezing sanctions against five individuals and 20 entities under the Global Irregular Migration sanctions regime for their role in people-smuggling networks that drive irregular migration to the U.K. (Here and the Office of Foreign Affairs press release) 



Thursday, July 24

  • OFAC imposed blocking sanctions against three individuals and one entity - Korea Sobaeksu Trading Company -  for their role in North Korea's fraudulent information technology worker scheme. The North Korean regime dispatches teams of highly skilled IT workers around the world in order to generate revenue in violation of U.S. and UN sanctions. The teams of IT workers typically use fraudulent documents, stolen identities, and false personas to obfuscate their identities and infiltrate legitimate companies, including those in the United States and allied jurisdictions. The regime withholds most of the wages earned by these workers to finance itself. (Here, Department of the Treasury press release, and the Department of State press release)

  • The Department of Justice unsealed indictments against seven North Korean individuals for sanction evasion that violates the International Emergency Economic Powers Act involving the illicit trafficking of counterfeit cigarettes. In addition, the Department of State announced a reward offer totaling up to $15 M under the Transnational Organized Crime Rewards Program for information leading to these individuals’ arrest and/or conviction. (Here)

  • An Arizona woman was sentenced to 102 months in prison for her role in facilitating the fraudulent North Korean information technology worker scheme. (Here)


Friday, July 25

  • OFAC sanctioned the Cartel de los Soles, a.k.a. Cartel of the Suns as a Specially Designated Global Terrorist. The cartel is a Venezuela-based criminal group headed by Venezuelan president Nicolas Maduro Moros and other high-ranking government officials. It provides material support to foreign terrorist organizations threatening the peace and security of the United States, namely Tren de Aragua and the Sinaloa Cartel. Action taken pursuant of Executive Order 13224. (Here, and the Department of the Treasury press release)

  • The European Council extended asset freezing sanctions imposed under CFSP 2023/1532 imposed in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region until July 27, 2026. (Here) 



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