Last Week's Major Developments in Sanctions - July 28, 2025, to August 1st, 2025
- Christopher Roth
- 6 days ago
- 4 min read
You can now listen to the audio version of our weekly sanctions updates here.
Monday, July 28
DOJ announced that Cadence Design Systems Inc. agreed to plead guilty to charges of criminal violations of export controls by selling electronic design automation hardware, software, and semiconductor design intellectual property technology to the Chinese National University of Defense Technology. In addition, the company entered a settlement agreement with BIS, in which it admitted to 56 violations of the EAR between September 2015 and September 2020. The total fine imposed on Cadence is $140 million of which $95 million is imposed by BIS and $45 million by DOJ. (Here's the BIS press release and the Department of Justice press release)Â
The European Council renewed asset freezing sanctions imposed to improve the political crisis in Lebanon in CFSP 2021/1277 until July 31, 2026. (Here)
Tuesday, July 29
BIS notified Andritz Inc., of its intention to initiate an administrative proceeding against the company pursuant to Section 766.3 of the Export Administration Regulations, through the issuance of a Proposed Charging Letter to Andritz Inc. that alleges Andritz Inc. committed 36 violations. Alleged violations occurred between May 2023 through February 2024 when Andritz Inc. exported refiner plates, valued at $3.1 million, to Andritz Fiedler. Andritz Fiedler then re-exported the refiner plates to Russia. (Here)
A Wisconsin-based business owner pleaded guilty in federal court to having willfully violated and evaded BIS export restrictions put in place in response to Russia’s invasion of Ukraine from September 2022 to October 2023. Through his company he exported scientific and diagnostic research equipment components to Russia without the required licenses, using transshipment points in third-party countries to conceal the ultimate destination. (Here)Â
The European Council imposed asset freezing sanctions against two entities based in Haiti. Both entities are criminal gangs that are responsible for violence committed against the civilian population. Action taken pursuant of CFSP 2022/2319 and after the entities were sanctioned by the United Nations Security Council Committee under UNSC Resolution 2653. (Here)
Wednesday, July 30Â
OFAC imposed blocking sanctions against Brazilian Supreme Federal Court justice Alexandre de Moraes for allegedly engaging in an oppressive campaign of censorship, arbitrary detentions that violate human rights, and politicized prosecutions. Sanctions imposed pursuant of Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse around the world. (Here, the Department of the Treasury press release, and the State Department press release)
OFAC imposed blocking sanctions against 50 individuals and entities and more than 50 vessels that are allegedly part of the vast shipping network controlled by Mohammad Hossein Shamkhani. The network transports oil and petroleum products from Iran and Russia, as well as other cargo, to buyers around the world, generating tens of billions of dollars in profit. Actions taken pursuant of Executive Order 13902, which targets those operating in certain sectors of the Iranian economy. (Here, and the Department of the Treasury press release)
Concurrently, the Department of State imposed blocking sanctions against 20 entities and identified 10 vessels as blocked property for their role in the trade of Iranian petroleum, petroleum products, or petrochemicals. Designation made pursuant of Executive Order 13846, which authorizes and reimposes certain sanctions with respect to Iran. (Here the State Department fact sheet and press release)
OFAC issued Iran General License R, “Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on July 30, 2025." The license authorizes transactions prohibited by Executive Order 13902 until October 1st, 2025 for safe docking and anchoring, preservation of crew health/safety, emergency repairs, delivery and offloading cargo. (Here and the General License)Â
The EU Council renewed the list of persons, groups and entities subject to restrictive measures with a view to combatting terrorism, delisting one deceased person and maintaining the rest unchanged. (Here, and press release)
Thursday, July 31
OFAC imposed blocking sanctions against one individual and five entities based in Iran, Hong Kong, Taiwan, and China for their procurement of technology in support of OFAC-designated Iran Aircraft Manufacturing Industrial Company (HESA). HESA is a state-owned subsidiary of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) that manufactures Iran’s military aircraft and Ababil‑series unmanned aerial vehicles, which have been employed by the Islamic Revolutionary Guard Corps (IRGC). Action taken in furtherance of National Security Presidential Memorandum 2, which directs that Iran be denied asymmetric and conventional weapons capabilities, and that the IRGC and its surrogates be disrupted and degraded. (Here, the Department of the Treasury press release, and the Department of State press release)
The United States imposed sanctions that deny visas to Palestine Liberation Organization (PLO) and Palestinian Authority (PA) officials in accordance with section 604(a)(1) of the Middle East Peace Commitments Act of 2002. Sanctioned behavior includes: initiating and supporting actions at international organizations that undermine and contradict prior commitments in support of Security Council Resolution 242 and 338, taking actions to internationalize its conflict with Israel such as through the International Criminal Court (ICC) and International Court of Justice (ICJ), continuing to support terrorism including incitement and glorification of violence (especially in textbooks), and providing payments and benefits in support of terrorism to Palestinian terrorists and their families. (Here)Â
OFSI issued a monetary penalty for a breach of UK financial sanctions against Russia in response to its annexation of Crimea. The penalty of £300,000 was imposed on Markom Management Limited for their instruction of a payment directly to a designated person subject to an asset freeze. (Here and the penalty notice)
Friday, August 1
There was no major development on this day.
Recommendation of the Week
It appears that Iran imported five B777 despite sanctions imposed by the United States on such imports. To see more check out this story: Iran imports five B777s via purported Malagasy start-up