Last Week's Major Developments in Sanctions - April 14th, 2025, to April 18th, 2025

The EU Council imposed asset-freezing sanctions against seven individuals and two entities in Iran responsible for serious human rights violations. (Decision, and press release)
FinCEN announced the renewal of its Geographic Targeting Order (GTO) that requires U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate. The terms of the GTO are effective beginning April 15, 2025, and ending on October 9, 2025. (Here)
OFSI imposed asset-freezing sanctions against one individual and one entity for their human rights violations in Iran under the Sanctions and Anti-Money Laundering Act. (Here, and press release)

OFAC imposed blocking sanctions on four individuals affiliated with La Nueva Familia Michoacana (LNFM), a Mexican cartel, under its illicit drugs and counter-terrorism sanctions programs for smuggling illicit drugs and aliens into the United States and for violence committed against its rivals and Mexican security forces. (Here, and the Department of the Treasury press release)
The EU Council announced that Albania, Bosnia and Herzegovina, Iceland, Liechtenstein, Montenegro, North Macedonia, Norway, and Ukraine aligned themselves with Decision 2012/642/CFSP on asset-freezing sanctions against five individuals and seven entities for the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine. (Press release)
ECJU updated its open general export licence NTE 2025/09 for oil and gas exploration dual use items to permit exports to the continental shelf of coastal destinations which are themselves included as permitted destinations. (Here)

OFAC imposed blocking sanctions against a China-based independent “teapot” refinery for purchasing more than a billion dollars’ worth of Iranian crude oil, and six companies and five vessels for facilitating Iranian oil shipments to China as part of Iran’s “shadow fleet” pursuant to Executive Order 13902. (Here, the Department of the Treasury press release, and the Department of State press release)
Concurrently, OFAC updated its September 2019 advisory to assist the global shipping and maritime industry in identifying sanctions evasion related to the shipment of Iranian-origin petroleum, petroleum products, or petrochemical products and implement sanctions compliance practices to guard against such sanctions risk. (Here)

In a notable move,OFAC imposed blocking sanctions against Yemen-based International Bank of Yemen Y.S.C. for its financial support of the Houthis. Sanctions imposed under the global terrorisms sanctions regime. (Here, the Department of the Treasury press release, and the Department of State press release)
France imposed asset-freezing sanctions against one entity and one individual under its autonomous counter-terrorism sanctions regime. (Here)

International Sanctions and Export Control Society is hosting an online event U.S. State Department’s role in development of export controls and sanctions policy. You can register here.

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