Last Week's Major Developments in Sanctions - April 21st, 2025, to April 25th, 2025

OFAC imposed blocking sanctions on two Iranian nationals and their corporate network of 12 entities and one vessel for shipping liquified petroleum gas from Iran to foreign markets. The action was taken under Executive Order 13902 and in line with National Security Presidential Memorandum 2. (Here, and the Department of the Treasury press release and the Department of State press release)
OFSI issued three new FAQs about recent mergers in the banking sector of Russia where two targeted banks ceased to exist and merged into a new entity. (FAQs 146 to 148)

The UK Department for Business and Trade revised an Open General Export license for oil and gas exploration dual-use goods to re-include the UK Continental Shelf as a permitted destination. (Here)

OFSI extended general license INT/2023/3263556 GTLK Companies and their Subsidiaries to allow payments and other permitted activities to GTLK companies despite falling under the 2019 Russia Regulations 2019. (Here)
In a notable development, OFSI revoked asset-freezing sanctions imposed on 12 Syrian entities made under the UK sanctions program against Syria. Entities include the Ministry of Interior, Ministry of Defence, the General Intelligence Directorate as well as several TV stations. (Here, and the Foreign, Commonwealth & Development Office press release)
The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 came into force. As a result of this new instrument, the UK expanded the scope of trade restrictions to include additional export sanctions, technology transfer sanctions, software sanctions, and import sanctions. (Here) OFSI published a guidance on complying with technology transfer sanctions. (Here) OFSI also issued guidance about complying with sectoral software sanctions. (Here) The DBT’s Export Control Joint Unit published a notice for exporters about the new restrictions. (Here)

The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025 came into effect. (Here) This instrument revokes specific sanctions on energy, transport (aircraft), financial transactions, trade, and exemptions on financial/credit institutions. Accordingly, OFSI updated its Syria sanctions guidance. (Here)
OFSI amended the statement of reasons for 348 targeted individuals, under Syria Regulation 2019, to reflect the recent political changes in Syria and indicate the link between those individuals and the Assad regime. (Here)
The DBT’s Export Control Joint Unit published another notice for exporters about the new restrictions as a result of the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. (Here) OFSI also updated its Russia sanctions guidance to reflect changes made by the new regulations. (Here)
France imposed asset-freezing sanctions against two individuals under France’s autonomous counterterrorism sanctions. (Here)
The EU Council decided to extend the validity of the EU restrictive measures against Myanmar for one year, until 30 April 2026. (Here, and press release)

Check out this post by our founder, Amir Fadavi, about the number of sanctioned parties under the U.S. Iran sanctions program since the new U.S. administration took office in January.

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