Last Week's Major Developments in Sanctions - August 18, 2025, to August 22, 2025

OFAC imposed blocking sanctions against four individuals and two entities, all based in the Limón region of Costa Rica, for their role in narcotics trafficking and money laundering. Costa Rica has become an increasingly significant waypoint for criminal groups trafficking cocaine into the Unites States. Action taken pursuant to Executive Order 14059, which targets the international proliferation of illicit drugs or their means of production. (Here, the Department of the Treasury press release, and the Department of the Treasury chart)
A dual U.S. and Russian national was sentenced by U.S. district court to 30 months in prison for his role in an illicit procurement and money laundering network that sought to acquire ammunition and sensitive dual-use electronics for Russian military and intelligence services. (Here)
The U.S. Department of the Treasury issued a Request for Comment required by the GENIUS Act, which is meant to support the responsible growth and use of digital assets, as outlined in Executive Order 14178 on “Strengthening American Leadership in Digital Financial Technology.” Treasury asked commenters about application program interfaces, artificial intelligence, digital identity verification, and use of blockchain technology and monitoring. (Here)

FinCEN extended the effective dates of orders issued on June 25, 2025, prohibiting certain transfers of funds involving Mexico-based financial institutions, CIBanco, Intercam, and Vector. FinCEN found them to be of primary money laundering concern in connection with illicit opioid trafficking pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act. Financial institutions now have until October 20, 2025, to implement the orders. (Here)
A Chinese national was sentenced to 96 months in prison for illegally exporting firearms, ammunition, and other military items to North Korea by concealing them inside shipping containers that departed from the Port of Long Beach and for committing this crime at the direction of North Korean government officials. (Here)
OFSI added FAQs 162, 163 and 164 to address questions around the use of Russia and Belarus related licence INT/2025/6641960. The license authorizes transfers of funds held through the National Settlement Depository and the termination of accounts with brokers who are Designated Persons. (Here)

OFAC imposed blocking sanctions against four individuals associated with the International Criminal Court (ICC). Action taken pursuant of Executive Order 14203, for having directly engaged in an effort by the ICC to investigate, arrest, detain, or prosecute a protected person without consent of that person’s country of nationality. (Here and the Department of State press release, and the Department of State fact sheet)
Concurrently, OFAC issued International Criminal Court-related General License 9, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on August 20, 2025. The license allows for ordinary and wind down transactions until September 19, 2025. (Here and the General License)
A federal jury convicted a U.S. Navy sailor of espionage and export violations for agreeing to sell Navy secrets to a Chinese intelligence officer for $12,000. Sentencing is scheduled for December 1st. (Here)
OFSI imposes asset freezing sanctions against three individuals and five entities under the Russia Sanctions Regime for their role circumventing Russia sanctions. Action closes in on the Kyrgyzstan-based Capital Bank which Russia uses to pay for military goods. (Here and the OFSI press release)

OFAC imposed blocking sanctions against one individual, a Greek national, and his network of eight entities, as well as 11 vessels used to circumvent sanctions on Iranian oil exports. Action taken pursuant to Executive Order 13902, which targets Iran’s petroleum industry. (Here, the Department of the Treasury press release, and the Department of State press release)
An eight-count indictment was unsealed in the federal courthouse in Brooklyn charging one individual for his involvement in a scheme to illegally export weapons parts and accessories from the United States to other countries, including Kazakhstan, which serve as transshipment points for materials destined for Russia. Charges include conspiracy to defraud the United States, conspiracy to violate the Export Control Reform Act, conspiracy to violate the Arms Export Control Act, and attempted violation of the Arms Export Control Act. (Here)
OFSI imposed asset freezing sanctions against one individual and four entities in Iran for their role in destabilizing political activity directed towards the United Kingdom and other countries. Action taken in accordance with the Iran (Sanctions) Regulations 2023 (S.I. 2023/1314) made under the Sanctions and Anti-Money Laundering Act 2018. (Here)