Last Week's Major Developments in Sanctions - August 25, 2025, to August 29, 2025

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Monday, August 25

• OFAC amended the Syria Sanctions Regulations to remove the sanctions from the Code of Federal Regulations in accordance with Executive Order 14312 of June 30, 2025. Executive Order 14312 rescinded some Syria sanctions. (Here)

Tuesday, August 26

• There was no major development on this day.

Wednesday, August 27 

• OFAC issued Russia-related General License 104A, “Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068.” Executive Order 14068 of February 8, 2024 imposes limitations on diamonds imported from Russia. (Here and the General License)

• OFAC imposed blocking sanctions against two individuals and two entities for their roles in the fraudulent IT worker scheme orchestrated by the government of North Korea. Sanctioned individuals are a Russian and a North Korean national. The scheme utilizes North Korean IT workers to generate revenue for North Korea and enable its illicit weapons and ballistic missile programs. (Here and the Department of the Treasury press release)

• Concurrently, the United States, Japan, and South Korea released a joint statement denouncing the North Korean IT worker scheme and reaffirming their commitment to counter malicious cyber activities and illicit revenue generation by North Korea. (Here) 

Thursday, August 28

• France, the U.K., and Germany initiated the snapback process embedded in UN Security Council Resolution 2231. This opens a 30-day period before the possible reestablishment of previously terminated UN Security Council sanctions on Iran. The countries allege that since 2019, Iran has exceeded agreed upon limits on enriched uranium, heavy water, and centrifuges, restricted the IAEA’s ability to conduct verification and monitoring activities, and has abandoned the implementation and the ratification process of the Additional Protocol to its Comprehensive Safeguards Agreement. (Here the Joint Statement of France, the U.K. and Germany and their letter to the United Nations Security Council)

• BIS published a rule easing license requirements for civilian exports to Syria. The rule has two key implications:

  • U.S.-origin goods, software, and technology that have purely civilian uses (i.e., those classified under BIS’s regulations as “EAR99”), as well as consumer communications devices and certain items related to civil aviation can be exported to Syria without an export license;

  • Approval of export licenses for telecommunications infrastructure, sanitation, power generation, and civil aviation are facilitated;

  • Restrictions on dual-use goods and restrictions on exports to malign actors remain in place. (Here)

• FinCEN issued an Advisory and a Financial Trade Analysis on Chinese money laundering networks (CMLNs):

  • The Advisory urges financial institutions to be vigilant in detecting the use of CMLNs by Mexico-based drug cartels; 

  • The Financial Trend Analysis highlights the scope and breadth of CMLN activity in the United States. (Here)

Friday, August 29

• BIS ended the Validated End-User program that allowed foreign companies to export semiconductor manufacturing equipment and technology to China license-free. (Here)