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Last Week's Major Developments in Sanctions - August 4, 2025, to August 9, 2025

  • Writer: Christopher Roth
    Christopher Roth
  • 2 minutes ago
  • 2 min read
You can now listen to the audio version of our weekly sanctions updates here.


Monday, August 4

  • FinCEN issued a notice urging financial institutions to be vigilant in identifying and reporting suspicious activity involving convertible virtual currency (CVC) kiosks that have increasingly become vehicles for illicit actors. (Here and the FinCEN notice)

  • The European Commission published FAQs on sanctions against Russia and Belarus, with a focus on Article 3p of Council Regulation (EU) No 833/2014 that imposes restrictions on diamonds. A total of 13 questions were updated. (Here) 


Tuesday, August 5

  • Two Chinese nationals were arrested on charges that they knowingly exported to China tens of millions of dollars’ worth of sensitive microchips used in artificial intelligence applications in violation of  the Export Control Reform Act. (Here) 


Wednesday, August 6 

  • OFAC imposed blocking sanctions against four individuals associated with the Mexico-based Cartel del Noreste (CDN), formerly known as Los Zetas. CDN, one of the most violent drug trafficking organizations in Mexico, is a U.S.-designated Foreign Terrorist Organization. Action taken pursuant of Executive Orders 14059, which targets the international proliferation of illicit drugs and their means of production, and 13224, which targets terrorists and their supporters. (Here, the Department of the Treasury press release, the Department of the Treasury chart)  

  • OFAC released its Quarterly Report on Licensing Activities pursuant to Section 906(b) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), covering activities undertaken by OFAC under Section 906(a)(1) of the TSRA from April through June 2025. Under Section 906 of the TSRA OFAC processes license applications requesting authorization to export agricultural commodities, medicine, and medical devices to Iran. (Here and the Quarterly Report) 

    • OFAC received a total of 32 applications and issued a total of 34 licensing determinations, including 16 licenses, one license amendment, 11 “return-without-action” letters, no denial letters, and four general license guidance letters. 

  • A Texas-based active duty soldier was arrested on charges of attempting to transmit national defense information on the operation of M1A2 Abrams tanks to Russia and attempting to export controlled technical data without a license. (Here)


Thursday, August 7

  • OFAC imposed blocking sanctions against seven individuals and 11 entities for their role in facilitating Iran’s evasion of U.S. sanctions and continued repression of the Iranian people. Targets include financial and IT firms, including one company that has enabled Iran’s security services to restrict ordinary Iranians’ internet access. Action taken pursuant of Executive Order 13902, which targets Iran’s financial and petroleum and petrochemical sectors. (Here and the Department of State press release)

  • OFSI extended General License INT/2022/2085212 until August 14, 2025. The license authorizes payments to sanctioned Russian banks or subsidies for the purpose of making energy available for use in Mongolia. (Here) 


Friday, August 8

  • There was no major development on this day.


Recommendation of the Week


  • Check out the latest issue of the Fordham International Law, which is focused on sanctions, and includes several scholarly articles about economic sanctions: Volume 48, Issue 5

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