Last Week's Major Developments in Sanctions - December 1, 2025, to December 5, 2025
- Amir Fadavi
- Dec 8
- 3 min read
You can now listen to the audio version of our weekly sanctions updates here.
Monday, December 1
Without providing much detail, the UK government announced that, in September 2025, a UK exporter paid a compound settlement offer of £620,515.04 to HM Revenue and Customs in relation to unlicensed exports of military goods controlled by The Export Control Order 2008. (Here)
The EU Council extended its Mali sanctions regime for another year through 14 December 2026. (Here) The Council also added two individuals to the list of targets under its Haiti sanctions regime, to implement recent UNSC designations. (Here)
Tuesday, December 2
OFSI published "supporting Syria’s future: guidance for businesses and NGOs." The guidance document describes current prohibitions and designations, after recent relaxation of sanctions against Syria, and how to use licenses and exceptions engaging in Syria. (Here)
OFAC announced a $11,485,352 settlement with a Chicago-based private equity firm, IPI Partners, LLC for soliciting, receiving, and maintaining investments from and for a Russian designated oligarch, Suleiman Kerimov. OFAC clearly states that in some cases a simple analysis of 50% rule is not enough and a more exhaustive analysis may be appropriate. (Here)
Australia sanctioned several vessels that were involved in moving Russian oil after Russia's invasion of Ukraine in 2022. (Here)
Wednesday, December 3
OFAC imposed blocking sanctions on seven individuals and four entities under its global terrorism and transnational crime sanctions programs for their ties to Tren de Aragua. (Here, and the Department of the Treasury's press release)
Thursday, December 4
OTSI published "one year of the Office of Trade Sanctions Implementation" which provides an overview of OTSI’s activities within its first year of operation, alongside a forward look to OTSI’s future priorities. (Here)
OFSI imposed asset freezing sanctions against:
OFSI and FDCO announced a webinar on Wednesday 17 December 2025, 11:00am – 12:00pm GMT. In this webinar OFSI and FDCO explain the upcoming move from the UK Consolidated List to a single list for UK sanctions designations. (Register here.)
The EU Council extended its human rights sanctions regime for another year until 8 December 2026. (Here, and press release)
Friday, December 5
As the expiration date of General License 128A under Russia Harmful Foreign Activities on December 13 was approaching OFAC replaced it with General License 128B authorizing all transactions prohibited by Executive Order 14024 involving Lukoil International GmbH (LIG) or any entity in which LIG owns, directly or indirectly, a 50 percent or greater interest, including Lukoil NorthAmerica LLC and Lukoil Americas Corporation, (collectively, “LIG Entities”) that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of, physical retail service stations located outside of the Russian Federation through April 29, 2026. (Here) OFAC also published FAQ 1225 to explain this General License.
OFAC issued a Penalty Notice imposing a $7,139,305 penalty on Gracetown, Inc., a property management company based in New York, for violating OFAC’s Ukraine-/Russia-Related sanctions and for failing to file reports of blocked assets. Between April 2018 and May 2020, Gracetown received 24 payments on behalf of a company ultimately owned by a sanctioned Russian oligarch, Oleg Deripaska, despite having received explicit prior notice from OFAC that direct and indirect dealings with Deripaska were prohibited. (Here)
DoJ announced that a Maryland resident was sentenced to 15 months in prison followed by three years of supervised release for his role in a fraudulent scheme that assisted foreign IT workers, including North Korean National, posing as U.S. citizens with obtaining remote IT positions at over a dozen U.S. companies. (Here)