Last Week's Major Developments in Sanctions - December 15, 2025, to December 19, 2025

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Monday, December 15

• The EU Council started the week by adopting six sanctions-related decisions:

  • Decision 2025/2594: Imposing asset freezing sanctions against five individuals and four entities for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. (Press release)

  • Decision 2025/2572: Imposing asset freezing sanctions against 12 individuals and two entities for being part of Russia’s malicious activities directed against the Union, its Member States, international organizations and third countries. (Press release)

  • Decision 2025/2561: Imposing asset freezing sanctions against three individuals and one entity for for being part of the gangs in Haiti and abusing the human rights in the country. (Press release)

  • Decision 2025/2580: Amending some of the target entries under the block's DPRK sanctions (i.e., no new sanctions).

  • Decision 2025/2585: Adding a new ground for designation under the EU's Belarus sanctions regime. The new ground allows EU to designate individuals or entities responsible for "implementing, supporting, benefitting from, involved in or facilitating actions or policies attributable to the Republic of Belarus which undermine or threaten democracy, the rule of law, stability or security in the Union or in one or several of its Member States, in an international organization or in a third country, or which undermine or threaten the sovereignty or independence of one or several of its Member States, or of a third country, including in cases where it results in the disruption of the functioning of critical infrastructure, where it is reasonable to believe the natural or legal persons, entities or bodies were at least aware of the potential effects." (Press release)

  • Decision 2025/2586: Extended the EU sanctions regime against Venezuela until 10 January 2027. (Press release)

• In response to Belarus' release of 123 political prisoners, OFAC issued General License 13 under its Belarus sanctions program authorizing all transactions with the following entities: (1) Joint Stock Company Belarusian Potash Company; (2) Agrorozkvit LLC; (3) Belaruskali OAO; or (4) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. (Here, read more about this action here.)

  
  

Tuesday, December 16

• The U.S. Department of State designated Colombia-based Clan del Golfo as a Foreign Terrorist Organization and a Specially Designated Global Terrorist. (Here)

  
  

Wednesday, December 17

• OFSI amended General License INT/2025/5635700 to add the Zohr project, Egypt's offshore natural gas field in the Mediterranean in which Rosneft is involved, to the list of Exempt Projects under this license. (Here)

• OFAC imposed blocking sanctions against Cartel de Santa Rosa de Lima, which derives the vast majority of its illicit revenue from fuel and oil theft in the Mexican state of Guanajuato, and its leader. (Here, and the Department of the Treasury's press release)

• OFAC issued General License Russia-related General License 55E, "Authorizing Certain Services Related to Sakhalin-2;" and Russia-related General License 115C, "Authorizing Certain Transactions Related to Civil Nuclear Energy." These licenses replace older versions of the same authorizations that were set to expire. OFAC also amended several FAQs to reflect the new licenses. (Here)

• OFSI amended Legal Services General License INT/2025/7323088 to clarify that the definition of “Legal Services” includes legal advice and/or representation in dispute resolution. OFSI published FAQ 175 about the amended General License. (Here, and the FAQs) OFSI also amended General License - INT/2025/7628424,the Interim Necessities General License, to amend the "IT Providers" definition and revised the scope of one of the permissions under the General License. (Here)

Thursday, December 18

• The EU Council added 41 vessels to the list of vessels set out in Annex XVI to Decision 2014/512/CFSP for contributing to Russia’s energy revenues. These vessels are banned from Member States’ ports and locks, as well as from receiving a broad range of services related to maritime transport. (Here, and press release)

• EU Commission published 14 FAQ about the movement of Russian diplomats. (Here)

• The UK government replaced its general trade license under Russia sanctions for financial services and funds related to fertilizers. (Here)

• OFSI imposed asset freezing sanctions against five individuals and 19 entities under its Russia sanctions regime for being involved in Russia energy and military supply chain sectors. This action targeted Russia’s largest remaining unsanctioned oil companies, PJSC Tatneft, PJSC Russneft, LCC NNK-Oil, and LLC Rusneftegaz Group. (Here, and press release) OFSI published General License INT/2025/8202932 authorizing certain wind-down transactions. (Here)

• OFAC imposed blocking sanctions against one individual, 20 entities and 29 vessels under its Iran sanctions program for exporting Iranian petroleum and petroleum products through deceptive shipping practices. (Here, the Department of the Treasury's press release, and the Department of State's press release) Concurrently, OFAC issued Iran-related General License S, "Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on December 18, 2025."

• The U.S. Department of State imposed blocking sanctions against two International Criminal Court (ICC) judges for engaging in efforts by the ICC to investigate, arrest, detain, or prosecute Israeli nationals, without Israel’s consent, including voting with the majority in favor of the ICC’s ruling against Israel’s appeal on December 15. (Here, and the Department of State's press release)

• OFAC published revised versions of FAQ 1224 and 1225 related to sale and operation of Lukoil International GmbH. (Here)

Friday, December 19

• OFSI imposed asset freezing sanctions against six individuals and three entities under its Syria sanctions regime for their involvement in violence against the Syrian people. (Here, and press release)

• OFSI published General License INT/2025/8257372 related to Myanmar humanitarian activity. (Here) OFSI also published FAQ 176 that discusses the Myanmar and Syria related humanitarian General Licenses. (Here)

• OFAC impose blocking sanctions against seven members and associates of the Maduro-Flores family. (Here, the Department of the Treasury's press release, and the Department of State's press release)