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Last Week's Major Developments in Sanctions - December 8, 2025, to December 12, 2025

  • Writer: Amir Fadavi
    Amir Fadavi
  • Dec 16
  • 3 min read
You can now listen to the audio version of our weekly sanctions updates here.


Monday, December 8

  • The EU Council extended its DRC sanctions regime for another year through 12 December 2026. (Here, and press release)

  • DoJ announced that operation Gatekeeper has successfully shut down a major China-linked AI technology smuggling network, which resulted in the seizure of over $50 million in advanced GPUs and cash, and the arrest of two businessmen. According to DoJ, the network, including a Houston company and its owner who pleaded guilty, was involved in illegally exporting and attempting to export over $160 million worth of high-speed Nvidia H100 and H200 Tensor Core GPUs to China, Hong Kong, and other restricted destinations. The individuals charged, including Alan Hao Hsu and PRC natives Benlin Yuan and Fanyue Gong, allegedly falsified shipping documents, misclassified the goods as generic computer parts, and utilized straw purchasers to conceal the true nature and final recipients of the export-controlled technology. (Here)


Tuesday, December 9

  • OFSI imposed asset freezing sanctions against two individuals and five entities under its Russia sanctions regime. (Here, and relevant policy paper) OFSI imposed asset freezing sanctions against two entities under the UK's cyber sanctions regime. (Here, and press release)

  • OFAC imposed blocking sanctions against four individuals and four entities in Colombia under its Sudan program for their roles in recruiting former Colombian military personnel and training soldiers to fight for the Sudanese paramilitary group known as the Rapid Support Forces. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFAC published a $1,092,000 settlement with an individual to settle potential civil liability for apparent violations of Ukraine-/Russia-related sanctions. The facts of the case suggest that the person who settled acted as a "fiduciary" for a trust whose grantor was a sanctioned person. In my opinion, OFAC may have gone beyond its power by considering dealings with a trust that was not owned but merely controlled by a sanctions person as apparent violations. (Here)

  • DoJ announced two indictments charging a Ukrainian national for her role in conducting cyberattacks and computer intrusions against critical infrastructure and other victims around the world, in support of Russia’s geopolitical interests. (Here)

  • In an AML-related development, FinCEN assessed a $3,500,000 civil money penalty against Paxful, Inc. and Paxful USA, Inc. (collectively, Paxful) for willful violations of the Bank Secrecy Act. Paxful did not (i) register with FinCEN as a money services business (MSB); (ii) develop, implement, and maintain an effective AML program; and (iii) file suspicious activity reports. (Here)


Wednesday, December 10

  • OFAC issued General License 131A under its Russian Harmful Foreign Activities Sanctions Regulations replacing the expiring General License 131. The new General License is valid through through 12:01 a.m. eastern standard time, January 17, 2026. The new General License also authorities the use, debit, or credit of all blocked accounts of LIG Entities for the transactions authorized in the General License. (Here)


Thursday, December 11

  • Hours after seizing a sanctioned oil tanker off the coast of Venezuela,OFAC imposed blocking sanctions on four individuals, six entities, and six vessels under its Venezuela sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • December 11 marked the fifth anniversary of Sanctions Expert's weekly newsletter. Thank you for your constant support, and please continue to share our newsletter with anyone who would benefit from it.

Friday, December 12

  • OFSI imposed asset freezing sanctions against two individuals under its Sudan sanctions regime. (Here, and press release)

  • OFSI amended General Licence INT/2022/1839676 to add JSC Siberia Airlines to the definition of a designated person and it was extended and now expires on 22 May 2028. (Here)

  • OFAC delisted three individuals (including a Brazilian Supreme Court Judge) and one entity that were designated under the Global Magnitsky program. These individuals and the entity were sanctioned for their role in former Brazilian president, Bolsonaro, trial. (Here)

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