Last Week's Major Developments in Sanctions - June 16, 2025, to June 20, 2025

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Monday, June 16

• OFAC announced a $3.9 M settlement with Unicat Catalyst Technologies, U.S.-based company that sells catalyst products. The agreement settled Unicat’s potential civil liability for 13 apparent violations of the Iranian Transactions and Sanctions Regulations, and one apparent violation of the Venezuela Sanctions Regulations that arose from its provision of catalyst products and consulting services to Iran and its sale of catalysts to a blocked Venezuelan entity. Simultaneously, the Department of Justice announced that they declined the prosecution of private equity firm White Deer Management LLC (White Deer) and its affiliates after the firm discovered and voluntarily self-disclosed criminal violations of U.S. sanctions and export laws committed by a company it acquired Unicat. (Here, the Enforcement Notice, the Settlement Agreement, and the Department of Justice press release)

• The Department of Justice announced the arrest of two U.S.-based individuals charged with violating U.S. sanctions related to Venezuela, illegally smuggling goods from the United States, and money laundering. The defendants are accused of selling millions of dollars’ worth of catalysts, industrial equipment, and related services to the Venezuelan steel company Complejo Siderurgico de Guayana S.A., which is owned by the Venezuelan government and is subject to U.S. sanctions. (Here)

• The European Council issued Council Decision 2025/1204 that extended asset freezing sanctions imposed in response to the illegal annexation of Crimea and Sevastopol by Russia by one year until June 23, 2026. (Here) 

Tuesday, June 17

• A Spanish national living in the United Arab Emirates pleaded guilty to conspiring to illegally export U.S.-origin radio communications technology to Russian end users without a license in a U.S. District Court. (Department of Justice press release)

• The European Council adopted Council Regulation No 881/2002 that imposes sanctions directed against individuals and entities associated with the ISIL (Da'esh) and Al-Qaida organisations to reflect recent changes made by the Sanctions Committee of the United Nations Security Council. (Here)

• OFSI imposed asset-freezing sanctions against four individuals, six entities, and 20 vessels under the Russia (Sanctions) (EU Exit) Regulations 2019. The action targets Russia's energy, financial and military sectors. (Here)

Wednesday, June 18 

• OFAC imposed blocking sanctions against five Mexico-based leaders of Cartel de Jalisco Nueva Generacion (CJNG). Designations were made pursuant to Executive Orders 14059, which targets illicit drugs and their means of production, and 13224, which targets terrorists and their supporters. (Here, the Department of the Treasury press release, and the Department of State press release)

• OFAC issued Russia-related General License 55D, "Authorizing Certain Services Related to Sakhalin-2" that would otherwise be blocked under Executive Order 14071. This general license simply extended the authorization period and added a paragraph about the prohibition on petroleum services. (Here, and General License 55D) 

• FinCEN announced the release of its Year in Review of Fiscal Year 2024 report that provides information and statistics on the usefulness of BSA reporting at the 62nd semi-annual plenary meeting of the Bank Secrecy Act Advisory Group. (Here the full Fiscal Year 2024 report)

Key takeaways from the report include:

• 324,000 registered financial institutions and other e-filers produced 4.7 M SARs in 2024;

• 818 Section 314(a) requests made by law enforcement agencies; 

• 6,100+ Section 314(b) registered institutions and 48,223 SARs reference Section 314(b).

• The European Commission published two new consolidated versions of the frequently asked questions related to Russia’s invasion of Ukraine:

  • Questions concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it. (Here) 

  • Questions on targeted vessels adopted following Russia’s military aggression against Ukraine. (Here)

• OFSI imposed asset-freezing sanctions against one individual under the ISIL (Da'esh) and Al-Qaeda Sanctions Regime following the UN's addition of this individual to their ISIL (Da’esh) and Al-Qaida Sanctions List. (Here)

• OFSI published its “Art Market Participants and High Value Dealers Threat Assessment Report” that identifies key evasion threats, red flags that businesses should be aware of, and guidance on areas where compliance could be strengthened. (Threat Assessment Report)

Thursday, June 19

• There was no major development on this day.

Friday, June 20

• OFAC imposed blocking sanctions against four individuals, 12 entities, and two vessels that have imported oil and other illicit goods in support of the Houthis in Yemen. Sanctioned entities include Houthi front companies, their owners, and other key Houthi operatives that generate significant revenue for the group through the sale of oil and other commodities on Yemen’s black market and by engaging in smuggling operations through Houthi-controlled ports. Action taken pursuant to Executive Order 13224.(Here, the Department of the Treasury press release, and the Department of State press release)

• OFAC imposed blocking sanctions against one individual, eight entities, and one vessel for their involvement in procuring and transshiping sensitive machinery for Iran’s defense industry. Action taken in furtherance of National Security Presidential Memorandum-2, which directs that Iran be denied the development of missiles and other weapons capabilities. (Here, the Department of the Treasury press release, and the Department of State press release)

• OFAC issued Venezuela General License 5S, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After December 20, 2025” that would be prohibited by Executive Order 13835. (Here, and General License 5S)

Recommendation of the Week

• Last week OFSI published an estimation of the impact of sanctions on Russia’s war efforts. The publication highlights that as of February 2025, the Foreign, Commonwealth & Development Office estimates that global sanctions have deprived the Russian state of at least $450 billion since February 2022. Check out the publication here.

• On June 19, FATF published a new report on Complex Proliferation Financing and Sanctions Evasion Schemes revealing that significant vulnerabilities remain across the global financial system in countering the financing of weapons of mass destruction.