Last Week's Major Developments in Sanctions - June 23, 2025, to June 27, 2025

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Monday, June 23

• BIS notified Unicat Catalyst Technologies of its intention to initiate administrative proceedings against Unicat Catalyst Technologies pursuant of Section 766.3 of the Export Administration Regulations by issuing a Charging Letter to Unicat. Action taken after OFAC announced a settlement with the company last week. (Here)

• FinCEN advised U.S. financial institutions to consider FATF’s updated stance towards the British Virgin Islands and Bolivia that were added to the Jurisdictions Under Increased Monitoring list, while Croatia, Mali, and Tanzania were removed. The list High-Risk Jurisdictions Subject to a Call for Action has not changed. (Here)

• The EU Council imposed asset-freezing sanctions against five individuals under the European Union Global Human Rights Sanctions regime as they were allegedly involved in serious human rights violations and abuses in Syria, including involvement in the violence in the coastal region of Syria in March 2025 and supporting the use of chemical weapons against the civilian population under the al-Assad regime. (Council Decision, and press release)

Tuesday, June 24

• OFAC imposed blocking sanctions on Giovanni Vicente Mosquera Serrano, a fugitive leader of Tren de Aragua, a Foreign Terrorist Organization. Tren de Aragua is involved in illicit drug trade, human smuggling and trafficking, extortion, sexual exploitation of women and children, and money laundering, among other criminal activities. Action taken pursuant of Executive Order 13581 and 13224. (Here, the Department of the Treasury press release, and the Department of State press release)

Wednesday, June 25 

• In one of the first of its kind types of developments, FinCEN issued orders identifying three Mexico-based financial institutions, CIBanco S.A., Institution de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector), as being of primary money laundering concern in connection with illicit opioid trafficking, and prohibit certain transmittals of funds involving these banks. These orders are the first actions by FinCEN pursuant to the FEND Off Fentanyl Act, which provide Treasury with additional authorities to target money laundering associated with the trafficking of fentanyl and other synthetic opioids. (Here) As a result of this action, covered financial institutions in the United States are prohibited from engaging in any transmittal of funds from or to the designated financial institutions. Please note that this is not a blocking sanction like those implemented by OFAC. To support the implementation of this new regulatory framework FinCEN published FAQ on Section 2313a Orders Prohibit Certain Transmittals of Funds Involving CIBanco, Intercam, and Vector. (Here) 

Thursday, June 26

• Australia imposed blocking sanctions against 37 individuals and seven entities under the Australian autonomous sanctions regime against Russia. (Here)

• The Secretary of State announced a new visa restriction policy under section 212(a)(3)(C) of the Immigration and Nationality Act that will apply to family members and close personal and business associates of individuals sanctioned under Executive Order 14059, imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade. (Here)

• A Kyrgyzstani-national pleaded guilty to conspiring to commit export violations by exporting firearms and ammunition worth over $1.5 million from the United States to Russia, in violation of U.S. law. When sentenced, Zharnovnikov faces up to 20 years in prison. (Here)

• A Mexican-national was sentenced to eight years and four months in prison and three years of supervised release for his role in the collection of drug proceeds in the United States and the repatriation of those proceeds or their equivalent value to Mexico as part of a money laundering conspiracy. (Here)

• The European Council imposed asset freezing sanctions on one individual related to Russia’s Russia’s malign activities directed against the Union, its Member States, international organisations and third countries under Council Decision 2025/1279. The sanctioned individual is a social media influencer pushing for ousting France and the West from the African continent. (Here)

• The European Council imposed asset-freezing sanctions on one individual associated with ISIL after the Sanctions Committee of the United Nations Security Council added the individual to a list of persons to whom the freezing of funds and economic resources should apply. (Here)

• The U.K. Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 came into force which strengthens the implementation and enforcement of UK sanctions. This legislation identifies additional matters that can be disclosed to the Secretary of State for Business and Trade and Secretary of State for Transport as prescribed persons for whistleblowing. (Here)

Friday, June 27

• OFAC published General License No 115b “Authorizing Certain Transactions Related to Civil Nuclear Energy” that would be prohibited under Executive Order 14024 targeting Russia. The license allows transactions with 13 Russian entities. (General License No 115b)

• OFAC updated ten Russia-related Frequently Asked Questions related to Executive Order 14024. (Here, and the FAQ)

• OFAC invited the public and Federal agencies to comment on a proposal to add an electronic Sanctions Reconsideration Portal information collection within OFAC’s Reporting. Written comments must be submitted by August 25, 2025, to be assured of consideration. (Here)

• FinCEN issued an order permitting banks to collect Tax Identification Number (TIN) information from a third party rather than from the bank’s customer. (Here, and the FinCEN press release)

• FinCEN launched a public-private information sharing Exchange program, “Combating and Obstructing Money Movements Associated with Narcotics and Drug Trafficking Organizations” (COMMAND). COMMAND mobilizes community and regional financial institutions as frontline partners in the fight against illicit finance to combat narcotics and drug trafficking organizations, including cartels. COMMAND supports Executive Order 14157, which designates cartels and other organizations as foreign terrorist organizations and specially designated global terrorists. (Here)

• The U.K. Foreign, Commonwealth and Development Office published new sanctions guidance to support non-U.K. businesses operating outside the U.K. The guidance includes country-specific guides for businesses in Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Uzbekistan. (Here)

• OFSI amended two general licenses, INT/2022/2470156, Oil Price Cap: Exempt Projects and Countries, and INT/2025/5635700, Russian Oil Exempt Projects to continue the exemption of the Sakhalin-2 Project (Here INT/2022/2470156 and here INT/2025/5635700) 

Recommendation of the Week

• Sanctionsexpert.com’s founder, Amir Fadavi, will be in Taipei City and Singapore for some sanctions training in collaboration with Institute for Financial Integrity Network, Crowell, and the U.S. State Department between July 9 and July 15. If you are in those cities and are interested in meeting in person to discuss sanctions, send a message to info@sanctionsexpert.com.