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Last Week's Major Developments in Sanctions - June 2nd, 2025, to June 6, 2025

  • Writer: Christopher Roth
    Christopher Roth
  • 3 minutes ago
  • 3 min read
You can now listen to the audio version of our weekly sanctions updates here.

Monday, June 2

  • France imposed asset freezing sanctions against three individuals under France’s autonomous counter-terrorism sanctions. (Here) 


Tuesday, June 3

  • There was no major development on this day.


Wednesday, June 4 

  • OFSI published six videos on YouTube as part of its new series ‘Financial Sanctions: The Basics’ that highlight six key areas in which OFSI operates and financial sanctions more generally. (Here, and the YouTube channel)

  • FinCEN rescinded two prior advisories and guidance documents related to Syria on 4 June. These advisories, issued in 2011 and 2013, respectively, had warned U.S. financial institutions about the risk of transactions involving persons specifically designated for sanctions relating to Syria, as well as proxies acting on behalf of such persons. FinCEN also rescinded 2011 guidance on the application of section 311 measures with respect to the Commercial Bank of Syria.


Thursday, June 5

  • OFAC imposed blocking sanctions against four individuals, currently serving as judges of the International Criminal Court (ICC) for engaging in efforts by the ICC to investigate, arrest, detain, or prosecute nationals of the United States or Israel, without consent from either state. These designations were made pursuant to Executive Order 14203, “Imposing Sanctions on the International Criminal Court.” (Here, and the Department of State press release, and the Department of State fact sheet)Concurrently and to mitigate the unintended effects of these sanctions,, OFAC issued seven ICC-related General Licenses that authorize a wide range of payments that would be blocked otherwise:

    • General License No. 1: Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on June 5, 2025 (Here)

    • General License No. 2: Authorizing the Provision of Certain Legal Services (Here)

    • General License No. 3: Authorizing Payments for Legal Services From Funds Originating Outside the United States (Here)

    • General License No. 4: Authorizing Emergency Medical Services (Here)

    • General License No. 5: Entries in Certain Accounts for Normal Service Charges and Payments and Transfers to Blocked Accounts in U.S. Financial Institutions Authorized (Here)

    • General License No. 6: Authorizing Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates for Personal, Non-Commercial Use (Here)

    • General License No. 7: Official Business of the United States Government (Here)

  • OFAC imposed blocking sanctions against six individuals, four Guyanese and two Colombians nationals, for smuggling cocaine from South America to the United States, Europe, and the Caribbean. Action taken pursuant of Executive Order 14059, which targets the proliferation of illicit drugs and their means of production. (Here, the Department of the Treasury fact sheet, and the Department of State press release)

  • OTSI published a collection of sanctions content, including introductory guidance, statutory guidance, guidance by industry sector, sanctions lists and how to report a breach. (Here) 

  • The U.S. Department of Justice filed a civil forfeiture complaint alleging North Korean IT workers illegally obtained millions in cryptocurrency to evade U.S. sanctions, with over $7.74 million seized. (Here)


Friday, June 6

  • OFAC imposed blocking sanctions against 10 individuals and 27 entities linked to Iranian brothers Mansour, Nasser, and Fazlolah Zarringhalam, who have collectively laundered billions of dollars through the international financial system via Iranian exchange houses and foreign front companies under their control as part of Iran’s “shadow banking” network. (Here, and the Department of the Treasury press release, and the Department of State press release)

  • Concurrently, FinCEN issued an ‘Advisory on the Iranian Regime’s Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons Procurement Efforts’ that provides updated red flags and information on current trends and typologies for Iranian sanctions evasion and other illicit activities. (Here)

  • OFSI issued new guidance to understand the circumstances under which it may license payments for travel concerning designated individuals. (Here)

  • OFSI published a page to house its sector-specific threat assessment reports. (Here) 

  • A federal jury convicted a Pakistani national today on charges related to smuggling Iranian-made advanced conventional weaponry destined for the Houthis in Yemen and threatening multiple witnesses. (Here)


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