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Last Week's Major Developments in Sanctions - June 30, 2025, to July 4, 2025

  • Writer: Christopher Roth
    Christopher Roth
  • Jul 8
  • 3 min read
You can now listen to the audio version of our weekly sanctions updates here.

Monday, June 30

  • The White House issued Executive Order 14213 which removes U.S. sanctions on Syria, effective July 1, 2025. The Executive Order replaces Syria General License (GL) 25, issued on May 28. OFAC’s previous Syria sanctions program is now the Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS) program. Consequently, OFAC removed 518 individuals and entities from the SDN List and also designated 139 individuals and entities affiliated with the previous regime under E.O. 13894. (Here, Executive Order 14312, the Department of the Treasury press release, and the Department of State press release)

  • To facilitate the removal of sanctions, OFAC published four new Syria FAQs. (Here)

  • OFAC published regulations to implement Executive Order 14203 of February 26, 2025, "Imposing Sanctions on the International Criminal Court” that came into effect on July 1, 2025. (Here)

  • The European Council extended Council Decision 2014/512/CFSP by six months until January 31, 2026. The council decision imposes asset freezing sanctions first introduced in 2014 and significantly expanded since February 2022 in response to Russia’s unprovoked, unjustified and illegal military aggression against Ukraine. (Here)


Tuesday, July 1

  • OFAC imposed blocking sanctions on four individuals and four entities associated with Aeza Group, a Russia-based bulletproof hosting (BPH) services provider. Bulletproof hosting service providers sell access to specialized servers and other computer infrastructure designed to help cybercriminals like ransomware actors, personal information stealers, and drug vendors evade detection and resist law enforcement attempts to disrupt their malicious activities. Action taken pursuant of Executive Order 13694 that targets cybercrime committed against the U.S. (Here, and the Department of the Treasury press release)


Wednesday, July 2 

  • OFAC announced a $609k settlement with Key Holding, LLC.  Key Holding agreed to settle its potential civil liability for 36 apparent violations of OFAC sanctions on Cuba that arose from the conduct of its subsidiary in Colombia. The low settlement amount reflects OFAC's understanding that the apparent violations were non-egregious and voluntarily self-disclosed. (Here and the Enforcement Release)

  • BIS notified Alpha and Omega Semiconductor Incorporated of Sunnyvale, California of its intention to initiate an administrative proceeding against the company pursuant to Section 766.3 of the Export Administration Regulations. The company designs, develops, and supplies power semiconductors for personal electronics and is accused of exporting 1,650 power controllers, smart power stages, and related accessories to Huawei Technology, a company listed on the BIS Entity List in 2019. (Here)


Thursday, July 3

  • OFAC imposed blocking sanctions on one individual, Iraqi businessman Salim Ahmed Said, as well as four entities, and several vessels under his control. Action targets a network that has transported and purchased billions of dollars’ worth of Iranian oil, some of which has benefited Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. The network operates by transferring Iranian oil ship-to-ship and mixing it with Iraqi oil to evade sanctions. Action taken pursuant of Executive Order 13902 and 13224. (Here, the Department of the Treasury press release, the Department of State press release, and the Department of State fact sheet)

  • OFAC imposed blocking sanctions on seven senior officials and one entity associated with the Hizballah-controlled financial institution Al-Qard Al-Hassan (AQAH), which was designated by OFAC in 2007. The sanctioned individuals are senior leaders of AQAH and have facilitated the evasion of U.S. sanctions, enabling Hizballah’s access to the formal financial system. Action taken pursuant of Executive Order 13224. (Here, the Department of the Treasury press release, and the Department of State press release)

  • ​​The U.K.’s Export Control Joint Unit updated its arms embargo guidance on Armenia and Azerbaijan. The embargo now applies to weapons, ammunition and munitions that might be used on the land border between Armenia and Azerbaijan by military, police, security forces and related government entities of either state. The embargo no longer contains a condition of usage in the Nagorno-Karabakh region. (Here)

  • OFSI added four new FAQs: (Here)

    • #149 provides guidance on what constitutes ‘economic resources’; 

    • #150 and #151 provide further clarification on whether licences are required from both OFSI as well as Crown Dependencies and Overseas Territories for the same activity;

    • # 152 provides guidance regarding the reporting of securities held at designated local Russian registrars.


Friday, July 4

  • There was no major development on this day.

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