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Last Week's Major Developments in Sanctions - March 24th, 2025, to March 28th, 2025

  • Writer: Amir Fadavi
    Amir Fadavi
  • Mar 31
  • 3 min read
 
You can now listen to the audio version of our weekly sanctions updates here.
 
Monday, March 24

  • OFSI amended two of its general licenses - INT-2022-1947936 and INT/2022/2085212 - to reflect the recent merger of Rosbank into T-Bank (formerly known as Tinkoff Bank).

  • OFSI imposed blocking sanctions against four individuals for being involved in serious human rights violations and abuses during the civil war in Sri Lanka. (Here, and press release)

  • OFAC amended general license 41A under the Venezuela Sanctions Regulations by issuing general license 41B, which allows more time for the wind down activities of Chevron in Venezuela. The new deadline on May 27, 2025. (Here)

  • In a non-sanctions-related development, FinCEN published 21 FAQs about a Geographic Targeting Order (GTO) issued on March 11 in an attempt to combat illicit activities and money laundering by Mexico-based cartels along the southwest U.S. border. As a reminder, the GTO mandates money services businesses in 30 ZIP codes in California and Texas to file Currency Transaction Reports for cash transactions over $200. (Here)

  • President Trump, for the first time, used "secondary tariffs" against another country. Specifically, he created the framework for the United States to impose 25% tariffs on all goods exported from a country that continues to export Venezuelas oil, directly or indirectly, after April 2, 2025. Such use of tariffs is analogous to the so-called "secondary sanctions" that intend to prevent actors over whom the United States has no jurisdiction from engaging with a person sanctioned by the United States. (Here)

  • The EU Commission published eight FAQs about sanctions related to liquefied natural gas (LNG) transshipments under EU's Russia sanctions regime. (Here)


Tuesday, March 25

  • OFAC imposed blocking sanctions against three individuals in Iran for being involved in the abduction, detention, and probable death of a former FBI Special Agent under the United States' Hostages and Wrongfully Detained U.S. Nationals sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • BIS added 80 entities to the Entity List from China, the United Arab Emirates, South Africa, Iran, Taiwan, and others for alleged engagements with Iran and China, including supporting China’s development of its hypersonic weapons program, and Iran's procurement of unmanned aerial vehicles. (Press release)


Wednesday, March 26

  • There was no major development on this day.


Thursday, March 27

  • OFSI extended the validity of general license INT/2023/2883496 for two more years, until April 13, 2027. The general license authorizes certain payments related between Russian Railways and Lithuanian Railways (LTG) relevant to the transit of persons between the Kaliningrad Region and other parts of Russia via the passenger rail service operated by LTG. (Here)

  • OFSI made major amendments to general license INT/2022/1280976 to allow any designated party in the UK to comply with certain obligations including financial prudential supervision, financial stability, or consumer protection. (Here)

  • OFSI published FAQ 145 about creating temporary "suspense accounts" in order to freeze asset of designated persons. (Here)

  • The Justice Department announced the disruption of an ongoing terrorist financing scheme through the seizure of approximately $201,400 in cryptocurrency held in wallets and accounts intended to benefit Hamas. (Here)

  • The EU Council imposed asset freezing sanctions against 25 individuals and seven entities responsible of undermining democracy and the rule of law in Belarus, as well as military cooperation with Russia in support of the war against Ukraine. (Decision, and press release)


Friday, March 28

  • OFAC imposed blocking sanctions against five individuals and three entities in Lebanon for being part of an evasion network supporting the Hizballah finance team. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFSI issued a general license authorizing payments to arbitration associations and arbitrators to cover fees and expenses for their arbitration services that involves a designated person under Russia or Belarus sanctions programs of the UK. The

    general licence also permits arbitrators and arbitration associations to direct payment of, receive and use such payments to cover arbitration costs. (Here)

  • The U.S. DoJ brought action against two individuals for allegedly smuggling U.S. goods and technology to Pakistan’s Military in violation of the U.S. export administration regulations. (Here)


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