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Last Week's Major Developments in Sanctions - March 31st, 2025, to April 4th, 2025

  • Writer: Amir Fadavi
    Amir Fadavi
  • Apr 7
  • 3 min read
 
You can now listen to the audio version of our weekly sanctions updates here.
 

Monday, March 31

  • The U.S. Department of State designated six individuals under the U.S. sanctions program against Hong Kong. The designated parties are subject to blocking sanctions of the United States. The last time the United States designated someone under its Hong Kong sanctions program was in July 2021. (Here, the Department of State's press release, the Department of State's fact sheet)

  • OFAC imposed blocking sanctions on six individuals and seven entities for supporting the Sinaloa Cartel. These designations are made pursuant to both illicit drugs and counter-terrorism sanctions programs of the United States. (Here, and the Department of the Treasury's press release)

  • In an AML-related development, FinCEN issued an alert on bulk cash smuggling and repatriation by Mexico-based Transnational Criminal Organizations, urging financial institutions to be vigilant to such activity. (Here)


Tuesday, April 1

  • OFAC imposed blocking sanctions against two individuals and six entities for being responsible for the procurement of unmanned aerial vehicle components on behalf of Iran-based Qods Aviation Industries. Four out of six designated entities as part of this action were located in the UAE. On the same day, the Department of Justice brought charges against the two individuals, one of whom was sanctioned on this day and the other sanctioned in 2013, and one entity that was also sanctioned on this day, for conspiring to procure U.S. parts for Iranian drones, conspiring to provide material support to the IRGC, and conspiring to commit money laundering.  (Here, the Department of the Treasury's press release, the Department of State's press release, and the Department of Justice's press release)

  • FinCEN issued another advisory, this time about ISIS. The advisory highlights how ISIS and its global affiliates fund themselves and receive financial support from sympathizers internationally and describes several typologies ISIS uses to transfer money between its affiliates. The advisory also provides red flags that may assist financial institutions in identifying related suspicious activity. (Here)


Wednesday, April 2

  • OFSI imposed asset-freezing sanctions against 12 individuals and one entity under the UK's global anti-corruption sanctions regime. (Here, and press release)

  • OFAC imposed blocking sanctions against five individuals, four entities, and one vessel under its counter-terrorism sanctions program for being involved in a network that procured tens of millions of dollars’ worth of commodities from Russia to Houthi-controlled Yemen. OFAC also identified eight digital asset wallets used by the Houthis to transfer funds associated with their activities. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFAC delisted Karina Rotenberg, Boris Rotenberg's wife. Boris Rotenberg is a close ally of Vladimir Putin. (Here)

  • A Russian national, was sentenced today to 70 months in prison for his role in a conspiracy to export controlled aviation technology to Russia and to launder money in connection with the illegal export scheme. (Here)


Thursday, April 3

  • OFSI published Legal Services Threat Assessment. Since February 2022, the legal services sector has submitted the second highest number of suspected breach reports to OFSI by sector, accounting for 16% (compared with 65% submitted by the financial services sector). The assessment highlighted four key judgments about the legal services sector in the UK:

    • It is highly likely that UK trust and company services providers have not

      self-disclosed all suspected breaches to OFSI.

    • It is almost certain that most non-compliance by UK legal services providers has

      occurred due to breaches of OFSI licence conditions.

    • It is almost certain that complex corporate structures, including trusts, linked to

      Russian DPs and their family members have obfuscated the ownership and control

      of assets which could be frozen under UK financial sanctions.

    • It is likely that Russian DPs have transferred the ownership and control of assets

      to non-designated individuals and entities. In some cases, this could breach UK

      financial sanctions.


Friday, April 4

  • There was no major development on this day.


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