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Last Week's Major Developments in Sanctions - May 12th, 2025, to May 16th, 2025

  • Writer: Christopher Roth
    Christopher Roth
  • May 19
  • 4 min read
You can now listen to the audio version of our weekly sanctions updates here.

Monday, May 12

  • OFAC imposed blocking sanctions against two Iranian nationals and one entity affiliated with Iran’s Organization of Defensive Innovation and Research’s Shahid Karimi Group. The group works on explosives and nuclear-related research that could have military applications. Sanctions imposed under Executive Order 13382. (Here, and the Department of State press release the Department of State fact sheet)

  • The European Council extended the restrictive measures imposed under the EU’s cyber sanctions regime for another year until May 18, 2026; and extended the framework of the cyber sanctions regime for three more years, until May 18, 2028. (Decision, and press release)


Tuesday, May 13

  • The European Council added more designation grounds under its sanctions program against Russia. Specifically, the EU can now impose asset-freezing sanctions against individuals and entities that “enabled transfers of ownership, control or economic benefit of the business interests of leading businesspersons who are subject to Union restrictive measures” in order to circumvent the EU sanctions. (Decision)

  • In a notable move, the Department of Commerce’s Bureau of Industry and Security (BIS) rescinded the Biden-era AI Diffusion Rule before it took effect on May 15. The rule would have imposed new stringent export controls on AI models and semiconductors necessary to develop AI. A replacement rule will be announced in the future. (Here) To mitigate the risks posed by the PRC’s AI and semiconductor advancements, BIS published three guidance:

    •  Alerting industry to the risks of using PRC advanced computing ICs, including specific Huawei Ascend chips. (Here)

      • This guidance may have far reaching impacts as it suggests that using Chinese AI models that rely on microchips that ended up in China in violation of EAR may violate General Prohibition 10 under EAR.  

    • Warning the public about the potential consequences of allowing U.S. AI chips to be used for training and inference of Chinese AI models. (Here)

    • Informing U.S. companies on how to protect supply chains against diversion tactics.(Here)

  • OFAC imposed blocking sanctions against one individual, 15 entities, based in China, Hong Kong, Singapore, Seychelles, and two vessels for enabling Iran’s illicit international oil trade. The trade is orchestrated by Iran’s Armed Forces General Staff (AFGS) and enables Iran’s Ministry of Defense and Armed Forces Logistics (MODALF) to develop ballistic missiles and finance terrorism. Sanctions imposed under Executive Order 13224, as amended by Executive Order 13886. (Here, the Department of the Treasury press release, and the Department of State press release)

  • The US Secretary of State certified Cuba as a “not fully cooperative country” with US counterterrorism efforts in 2024 under section 40A of the Arms Export Control Act. Consequently, sale or license for export of defense articles and services to Cuba is prohibited. (Here) The last determination pursuant to section 40A did not include Cuba.  North Korea, Iran, Syria, and Venezuela are the other non-fully cooperative countries which were re-certified. On the same day that Syria was re-certified, President Trump announced that his administration will start lifting sanctions against Syria. More on that in the recommendation of the week section below. 


Wednesday, May 14 

  • OFAC imposed blocking sanctions against five individuals and ten entities for their involvement in supporting various Islamic Revolutionary Guard Corps sub-organization in their efforts to domestically develop carbon fiber materials required to manufacture intercontinental ballistic missiles. Action taken under Executive Order 13382, which targets proliferators of weapons of mass destruction. (Here, the Department of the Treasury press release, and the Department of State press release)

  • Starting on May 14, 2025, the following categories in the UK are considered relevant firms subject to financial sanctions reporting requirements: High Value Dealers (HVDs), Art Market Participants (AMPs), Letting Agents, and Insolvency Practitioners. (See the relevant Guidance)


Thursday, May 15

  • OFAC published General License 124 authorizing transactions to Russian petroleum services, banned under Executive Order 14701, that are related to the Caspian Pipeline Consortium and the Tengizchevroil project without time limitations. (Here)Concurrently, OFAC published an update to FAQ 1216 that explains the changes made by the General License 124. (Here)

  • OFAC imposed blocking sanctions on four individuals for their role in coordinating financial transfers to Hizballah, a Specifically Designated Global Terrorist. Action taken under Executive Order 13224. (Here, the Department of the Treasury press release, and the Department of State press release)

  • The UK Minister for Europe publishes a cross-government review of sanctions implementation and enforcement in the United Kingdom. The report details ways to improve and facilitate compliance, increase the deterrence effect of enforcement, and invigorate the cross government toolkit across the different Government stakeholders. (Here) 

  • The UK’s Export Control Joint Unit (ECJU) of the Department for Business and Trade (DBT) published 2024 statistics on standard individual export licenses (SIELs). For all of 2024, 11,415 SIEL decisions were made, of which 95% were approved. (Here the Official Statistics)


Friday, May 16

  • OFAC published a Memorandum of Understanding with Switzerland’s State Secretariat for Economic Affairs to enhance cooperation on sanctions enforcement through information sharing. (Here, and the Memorandum of Understanding) This is the second MOU OFAC signed with another country; the first one was with OFSI. 


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