Last Week's Major Developments in Sanctions - May 19th, 2025, to May 23rd, 2025

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Monday, May 19

• There was no major development on this day.

Tuesday, May 20

• The European Council adopted 17th sanctions package against Russia that includes six Council Decisions:

  • Council Decision (CFSP) 2025/931 which amended Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine by:

    • Adding 31 new entities to the list of natural or legal persons, entities or bodies set out in Annex IV to Decision 2014/512/CFSP, namely the list of persons, entities and bodies supporting Russia’s military and industrial complex in its war of aggression against Ukraine and as such are subject to a stringent export controls;

    • Expanding the list of items which might contribute to Russia’s military and technological enhancement, including chemical precursors to energetic materials and spare parts for machine tools;

    • Extending the duration of an exemption from the oil price cap of crude oil originating from the Sakhalin-2 Project in Russia to Japan; 

    • Adding 189 vessels to the list of vessels banned in Member States. (Here, and press release)

  • Council Decision (CFSP) 2025/936 imposed asset-freezing sanctions against 17 individuals and 58 entities responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. (Here)

  • Council Decision (CFSP) 2025/957 imposed asset-freezing sanctions against additional 28 individuals for human rights violations and repressions in Russia. (Here, and press release)

  • Council Decision (CFSP) 2025/960 imposed asset-freezing sanctions against three entities for the continued threat posed by the proliferation and use of chemical weapons.. (Here, and press release)

  • Council Decision (CFSP) 2025/963 and 2025/966, among other things, imposed asset-freezing sanctions against 21 individuals and six entities for their role in directing malign activities against the Union, its Member States, international organisations and third countries. The Council also introduced a prohibition on transactions of credit institutions, financial institutions and entities providing crypto-assets services that directly or indirectly facilitate activities by, persons, entities or bodies engaged in Russia’s destabilising activities (Here, and here, and press release)

• OFSI imposed asset-freezing sanctions against 20 individuals, 62 entities, and 18 vessels under the UK sanctions regime against Russia. These sanctions target Russian revenue generating sectors, including energy, communications and financial services, the Russian military industrial complex and its third country suppliers, and malign actors involved in democratic interference and Russia’s information war on Ukraine. (Here, and the UK government press release)

• Concurrently, OFSI issued two General Licenses authorizing wind-down transactions with two of the designated entities, and transactions related to the insurance premiums due to the Deposit Insurance Agency, an entity which was designated on this day. Specifically: 

  • General License INT/2025/6275812 authorizes to wind down from any transactions involving St. Petersburg Currency Exchange and non-bank Credit Organization Joint-Stock Company Petersburg Settlement Center. (Here)

  • General License INT/2025/6279615 allows for persons to make insurance premium payments to the State Corporation Deposit Insurance Agency. (Here) 

• OFSI imposed asset-freezing sanctions against three Israeli nationals and four entities that have supported, incited and promoted violence against Palestinian communities in the West Bank pursuant to the UK’s global human rights sanctions regime. (Here, and the UK government press release)

• OFAC issued Iran-related General License Q, authorizing limited safety, environmental, and sale transactions involving the blocked vessel M.V. Tinos I while located in the United States. (Here, and the General License) If you want to know more about the underlying vessel, check out this article by Lloyd’s List: How an LPG tanker’s maiden voyage ended with the US sanctioning a sprawling Iranian gas network

• The EU Council issued a statement on the lifting of sanctions against Syria announcing the political decision to lift its economic sanctions on Syria. (Here)

Wednesday, May 21 

• OFAC imposed blocking sanctions against two high-ranking members of the Mexico-based Cártel del Noreste (CDN), formerly known as Los Zetas for their role in drug trafficking, arms trafficking, and acts of violence. Sanctions imposed under Executive Order 14059 and 13224. The cartel is a designated Foreign Terrorist Organization and Specially Designated Global Terrorist involved in drug trafficking, kidnapping, extortion, migrant smuggling, and other illicit activities. (Here, the Department of State press release, and the Department of the Treasure press release) 

• OFAC removed a former Venezuelan official and a business person from its SDN list. (Here) No official public comment was made explaining the reason behind these removals. 

• As part of the Maximum Pressure Campaign against Iran, the Department of State identified the Iranian construction sector as being controlled directly or indirectly by the Islamic Revolutionary Guard Corps (IRGC) which means any person that knowingly sells, supplies, or transfers, directly or indirectly, to or from Iran, raw and semi-finished metals, graphite, coal, and software for integrating industrial purposes will be subject to “mandatory sanctions” if those materials are to be used in connection with the Iranian construction sector. The Department of State also identified 10 strategic materials Iran is using in connection with its nuclear, military, or ballistic missile program. The newly designated materials are: austenitic nickel-chromium alloy, magnesium ingots, sodium perchlorate, EDM-11, EDM-14A, EDM-15, tungsten copper, AA2024-T351 aluminum sheets and/or tubes, ISO-68, ISO-69; and any person that knowingly sells, supplies, or transfers, directly or indirectly, these materials to or from Iran (regardless of end-use or end-user) will now be subject to “mandatory sanctions.”  These actions were taken pursuant to Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012. (Department of State press release, and the Department of State fact sheet)

• OFSI extended General License INT/2022/1834876, issued on May 30, 2022 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 until 30th May 2028.  The General License allows for interim managers and trustees of sanctioned charities to act as receiver(s) and manager(s) in respect of the property and affairs of a charity. It covers payments for basic needs of operation of charities and routine holding and maintenance of frozen funds or economic resources and the payment of legal fees, receipt and disbursement of charitable funds, and payments associated with the wind up of a charity. (Here) 

• The UK Government introduced the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 to Parliament that will enter into force on June 26, 2025. The legislation will extend whistleblower protections when disclosing information about financial, transport, and certain trade sanctions to the relevant government department. (Here) To that end, OTSI added a “Whistleblowing for trade sanctions” to its website. (Here)

Thursday, May 22

• The U.S. Department of State determined that the Government of Sudan used chemical weapons in 2024 and is in non-compliance with the Chemical Weapons Convention, to which it is a party. As such, following a 15-day Congressional notification period, the United States will impose sanctions on Sudan on June 6. (Here)

Friday, May 23

• Following an announcement by President Trump last week OFAC, the United States started to lift sanctions against Syria. Specifically, sanctions imposed on Syria.

  • OFAC issued Syria General License 25 authorizing a wide range of transactions that were previously not allowed for the U.S. persons. (Here, and the Department of the Treasury press release)

  • The Secretary of State issued a 180-day waiver of mandatory Caesar Syria Civilian Protection Act of 2019 sanctions. The waiver will facilitate the provision of electricity, energy, water, and sanitation, and enable a more effective humanitarian response across Syria. (Here)

  • FinCEN provided an exception to prohibition imposed by section 311 of the USA PATRIOT Act against the Commercial Bank of Syria. (Here)

• OFAC published another video in its “Basic Video Series;” This time about requesting OFAC guidance. (Here)