Last Week's Major Developments in Sanctions - November 17, 2025, to November 21, 2025

Over the weekend, the U.S. Department of State announced its intent to designate Venezuela-based Cartel de los Soles, which is headed by Nicolás Maduro, as a Foreign Terrorist Organization, effective November 24, 2025. (Here)

In a coordinated action Australia, the United States, and the Unite Kingdom imposed sanctions against Russia-related cyber criminals. Specifically:
- OFSI imposed asset freezing sanctions against four individuals and two entities under the UK's cyber sanctions regime. (Here, and press release)
- OFAC imposed blocking sanctions against five individuals and seven entities under the the U.S. cyber sanctions program and CAATSA. (Here, and the Department of the Treasury's press release)
- Australia imposed asset freezing sanctions against two individuals and two entities under its autonomous cyber sanctions. (Here)
OFAC imposed blocking sanctions against 10 individuals and nine entities under its counter narcotics sanctions program. (Here, the Department of the Treasury's press release, and the Department of State rewards offer)
OFAC published FAQ 1224 to clarify the scope of General License (GL)131 under Russian Harmful Foreign Activities Sanctions Regulations. (Here) Notably, the FAQ explains that GL 131 does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset; and that any contract entered into pursuant to GL 131 must expressly be made contingent upon the receipt of a separate authorization from OFAC.

The EU Council imposed asset freezing sanctions against:
- One individual under the Union's Sudan sanctions regime; (Here) and
- 10 individuals under its Russia sanctions regime. (Here)
OFSI amended General Licence INT/2025/7895596 to extend it to the following subsidiaries of Lukoil: Lukoil Aviation Bulgaria EOOD; and Lukoil Bunker Bulgaria EOOD. (Here) Subsequently, OFSI amended its FAQ 173.
OFAC imposed blocking sanctions against 14 individuals, 24 entities, 10 vessels, and seven aircraft under its Iran program for being involved in trade of Iranian oil. (Here, the Department of the Treasury's press release, the Department of State's press release and fact sheet)
U.S. Department of Justice brought charges against two U.S. citizens and two nationals of the People’s Republic of China (PRC)—all residing in the United States—for alleged conspiracy to illegally export cutting-edge NVIDIA Graphics Processing Units, which have artificial intelligence applications, to the PRC. (Here)

OFAC issued Russia-related General License 132, "Authorizing Certain Transactions Involving Paks II Civil Nuclear Power Plant." (Here)