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

  • Writer: Amir Fadavi
    Amir Fadavi
  • 6 minutes ago
  • 2 min read
You can now listen to the audio version of our weekly sanctions updates here.


Monday, November 24

  • OFAC has issued a Penalty Notice imposing a $4,677,552 penalty on a natural U.S. Person for two violations of OFAC’s Russia sanctions and for failing to comply with an OFAC subpoena. The facts of the case are interesting since it shows how a transfer of a blocked property is considered null and void, and the importance of OFAC's notices. OFAC considered the violations egregious and the amount of penalty is almost 10 times the amount made as a result of the violations. (Here)

  • The EU Council designated DRC's "Allied Democratic Forces" under its ISIL and Al-Qaeda sanctions regime. (Here) The group was already designated under the EU's DRC sanctions regime.

  • The EU Council extended its restrictive measures in view of Türkiye’s unauthorized drilling activities in the Eastern Mediterranean for another year until 30 November 2026 and removed the name of the only remaining designated person under this sanctions regime. (Here)


Tuesday, November 25

  • There was no major development on this day.


Wednesday, November 26

  • There was no major development on this day.


Thursday, November 27

  • OFSI published a look-up guide in one place listing all considerations for trade licenses for certain prohibitions under its Russia sanctions. (Here)

  • OFSI published General License INT/2025/8031092, for continuation of business of Lukoil International GmbH and its subsidiaries. (Here) Concurrently, OFSI published FAQ 174 to provided additional guidance regarding the new General License. (Here)


Friday, November 28

  • OFSI amended General License INT/2022/2349952 to reflect changes to Schedule 3E Part 2A of the Russia Regulations, expanding the definition of fertilizer to include those permitted under commodity code 2814 and its subheadings. (Here)

  • In an AML-related development, FinCEN issued an alert on "Cross-Border Funds Transfers Involving Illegal Aliens." The alert reminds Money Service Business that they must report cross-border transactions above USD 2,000 derived from unlawful employment or otherwise derived from funds the MSB knows, suspects, or has reason to suspect were illicitly obtained in the United States by illegal aliens. (Here)

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