Last Week's Major Developments in Sanctions - October 20, 2025, to October 24, 2025

Following the designation of the UNSC, OFSI designated two individuals under its Haiti sanctions regime. (Here)
The EU Council extended its Niger sanctions regime for another year until 24 October 2026. (Here)

OFSI published General License INT/2025/7598960, allowing UK persons to continue business operations involving Rosneft Deutschland GmbH, RN Refining & Marketing GmbH; and entities owned or controlled, directly or indirectly, by them. OFSI also added FAQ 169 clarifying the new General License. (General License and FAQ)
OFSI imposed asset freezing sanctions against 12 individuals and one entity under the Global Irregular Migration and Trafficking in Persons sanctions regime. (Here, and press release)
OFSI published General License NT/2025/7323088 allowing UK legal firms or UK counsels, who has provided legal advice to a person designated under the UK Autonomous Sanctions Regimes listed in Annex 1 of the License to receive payment from that designated person without an OFSI specific license. (Here)
In a major shift in the Trump's administration sanctions policy, OFAC imposed blocking sanctions Rosneft and Lukoil. (Here, and the Department of the Treasury's press release) To learn more about this action, see the alert I wrote on K2 Integrity's website.

OFSI published General License INT/2025/7628424 under its Iran sanctions regime allowing designated persons to make payments for remuneration, allowances, and
contractual or statutory redundancy payments to UK employees and UK directors, pensions of UK employees, fees and others costs relating to provision of IT services, and fees or other costs related to the provision of UK chartered or certified accountancy services. (Here)
The EU adopted its 19 sanctions package against Russia. The new package includes several additional designations and many new restrictions. The new package also targeted Belarus. (Relevant Decisions and Regulations, and press release)
FinCEN issued a Financial Trend Analysis (FTA) identifying approximately $9 billion of potential Iranian shadow banking activity that occurred through U.S. correspondent accounts in 2024, based on reporting from U.S. financial institutions. (Here)

OFSI published two new FAQs, 170 and 171, and withdrew two FAQs, 54 and 76. (Here)
OFAC imposed blocking sanctions on Gustavo Francisco Petro Urrego, the President of Colombia, pursuant to U.S. counternarcotics-related authorities. In addition, OFAC imposed blocking sanctions on his wife, his son, and a close associate. (Here, and the Department of the Treasury's press release)

Recent Posts