Last Week's Major Developments in Sanctions - September 1, 2025, to September 5, 2025

Australia imposed asset-freeze sanctions against 14 14 individuals responsible for silencing political expression in Russia, as well as enabling the illegal and immoral invasion of Ukraine. (Here, and press release)
OFAC imposed blocking sanctions against an individual, seven entities, and nine vessels constituting a network of shipping companies and vessels for smuggling Iranian oil disguised as Iraqi oil. (Here, the Department of the Treasury's press release, and the Department of State's press release)
DOJ published a press release regarding an Armenian national who made his initial appearance in a federal court in Austin after he was indicted and extradited on charges related to an alleged export control conspiracy. According to court documents, from February 2022 until at least August 2024, the defendant and others allegedly participated in a criminal conspiracy to export goods, including items that can be used for semiconductor manufacturing, from the United States to the Russian Federation through the Republic of Armenia without the requisite license or authorization from the U.S. Department of Commerce, Bureau of Industry & Security. (Here)

OFSI imposed asset-freeze sanctions against 8 individual and 3 organizations under its Russia sanctions regime for supporting Putin’s attempts to forcibly deport and indoctrinate Ukraine’s children and erase their Ukrainian cultural heritage. (Here, and press release)
OFAC imposed blocking sanctions against one entity and two individuals under its counter-narcotics program for involvement in the manufacture and sale of synthetic opioids to Americans. (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFAC announced a settlement agreement with Fracht FWO Inc., an international freight forwarder. The settlement for $1,610,775 settles Fracht's potential civil liability for apparent violations of multiple OFAC sanctions programs, including those on Venezuela and Iran. The facts of the case are rather unusual and shows how several things may go wrong for a company. (Here)

The Department of State designated Los Choneros and Los Lobos as Foreign Terrorist Organizations and Specially Designated Global Terrorists. (Here)
The Department of State imposed blocking sanctions on three NGOs under the U.S. International Criminal Court (ICC) sanctions program for directly engaging in efforts by the ICC to investigate, arrest, detain, or prosecute Israeli nationals, without Israel’s consent. (Here, and the Department of State's press release)

The Council of the European Union imposed asset-freeze sanctions against the head and deputy head of the Directorate of the Russian Federal Penal Enforcement Service for the 'Republic of Crimea and the City of Sevastopol under the EU human rights sanctions regime. (Here, and press release)
FinCEN published a guidance on Cross-Border Information Sharing by Financial Institutions and SAR Confidentiality. The guidance objective is to: (i) clarify that the Bank Secrecy Act and its implementing regulations generally do not prohibit crossborder information sharing;1 and (ii) provide examples of information that typically would not reveal the existence of a Suspicious Activity Report and, thus, that the BSA does not prohibit sharing. (Here)
The President the United States issued an executive order to Strengthen Efforts to Protect U.S. Nationals from Wrongful Detention Abroad. The order create a new category of countries as "State Sponsor of Wrongful Detention." If designated as such, the designated country could be subject financial sanctions, export restrictions, or travel bans. (Executive Order, the White House Fact Sheet, the Department of State's press release)

Our founder, Amir Fadavi, will speak at the 5th Annual AML and OFAC Symposium hosted by the ACAMS Carolinas Chapter. If you are in Charlotte on September 30, come say hi.