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Last Week's Major Developments in Sanctions - September 22, 2025, to September 26, 2025

  • Writer: Amir Fadavi
    Amir Fadavi
  • Sep 30
  • 3 min read
You can now listen to the audio version of our weekly sanctions updates here.


Monday, September 22

  • This week started by EU Council extending its sanctions regime against Sudan for another year until 10 October 2026. (Decision, and press release)

  • The EU Council also removed names of six individuals from the list of sanctions targets under its Guinea-Bissau sanctions regime (here); removed one name from the list of sanctions targets under its Syria regime (here); and extended its Burundi sanctions regime for another year until 31 October 2026 while removing the name of one individual who was designated under Burundi sanctions regime of the EU (here).

  • The UK government published a "Starter Guide to UK Sanctions." (Here)

  • OFSI updated its Financial Sanctions General Guidance amending section 6.21 (HM Treasury debt exception) to clarify that the reference in the exception to an obligation owed by HM Treasury to a UN DP should also include an obligation owed by any other person to the UN DP in respect of HM Treasury debt. (Updated Guidance)

  • OFAC designated sanctioning the Lex Instituto de Estudos Juridicos LTDA and the head of the institute for their support to Brazilian Supreme Federal Court justice Alexandre de Moraes under OFAC global Magnitsky sanctions program. De Moraes was designated by OFAC on July 30, 2025. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFAC published an enforcement action in amount of $750,000 against ShapeShift AG, a digital asset exchange incorporated in Switzerland and operating from Colorado, for engaging in digital asset transactions on its exchange platform with users located in Cuba, Iran, Sudan, and Syria. (Here)


Tuesday, September 23


Wednesday, September 24

  • OFAC imposed blocking sanctions against two individuals and one entity in India under its counter narcotics sanctions program for their role in supplying counterfeit prescription pills filled with fentanyl and other illicit drugs to the United States. (Here, and the Department of the Treasury's press release)

  • OFAC published amended the Syria-Related Sanctions Regulations, 31 CFR Part 569, to, among other things, change the heading of the Syria-Related Sanctions Regulations to the Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations, and to implement Syria-related Executive Order 14142 and Syria-related Executive Order 14312 which relaxed the U.S. sanctions against Syria. (Here)


Thursday, September 25

  • OFSI imposed asset freezing sanctions against a British band and its label under the UK's counterterrorism regime for "promoting and encouraging terrorism via its dissemination of music whose content promotes and encourages terrorism." (Here)

  • OFAC imposed blocking sanctions against five individuals and one entity under its North Korea sanctions program for their role in generating illicit revenue for the DPRK government’s weapons of mass destruction and ballistic missile programs. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFSI published a full list of exceptions under its Russia sanctions regime in one place to facilitate compliance. (Here)


Friday, September 26

  • OFSI issued General Licence INT/2025/7328184 under all UK Autonomous Sanctions Regulations to allows Revenue Authority to make Permitted Payments to UK DPs’ Frozen UK Bank Accounts. (Here) OFSI also amended General Licences INT/2022/2104808, INT/2023/3179120, and INT/2022/2300292.

  • OFSI published three new FAQs (165, 166, and 167) to provide guidance regarding General Licences covering water, utility and banking bills and fees. (Here)

  • By a vote of 4 in favor (Algeria, China, Pakistan, Russian Federation) to 9 against (Denmark, France, Greece, Panama, Sierra Leone, Slovenia, Somalia, United Kingdom, United States), with 2 abstentions (Guyana, Republic of Korea), the Security Council failed to extend the Joint Comprehensive Plan of Action on Iran’s nuclear programme and resolution 2231 (2015) which endorsed it. As a result, the UN sanctions which were lifted under the JCPoA came back into force as of 27 September. More on this next week.



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