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Last Week's Major Developments in Sanctions - September 29, 2025, to October 3, 2025

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


Monday, September 29

  • Over the weekend the U.S. Secretary of State issued a press statement about the snapback of UN sanctions against Iran. (Here)

  • The Councils of the European Union re-imposed its sanctions against Iran. The EU went further than the UN imposed sanctions and adopted some autonomous sanctions measures as well. (Press release, and relevant decisions)

  • The Council of the European Union also extended its restrictive measures in view of the situation in Nicaragua by another year, until 15 October 2026. (Press release, and here)

  • The UK Government also took action to reimpose sanctions against Iran by introducing the Iran (Sanctions) (Nuclear) (EU Exit) (Amendment) Regulations 2025, which came into effect on September 30. OFSI also took steps to reimpose its nuclear sanctions against Iran by adding 71 new designations, issuing four general licenses (General licenses INT/2025/7363752, INT/2025/7345264, INT/2025/7345664 and INT/2025/7345464), issuing FAQ 168. (Press release)

  • OFAC issued General License 13O under its Russia sanctions program replacing an identical General License which was set to expire on October 9, 2025. (Here)

  • In a major shift, BIS issued an interim final rule introducing the Affiliate Rule, which is similar to 50% rule of OFAC. the Affiliate Rule applies to the Entity List, Military End User List, and certain SDNs. (Here) To find out more, check out this client alert from Steptoe.


Tuesday, September 30

  • With five enforcement actions on this, September 30 was one of the busiest days of sanctions and export control enforcement. Here are the actions:

    • OFSI <> Colorcon Limited: OFSI imposed a penalty of £152,750 on Colorcon Limited, a UK-registered company. The penalty was issued due to Colorcon's breaches of regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019, specifically for making funds available to designated persons. OFSI concluded that Colorcon had knowledge or reasonable cause to suspect their actions would make funds available to designated persons for payments made before the introduction of strict civil liability in June 2022. (Here)

    • BIS <> Hallewell Ventures Ltd: BIS issued an order approving a settlement between BIS and Hallewell Ventures, Ltd. and Albert Avdolyan for reexporting a Bombardier Global 7500 Aircraft from the Maldives to Russia without the required BIS license in March 2022. The Bombardier Global 7500 Aircraft is subject to the Regulations because it contains two U.S.-manufactured GE Passport turbofan engines classified under ECCN 9A991.c. As part of the settlement and Order, Respondents were assessed a civil penalty of $374,474.00. (Here)

    • BIS <> Luminultra Technologies, Inc.: BIS issued an Order approving a settlement between BIS and Luminultra Technologies Inc. for exporting three PhotonMaster luminometers and twenty-five aqueous test kits to Iran, all of which are categorized as EAR99 items that require authorization. The items were valued at $33,681.00. Additionally Luminultra Technologies made false and misleading representations, statements, and certifications, in connection with the submission of an Electronic Export Information filing. As part of the settlement and Order, Respondents were assessed a civil penalty of $685,051.00. (Here)

    • A dual citizen of Hungary and Spain who resided in the United Arab Emirates, was sentenced in U.S. District Court to 31 months in prison in connection with conspiring to illegally export U.S.-origin radio communications technology to Russian end users without a license. (Here)

    • Latvian national, Oleg Chistyakov, aka Olegs ÄŒitsjakovs, 56, pleaded guilty for his role in a years-long conspiracy to circumvent U.S. export laws by filing false export forms with the U.S. government and, after Russia’s invasion of Ukraine in February 2022, continuing to procure and sell sophisticated and controlled avionics equipment to customers in Russia without the required licenses from the U.S. Department of Commerce. (Here)


Wednesday, October 1

  • OFSI adding 121 new designations under its Iran Nuclear sanctions program. (Here, and press release)

  • OFAC imposed blocking sanctions against 21 entities and 17 individuals involved in networks that facilitate the acquisition of sensitive goods and technology for Iran’s Ministry of Defense and Armed Forces Logistics, as well as its missile and military aircraft production efforts. (Here, and the Department of the Treasury's press release)


Thursday, October 2

  • France imposed asset-freezing sanctions against two individuals under its autonomous counter-terrorism sanctions. (Here)


Friday, October 3

  • France imposed asset-freezing sanctions against two individuals under its autonomous counter-terrorism sanctions. (Here)

  • The Council of European Union decided to extend individual restrictive measures against those responsible for Russia’s destabilising actions abroad by one year, until 9 October 2026. (Press release)

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