Last Week's Major Developments in Sanctions - September 8, 2025, to September 12, 2025

OFSI published an enforcement actions with no monetary penalty against Vanquis Bank Limited. The breaches occurred due to a delay in restricting access to an account for eight days following designation, during which time a designated person was able to have full access to their funds. (Here)
FinCEN published a Notice to help financial institutions detect and disrupt financially motivated sextortion. (Here)
FinCEN reissued a modified Geographic Targeting Order (GTO) to combat illicit cartel and other criminal activity, including money laundering, along the southwest border of the United States. As modified, the GTO requires certain money services businesses to file Currency Transaction Reports with FinCEN for cash transactions between $1,000 and $10,000 occurring in specific counties and ZIP codes. The previous GTO required reporting of transactions in currency of more than $200, but not more than $10,000. (Here)
OFAC imposed blocking sanctions against seven individuals and 12 entities under its Transnational Criminal Organizations, Burma-related, Global Magnitsky, and Cyber-related Designations for being part of a network of scam centers across Southeast Asia that steal billions of dollars from Americans using forced labor and violence. (Here, the Department of the Treasury's press release, and the Department of State's press release)

France imposed asset-freezing sanctions against one individual under its counter-terrorism sanctions regime. (Here)

OFSI amended General licenses INT/2024/4888228, and INT/2024/4907888 to include the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025.
OFAC imposed blocking sanctions against 11 individuals, 21 entities, and four vessels under its counter-terrorism sanctions program for being part of the Houthis’ global illicit fundraising, smuggling, and weapons procurement operations. Among the designated entities were Houthi-associated companies China, the United Arab Emirates, and the Marshall Islands. (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFAC issued General License 11 under its Belarus sanctions program authorizing all transactions prohibited by the Belarus Sanctions Regulations involving Open Joint Stock
Company Belavia Belarusian Airlines, or any entity in which Belavia owns, directly or indirectly, a 50 percent or greater interest. (Here)

OFSI imposed asset-freezing sanctions against three individuals and 27 entities under its Russia sanctions regime. The UK government also sanctioned 70 shadow vessels carrying Russian oil exports. (Here, and press release)
The Council of European Union extended one of the main pieces of its sanctions regime against Russia for another six months, until 15 March 2026. (Here, and press release)
OFAC imposed blocking sanctions against one individual and one entity under its Sudan sanctions program for their involvement in Sudan’s brutal civil war and their connections to Iran. (Here, the Department of the Treasury's press release, and the Department of State's press release)