Tabla de contenidos
European Union
Russia
On 20 November, Council Implementing Regulation (EU) 2025/2356, which implements Regulation (EU) 2024/1485 adopting restrictive measures in view of the situation in Russia, and Council Decision (CFSP) 2025/2357 amending Decision (CFSP) 2024/1484 concerning restrictive measures in view of the situation in Russia, were adopted.
These two new regulations update the list of natural persons to whom the restrictive measures apply.
By means of these two new regulatory instruments, the list of natural persons subject to restrictive measures is updated. Specifically, nine individuals are added following the assessment that they may have been involved in Human Rights violations.
The conduct attributed to them, which justifies their inclusion on the list, includes acts of torture and inhuman or degrading treatment, as well as the imposition of politically motivated sentences on opposition figures, thereby undermining the exercise of fundamental rights, including freedom of expression.
Turkey
On 24 November 2025, the Council adopted Implementing Regulation (EU) 2025/2396, which implements Regulation (EU) 2019/1890 concerning restrictive measures in view of Turkey’s unauthorised drilling activities in the Eastern Mediterranean and Council Decision (CFSP) 2025/2395 amending Decision (CFSP) 2019/1894 concerning restrictive measures in view of Turkey’s unauthorised drilling activities in the Eastern Mediterranean.
This Council Decision extends the restrictive measures agreed against Turkey as a result of its drilling activities in the Eastern Mediterranean, specifically in waters that the Republic of Cyprus considers its own, until 30 November 2026.
These restrictive measures involve the freezing of assets and a travel ban on certain natural persons or entities directly involved in, responsible for or supporting these drilling activities that have not been authorised by Cyprus in its territorial sea, exclusive economic zone or continental shelf.
The Council expressed its concern about these illegal activities, which threaten hydrocarbon exploration and production in the region, in line with the support that the Union has shown with the Republic of Cyprus. According to the Council, these restrictive measures are intended to prevent Turkey from continuing these practices, which jeopardise maritime delimitation agreements under international law.
ISIL (Daesh) and Al-Qaida
On 24 November 2025, Council Implementing Regulation (EU) 2025/2401 was adopted, implementing Regulation (EU) 2016/1686 imposing additional restrictive measures against ISIL (Daesh) and Al-Qaida, as well as natural or legal persons, entities or bodies associated with them, and Council Decision (CFSP) 2025/2398 amending Decision (CFSP) 2016/1693 imposing restrictive measures against ISIL (Daesh) and Al-Qaida and persons, groups, undertakings and entities associated with them.
The Decision and the Implementing Regulation include the Allied Democratic Forces in Annex I, as they are alleged to have cooperated with Daesh and Al-Qaeda.
Furthermore, the Council of the European Union adopted Regulation (EU) 2025/2397, amending Regulation (EU) 2016/1686, imposing additional restrictive measures against ISIL (Daesh) and Al-Qaida, as well as natural or legal persons, entities or bodies associated with them, and Council Decision (CFSP) 2025/2398, amending Decision (CFSP) 2016/1693 imposing restrictive measures against ISIL (Daesh) and Al-Qaida and persons, groups, undertakings and entities associated with them.
This Decision and Regulation suspend paragraphs 1 and 2 of Article 6 of Regulation (EU) 2016/1686 in relation to the Allied Democratic Forces, as paragraphs 1 and 2 of Article 2 of Council Regulation (EC) No. 1183/2005, which freezes the funds and economic resources of those natural and legal persons listed in Annex I, already apply to them.
In addition, on 5 November, Commission Implementing Regulation (EU) 2025/2276 was adopted, amending Council Regulation (EC) No 881/2002, which imposes certain specific restrictive measures directed against certain persons and entities associated with ISIL (Daesh) and Al-Qaida.
On 12 November, Commission Implementing Regulation (EU) 2025/2327 was adopted, amending for the 353rd time the Council Regulation (EC) No 881/2002, which imposes certain specific restrictive measures directed against certain persons and entities associated with ISIL (Daesh) and Al-Qaida.
These Implementing Regulations, dated 5 and 12 November respectively, updated the identification details of one person of Egyptian origin and lifted the restrictive measures against two persons of Syrian origin.
Taken together, these Regulations of 5 and 12 November update the list of natural persons subject to asset freezes and other sanctions, by correcting the identifying details of one individual and removing two individuals from the sanctions regime. This action forms part of the ongoing process of review and maintenance of the EU’s autonomous counter-terrorism sanctions list.
Sudan
On 20 November 2025, Council Implementing Regulation (EU) 2025/2368, which implements Regulation (EU) 2023/2147 concerning restrictive measures in view of actions undermining the stability and political transition of Sudan. It was also adopted the Council Decision (CFSP) 2025/2369, which amends Decision (CFSP) 2023/2135 ,concerning restrictive measures in view of actions undermining stability and the political transition in Sudan.
With these new regulations, a new individual associated with the Rapid Support Forces (RSF) in Sudan has been added to the list of natural persons subject to restrictive measures.
United States
Russia
On 19 November 2025, the Office of Foreign Assets Control of the US Department of the Treasury (hereinafter ‘OFAC’), together with Australia and the United Kingdom, sanctioned Media Land, a Russian provider of bulletproof hosting services. These bulletproof hosting services are specialised web hosting providers that offer servers and other computing resources designed to resist attempts at blocking or removal by authorities or traditional service providers.
These hosting services are specialized web-hosting providers offering servers and other computing resources designed to withstand attempts at blocking or removal by authorities or traditional service providers. They are regarded as “bullet-proof” in that they host and protect illicit content or activities — such as malware, ransomware, cyber-attacks and other types of online criminal behaviour — thereby hindering detection and intervention by law-enforcement agencies or legitimate providers.
In this context, the entity Media Land was sanctioned for facilitating ransomware operations and other cyber-crimes. Media Land, based in Saint Petersburg, has reportedly enabled ransomware attacks by groups such as LockBit, BlackSuit and Play, as well as distributed-denial-of-service (DDoS) attacks against critical infrastructure in the United States, according to the US Treasury Department. Three members of its management team and three affiliated companies were also designated.
Its subsidiary companies, Media Land Technology and Data Center Kirishi, were likewise sanctioned.
Moreover, natural persons associated with the company’s management have been added to the list.
These sanctions freeze all assets in the United States and prohibit transactions with the designated individuals and entities, unless the Government issues an express licence to that effect.
Burma
On 12 November 2025, OFAC sanctioned the Burmese armed group Democratic Karen Benevolent Army (DKBA), as well as four of its leaders and their associated companies, for supporting cyber fraud centres in Burma, of which US citizens have been victims. According to OFAC, these networks finance illicit activities and contribute to the financing of the civil conflict in Burma.
OFAC also sanctioned Trans Asia International Holding Group and Troth Star Company, companies linked to Chinese organised crime that collaborate with the DKBA and other armed groups in the development of these scam centres.
In collaboration with the FBI and the Washington District Attorney’s Office, OFAC also announced the creation of a Task Force to combat these scam centres in Southeast Asia, with a particular focus on Burma, Cambodia and Laos. This task force seeks to investigate, disrupt and prosecute those responsible for these activities.
The sanctions include the freezing of assets and the prohibition of financial transactions by designated entities and individuals, with the aim of curbing the threat to US national and economic security.
Iran
On 20 November 2025, OFAC sanctioned a network of companies that finance the Iranian armed forces through the sale of crude oil.
OFAC also sanctioned six ships that are part of the fleet used by Iran to transport its oil, thereby increasing costs for Iranian exporters and reducing their revenues.
In addition, measures were taken against Mahan Air for collaborating with the Islamic Revolutionary Guard Corps to arm and supply terrorist groups in the Middle East.
The sanctions include the freezing of assets and a ban on transactions for all individuals and legal entities, as well as their cooperators and financiers, who participate in these activities.
Hizballah-Lebanon
On 6 November 2025, OFAC sanctioned financial entities used by Hizballah that channel tens of millions of dollars from Iran through currency exchange offices, taking advantage of Lebanon’s cash-based economy. These funds finance Hizballah’s paramilitary forces, the reconstruction of its terrorist infrastructure, and its resistance to the Lebanese government’s efforts to control the entire territory.
Since January 2025, according to OFAC, the Quds Force of the Islamic Revolutionary Guard Corps (IRGC-QF) has transferred more than $1 billion to Hezbollah through these exchange houses, laundering illicitly sourced capital. Three individuals have been sanctioned for assisting in the collection of money for Hezbollah.
These sanctions are covered by Executive Order 13224 to combat terrorism and seek to cut off the financial resources that sustain Hezbollah. The property and assets of individuals and entities that have been designated by the US or are under the control of US citizens are blocked, and transactions with them are prohibited unless expressly authorised.
Venezuela
On 24 November 2025, the US Department of State designated the “Cartel de los Soles” as a Foreign Terrorist Organisation (FTO).
This cartel, based in Venezuela, is allegedly led by Nicolás Maduro and other senior officials of the Bolivarian regime, according to OFAC. In July 2025, the “Cartel de los Soles” was sanctioned for providing support to other drug trafficking organisations in the region.
They are accused of corrupting the country’s military, intelligence, legislative, and judicial forces. According to OFAC, the “Cartel de los Soles”, along with other designated terrorist organisations such as “Tren de Aragua” and the Sinaloa Cartel, are responsible for terrorist violence in the region and drug trafficking to the United States and Europe.
United Kingdom
Russia
On 19 November 2025, the Foreign, Commonwealth and Development Office updated the UK Sanctions List, which contains details of individuals designated under these regulations.
The Russia (Sanctions) Regulations 2019 were established under the Sanctions and Anti-Money Laundering Act 2018. This regulation allows financial sanctions, such as asset freezes and transaction bans, to be imposed on individuals involved in the destabilisation of Ukraine or who undermine or threaten the territorial integrity, sovereignty or independence of Ukraine, or who derive benefits from or support the Russian Government.
With the update of this list, a new entity has been added. The British Secretary of State considers that there are grounds for suspecting that this is a “person involved” under the Russia (Sanctions) Regulations 2019, due to its involvement in the destabilisation of Ukraine through the provision of technological services, specifically “bulletproof hosting” services, which contribute to destabilising Ukraine and undermining its territorial integrity, sovereignty and independence.
As mentioned above, “bulletproof hosting” services are specialised web hosting services that provide servers and computing resources specifically designed to resist attempts at disconnection or blocking by authorities or legal providers. These services protect and enable the continuity of websites or online activities that are often linked to the dissemination of malware, ransomware, cybercrime operations or scams. This hinders investigations and the removal of such content.
United Nations
Syria
On 6 November 2025, the UN Security Council, through Resolution 2799/2025, took the decision to lift the sanctions previously imposed on Syrian President Ahmad Al Sharaa.
Until then, he had been included on the Sanctions List against ISIL (Daesh) and Al-Qaeda. This measure responds to political developments in Syria, which reflect a change in the country’s situation. The lifting of these sanctions is part of an international process that seeks to facilitate stability and political dialogue in the region, in line with the international community’s desire to support a peaceful resolution to the Syrian conflict.
In this context, on 10 November 2025 a meeting took place at the White House between the Syrian President, Ahmed al-Sharaa, and the President of the United States, Donald J. Trump, during which a peace plan for Gaza and the wider region was presented. This plan was subsequently endorsed by the United Nations Security Council as a framework aimed at reducing tensions and promoting a lasting reconciliation in the area.
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In Madrid, 30 November 2025
International Trade and Sanctions Department
Lupicinio International Law Firm
