European Union

IRAN

• On 4 April 2025 the Council of the European Union adopted Implementing Regulation (EU) 2025/689, which implements Regulation (EU) No 359/2011, concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Iran.​

This regulation provides for additional restrictive measures, including a freezing of funds and a prohibition on making funds available, against Iranian individuals and entities involved in activities that contravene UN Security Council resolutions, such as the development of nuclear and ballistic missile programmes.​

• On 4 April 2025, the Council of the European Union adopted Decision (CFSP) 2025/690 amending Decision 2011/235/CFSP concerning restrictive measures directed against certain persons and entities in view of the situation in Iran.

This amendment extends the list of persons and entities subject to restrictive measures, including a freezing of funds and a ban on entry into the EU, in response to activities that contravene UN Security Council resolutions. The Decision also establishes procedures for updating the list and the possibility to submit requests for authorisation to use frozen funds for essential needs.

• On 14 April 2025, the Council of the European Union adopted Implementing Decision (CFSP) 2025/774, which implements Decision 2011/235/CFSP concerning restrictive measures directed against certain persons and entities in view of the situation in Iran.

This decision extends the list of persons and entities subject to restrictive measures, such as a freezing of funds and a ban on entry into the EU, in response to activities that contravene UN Security Council resolutions. In the words of the Council of the European Union, serious violations of human rights in Iran were committed.

The measures also cover individuals and entities associated with the Islamic Revolutionary Guard Corps (IRGC) and other organisations involved in destabilising activities in the region.

• On 14 April 2025, the Council of the European Union adopted Implementing Regulation (EU) 2025/776, which implements Regulation (EU) No 359/2011 concerning restrictive measures against Iran for serious human rights violations.

The move adds seven individuals and two entities to the list of sanctioned individuals, including judges, prosecutors and prison directors implicated in torture, arbitrary executions and inhumane detention conditions. The sanctioned entities include the Shiraz Central Prison and the First Branch of the Shiraz Revolutionary Court, both responsible for the systematic repression of dissidents .and minorities..

The sanctions consist of an asset freeze and a ban on entry into the EU and on making funds or economic resources available to listed persons or entities as well, as a ban on the export to Iran of equipment which might be used for internal repression and monitoring telecommunications equipment. These sanctions have been imposed under the EU’s Comprehensive Human Rights Sanctions Regime.

RUSSIA

• On 7 April 2025, the Council of the European Union adopted Implementing Regulation (EU) 2025/701, which implements Regulation (EU) 2025/395, amending Regulation (EU) No 833/2014 concerning restrictive measures motivated by actions of Russia destabilising the situation in Ukraine.

This regulation provides for additional restrictive measures against Russian individuals and entities involved in activities that contravene UN Security Council resolutions, such as the development of nuclear and ballistic missile programmes.

The measures include, among others, restrictions on specific economic sectors, limitations on  financial transactions and travel restrictions for persons involved in activities that undermine the territorial integrity, sovereignty and independence of Ukraine.

• On 7 April 2025, the Council of the European Union adopted Decision (CFSP) 2025/700 concerning restrictive measures in response to actions by Russia which destabilise the situation in Ukraine.

This decision amends decision 2011/235/CFSP, extending the list of persons and entities subject to restrictive measures, such as a freezing of funds and a ban on entry into the EU. The new designations include individuals and entities responsible for activities that contravene UN Security Council resolutions, such as the development of nuclear and ballistic missile programmes.

The measures taken include asset freezes and travel bans to the European Union for designated individuals and entities. These sanctions apply at EU level and are binding on all Member States.

MYANMAR / BURMA

• On 29 April 2024, the Official Journal of the European Union published Council Decision (CFSP) 2024/1250, adopted on 26 April 2024, amending Decision 2013/184/CFSP concerning restrictive measures in view of the situation in Myanmar/Burma.

This Council Decision extends the validity of the restrictive measures until 30 April 2025 and introduces updates to the data concerning nineteen individuals included in the list of natural persons subject to these sanctions. These changes respond to developments in Myanmar/Burma, which remain worrying, with developments that undermine democratic order and constitute serious violations of human rights.

On 24 April 2025, a corrigendum to Decision (CFSP) 2024/1250 was published, amending Article 12. The new text clarifies that the derogations set out in Articles 6(7) and 6a (1), in conjunction with Articles 6(1) and (2), shall be subject to periodic review at least once every twelve months, or immediately upon request by any Member State, the High Representative or the Commission, in the event of a substantial change of circumstances was published.

This amendment is intended to strengthen the monitoring and frequency of review of the applicable derogations, ensuring that they are consistent with the aims pursued by the European Union with regard to the situation in Myanmar/Burma.

 

United States

RUSSIA

• On 2 April 2025, the US Treasury Department’s OFAC published a quarterly report on licensing activities for exports to Iran, such as agricultural and medical products. In addition, the list of Specially Designated Nationals (SDNs) was updated, sanctioning individuals and entities linked to the Houthis in Yemen, such as Hushang and Sohrab Ghairat, businessmen working with Sa’id al-Jamal, a senior Houthi official. Also sanctioned were AM Asia M6 Ltd, owner of a ship carrying stolen grain from Crimea to Yemen, and Russian captains Vyacheslav Vidanov and Yuri Belyakov. These sanctions seek to curb Houthi activities in the region and block funds related to their procurement network.

IRAN

• On 1 April 2025, the US Treasury Department and the Department of Justice imposed sanctions on an international network that facilitated the procurement of attack drone components for Iran. The network operated in Iran, the United Arab Emirates, and China, and provided technology to key companies in the Iranian military sector, including Qods Aviation Industries and Iran Aircraft Manufacturing Industrial Company. Criminal charges were brought against Hossein Akbari and Reza Amidi for their involvement in supplying US technology for Iranian drones. The sanctions include an asset freeze and a ban on transactions with the designated entities and individuals.
• On 9 April 2025, the US Treasury Department imposed sanctions on five entities and one individual in Iran for their support of key nuclear programmes. The designations include TESA, which is responsible for the production of centrifuges for uranium enrichment, and other entities such as Atbin Ista, which facilitated the procurement of components for TESA, and Pegah Aluminum Arak, which manufactures aluminium products for the same purpose. Companies linked to the development of nuclear reactor technologies, such as Thorium Power and Satra Pars, were also sanctioned. These sanctions are aimed at disrupting Iran’s access to critical technologies and preventing the development of nuclear weapons.
• On 10 April 2025, the US Treasury Department sanctioned Jugwinder Singh Brar, a shipping magnate in the United Arab Emirates, for facilitating the export of Iranian oil. Brar operates a fleet of nearly 30 vessels, some of which carry out high-risk oil transfers in the Persian Gulf, using Iran’s “phantom fleet” and falsifying documents to conceal the origin of the oil. Several associated companies, such as Prime Tankers LLC and Global Tankers, were also sanctioned. These sanctions, under Executive Order 13902, seek to disrupt networks that facilitate Iranian oil exports.
• On 16 April 2025, the US Treasury Department sanctioned Chinese refiner Shandong Shengxing Chemical Co., Ltd. for purchasing more than $1 billion in Iranian crude oil, including purchases from an IRGC-QF front company. These sanctions are implemented under Executive Order 13902, which targets Iran’s oil and petrochemical sectors. A number of vessels involved in the transportation of Iranian oil, such as RESTON and EGRET, and their operators were also designated. As a result, all assets of the sanctioned entities in the US are blocked.
• On 22 April 2025, the US Treasury Department sanctioned Seyed Asadoollah Emamjomeh, an Iranian liquefied petroleum gas (LPG) tycoon, and his business network for facilitating the export of Iranian LPG and crude oil. The linked entities include Caspian Petrochemical and Pearl Petrochemical in the UAE, and Parsa Trabar in Iran. The vessel TINOS I, which attempted to load LPG in the US in 2024, was also sanctioned. These sanctions, under Executive Order 13902, seek to disrupt Iran’s oil and LPG export networks, which fund destabilising activities in the region. All assets of sanctioned entities in the US are blocked.

Counter-terrorism designations; Counter-narcotics designations and update of designations; Deletion of the global Magnitsky designation

• On 15 April 2025, the US Treasury Department sanctioned four members of the Mexican criminal organisation La Nueva Familia Michoacana (LNFM), linked to drug trafficking, human smuggling and violence. Those sanctioned include Johnny and José Alfredo Hurtado Olascoaga, leaders of the organisation, and their brothers Ubaldo and Adita, involved in extortion, arms trafficking and money laundering. The sanctions block their assets in the US and prohibit transactions with them. In addition, rewards are offered for information on their arrest. This action was coordinated with several US and Mexican agencies.

Anti-terrorism designations; issuance of general anti-terrorism licence

• On 17 April 2025, the US Treasury Department sanctioned the International Bank of Yemen (IBY) and three of its executives for financially supporting Ansarallah (Houthis). IBY facilitates international transactions, allowing the Houthis to purchase oil and circumvent sanctions. Those sanctioned include Kamal Hussain Al Jebry, Ahmed Thabit Noman Al-Absi and Abdulkader Ali Bazara. These sanctions block their assets in the US and prohibit transactions with them.

 

United Kingdom

Added 13 new designations at under the Global Anti-Corruption Regime

• On 2 April 2025, the United Kingdom designated 13 individuals under the Global Anti-Corruption Regime. Those designated include Giammattei Falla Alejandro Eduardo, Pineda Avila Angel Arnoldo, Monterroso Gomez Cinthia Edelmira and others, all sanctioned under the Global Anti-Corruption Sanctions Regulations 2021, for corruption in Guatemala. The British government declared that these individuals are involved in acts of serious corruption and abuse of power in their respective regions. The sanctions include an asset freeze and a travel ban.

Added 4 new designations under the Human Rights sanctions regime

• On 10 April 2025, the UK designated four individuals under the Human Rights sanctions regime. The sanctions were imposed on Bedoidze Shalva, Kezevadze Mirza, Katsitadze Karlo and Gabitashvili Giorgi for their responsibility for serious human rights violations, particularly in relation to the cruel, inhuman and degrading treatment of demonstrators during the protests in Georgia. These individuals, in their respective roles within the Ministry of Internal Affairs and the Prosecutor General’s Office, were responsible for violence by security forces against citizens, political opposition leaders, journalists and youth activists. In addition, they are accused of failing to fulfil their responsibilities to investigate and prosecute these abuses. Sanctions include an asset freeze and a travel ban.

Added 2 new designations under the Iran sanctions regime. Two modifications and one administrative amendment under the Russia sanctions regime

• On 14 April 2025, the UK designated two new individuals under the Iran sanctions regime. The sanctions were imposed on Foxtrot Network and Majid Rawa for their involvement in hostile activities supported by the Government of Iran. Foxtrot Network has been involved in supporting armed groups facilitating organised crime in the UK and other countries, while Majid Rawa has been involved in planning and executing activities aimed at destabilising the UK and other countries, including those facilitating organised crime. Sanctions include an asset freeze and a travel ban.

12 revocations (delistings) under the Syria Sanctions Regime

• On 24 April 2025, the UK lifted sanctions on 12 Syrian entities under the Syria sanctions regime. These entities include key ministries such as the Ministry of Interior and the Ministry of Defence, as well as intelligence agencies such as the General Intelligence Directorate, the Political Security Directorate, the Air Force Intelligence Directorate and the National Security Bureau. In addition, sanctions were lifted on state media such as the General Organisation of Radio and Television, Al Watan newspaper, Cham Press TV and Sama TV, previously accused of broadcasting propaganda of Bashar al-Assad’s regime. These revocations follow a series of similar measures taken by the European Union and the United States, reflecting a shift in international policy towards the new Syrian government led by Ahmad al-Sharaa, who took power after the fall of al-Assad in December 2024.

 

*******************************************

In Madrid, 30 April 2025

International Trade and Sanctions Department

Lupicinio International Law Firm