International Sanctions · August and September 2025

2025-10-01 International Sanctions Newsletters

Tabla de contenidos

European Union
United States
United Kingdom

European Union

August 2025

Iraq

On 12 August 2025, Implementing Regulation (EU) 2025/1751 concerning certain specific restrictions on economic and financial relations with Iraq was adopted, amending Annex IV to Regulation (EC) 1210/2003 in relation to the sanctions regime against Iraq.

The European Commission updated Annex IV to align the European asset freeze list with the changes introduced by the UN Security Council Sanctions Committee. The amendment adjusts existing entries (identifications, aliases or biographical information) without introducing new substantive designations, ensuring consistency with international obligations and the effectiveness of the measures.

September 2025

Russia/Ukraine

On 12 September 2025, Decision (CFSP) 2025/1895 amending Decision 2014/145/CFSP and Implementing Regulation (EU) 2025/1894 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine were adopted.

The EU renewed and adjusted individual measures in response to actions undermining the territorial integrity of Ukraine. Names, aliases, dates and reasons for designation were updated. The asset freeze and travel ban remain in place. The measures are extended until 15 March 2026, thus reinforcing the European commitment to defending Ukrainian sovereignty.

Human rights violations

On 5 September 2025, Decision (CFSP) 2025/1790 and Implementing Regulation (EU) 2025/1789 were adopted concerning the sanctions regime for serious human rights violations.

Two individuals responsible for torture and abuse in detention centres in occupied Crimea were added to the list. The measures respond to systematic violations including ill-treatment, arbitrary detention and enforced disappearances of political prisoners, activists and ethnic minorities, especially Crimean Tatars. The freezing of assets and a ban on making funds available to those designated are activated.

Sudan

On 22 September 2025, Decision (CFSP) 2025/1932 was adopted, amending Decision (CFSP) 2023/2135 on restrictive measures for destabilising activities in Sudan.

The EU extended the sanctions framework for one year until 10 October 2026. The decision responds to the continuing deterioration marked by violence between the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF), mass displacement of the population and a growing humanitarian crisis. The basis for listing individuals and entities that finance, direct or support violence remains in place, with asset freezes, travel bans and restrictions on the provision of funds. Financial institutions must assess payment routes, identify risky regional counterparties and monitor possible diversions of dual-use goods.

Syria

On 22 September 2025, Implementing Decision (CFSP) 2025/1936 and Implementing Regulation (EU) 2025/1937 were adopted on restrictive measures against Syria.

Lists and grounds under the Syria regime were updated, including adjustments to identifying information and reasons for designation.

Asset freezes and travel restrictions remain in place, with an emphasis on government officials and regime facilitators involved in repression, the energy sector, military procurement and chemical weapons. This update maintains pressure and sends a clear signal that the EU will not tolerate impunity for war crimes and massive human rights violations.

Iran

On 29 September 2025, the Council of the EU reimposed nuclear measures suspended under the JCPOA, activating the ‘snapback’ mechanism of UNSC Resolution 2231, consisting of the following Regulations and the CFSP Decision.
Firstly, Council Regulation (EU) 2025/1975 of 29 September 2025 amending Regulation (EU) No 267/2012 concerning restrictive measures against Iran.
Secondly, Council Implementing Regulation (EU) 2025/1980 of 29 September 2025 implementing Regulation (EU) No 267/2012 concerning restrictive measures against Iran.

This action, which was not blocked by the Security Council, responds to Iran’s persistent failure to comply with its nuclear commitments. The package re-freezes assets, including those of the Iranian Central Bank, prohibits imports of oil and petroleum products, and re-establishes severe restrictions on transfers of sensitive technology and strategic sectors (finance, transport, energy). This decision marks the definitive collapse of the 2015 agreement and a return to the most severe sanctions regime against Iran. European financial institutions must prepare for strict compliance, with the consequent enforcement of the ban on transactions with the Iranian banking system, restrictions on the energy sector, limitations on trade in metals and petrochemicals, and rigorous controls on exports of dual-use technology. Although the full annexes were pending publication in the OJEU, the political decision is firm, binding and irrevocable.

United States

August 2025

Iran

On 8 August 2025, OFAC sanctioned 18 entities and individuals for facilitating sanctions evasion and supporting the Iranian regime’s internal repression.

Those designated include financial technology providers, offshore banks, information technology companies, and various financial intermediaries linked to the Islamic Revolutionary Guard Corps (IRGC).

This action seeks to close avenues used by Tehran to access the international financial system through front companies, alternative systems such as hawala, cryptocurrency platforms, and technology services in permissive jurisdictions. Notable examples include RUNC Exchange, Cyrus Offshore Bank, and various technology holding companies that have facilitated transactions worth hundreds of millions.

The impact translates into greater scrutiny of payments that may be linked to these entities, as well as the freezing of assets under US jurisdiction and a ban on commercial or financial relations with US nationals.

DR Congo

On 12 August 2025, OFAC sanctioned the armed group PARECO-FF, CDMC and Hong Kong traders (East Rise, Star Dragon) for illegal mining and violence in Rubaya.

The Democratic Republic of Congo region has abundant reserves of coltan, a mineral critical to the electronics industry, whose illegal extraction finances armed groups responsible for serious violations documented by the UN, including forced labour of adults and minors, displacement of communities, systematic sexual violence and child recruitment.

Investigations have shown that Hong Kong-based traders purchased illegal minerals worth tens of millions of dollars, allowing resources to be channelled directly to these groups. The measures taken are intended to disrupt the flow of financing linked to coltan and other minerals that perpetuate the conflict.

The individuals and entities identified have been added to the SDN List, subjecting them to asset freezing and transaction prohibitions. The action, supported by the State Department, is part of the United States’ strategy to promote responsible and abuse-free supply chains.

September 2025

Mexico

On 18 September 2025, OFAC sanctioned the “Los Mayos” faction, including the head of its armed wing and a network of 5 individuals and 15 companies in the border area.

The faction, led by associates of Ismael “El Mayo” Zambada, controls operations involving fentanyl and methamphetamine, drugs that cause more than 100,000 deaths annually in the United States.

The action seeks to dismantle financial and logistical infrastructure, such as clandestine laboratories, smuggling routes, distribution networks, and money laundering. The companies function as fronts for laundering money through real estate, legitimate businesses, currency exchange, car trade, and the acquisition of chemical precursors from China and India. It includes the freezing of assets under US jurisdiction, a ban on transactions, and possible secondary sanctions. It strengthens the line against fentanyl/methamphetamine chains and the cartel’s territorial control.

Iran

On 2 September 2025, OFAC designated networks operating in Iraq (traders, facilitators, front companies, and oil tankers) for smuggling Iranian oil.

On 2 September 2025, OFAC published new designations against networks operating in Iraq (traders, facilitators, front companies and associated oil tankers). These networks use falsified documentation, ship-to-ship transfers in international waters with AIS systems turned off, and shadow banking. Investigations revealed that they mix Iranian oil with legitimate Iraqi crude at port facilities to market it internationally, concealing its origin by manipulating certificates, transport documents, and quality analyses. Iraqi facilitators provide logistical cover, access to port infrastructure, informal hawala banking services, corrupt official protection, and connections to buyers willing to purchase sanctioned oil at a discount.

The designations target Iraqi nationals, trading companies based in Iraq, the United Arab Emirates, and other jurisdictions, as well as several vessels in the shadow fleet. These networks have facilitated exports valued at billions of dollars annually, which serve to fund missile programmes, nuclear activities, and proxy groups. The measure thus increases pressure on the Iranian energy sector and warns of the risk of secondary sanctions.

DPRK (Democratic People’s Republic of Korea, North Korea).

On 25 September 2025, OFAC designated arms traffickers and financial facilitators who support the DPRK’s ballistic and nuclear programmes.

The Treasury announced action against arms traffickers and financial facilitators supporting the DPRK’s ballistic and nuclear programmes, reinforcing July and August lines on IT workers and identity fraud. This round targets an international network that facilitates the acquisition of critical components, dual-use technology, strategic materials, manufacturing equipment and technical expertise for the development of missiles capable of reaching US territory and nuclear devices. Those designated include agents operating from China, Russia and third countries, front companies, financial intermediaries channelling funds through complex schemes, maritime transport operators using false documentation and flags of convenience, and technology entities.

Investigations identified links to the Reconnaissance General Bureau (RGB), the main foreign intelligence agency, and the Korea Mining Development Trading Corporation (KOMID), a procurement entity already designated by the UN. Those sanctioned are subject to a total asset freeze and a ban on transactions. The measure is part of the strategy to cut off the regime’s external sources of funding and restrict its access to sensitive technology, in line with UN Security Council resolutions.

United Kingdom

August 2025

Iran

On 21 August 2025, the United Kingdom added designations under the Iran Sanctions Regulations 2023, increasing pressure on internal repression and external military support.

The designations focus on individuals and entities linked to serious human rights violations within Iran (violent repression of peaceful demonstrations, arbitrary detention of activists, journalists and dissidents, torture in detention centres, excessive use of force against civilians) and the supply of weapons and military technology to regional proxy groups, especially those designated as terrorist organisations that threaten stability. This has resulted in the freezing of assets in the UK and dependent territories, and financial restrictions prohibiting UK persons and entities from conducting transactions or making funds available to designated individuals.

Russia

On 20 August and 12 September, new designations were announced under the Russia regime (EU Exit Regulations 2019). The measures affect both entities and vessels involved in logistical support for the hydrocarbon trade.

These designations are part of the British strategy to cut off funding for Russia’s war effort in Ukraine, particularly by restricting oil trade. The specifications include shadow fleet vessels used to transport Russian oil in circumvention of the $60/barrel price cap imposed by the G7. Companies that provide maritime transport, insurance and financial services, as well as port operators that allow for the resupply and maintenance of the sanctioned fleet, were also designated. The measures include asset freezes, bans on maritime services (insurance, classification, access to British ports) and restrictions on financial transactions related to Russian oil trade above the price cap.

September 2025

“Georgian supporters” of Russia

In September 2025, the FCDO designated Georgian individuals/companies supporting the conflict between Russia and Ukraine.

It includes two shadow fleet oil tankers now banned from ports and removed from the UK Ship Register. This action marks a toughening of stance towards third countries that facilitate the evasion of Russian sanctions, extending measures beyond Russia and Belarus. British investigations revealed that these networks use Georgian territory as a transit point for Russian oil destined for international markets, taking advantage of Georgia’s strategic position in the Caucasus and access to the Black Sea. The effects are the freezing of assets, bans on maritime services (fuel, repairs, insurance, port services), travel restrictions, and risk for logistics intermediaries in the Black Sea/Caucasus corridor.

OFSI

On 26 September 2025, the Office of Financial Sanctions Implementation (OFSI) issued a general licence allowing tax authorities to make payments to frozen accounts of designated persons and offset tax debts.

This licence resolves situations where authorities need to make legitimate tax refunds or accounting adjustments with funds subject to freezing. Banks must enable limited flows under licence, with strict reporting and controls (concept checks, limits and notification deadlines). They must update operating procedures to manage these exceptions without compromising the effectiveness of the freezing regime, keeping detailed records and reporting regularly to the authorities. This licence does not represent a relaxation of sanctions, but rather a technical mechanism to allow legitimate tax obligations to be met while maintaining pressure on the assets of designated persons.

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In Madrid, 30 September 2025

International Trade and Sanctions Department

Lupicinio International Law Firm