EUROPEAN UNION

RUSSIA

• On 24 February 2025, Council Regulation (EU) 2025/390 amending Regulation (EU) No 269/2014 concerning restrictive measures in response to the conflict between Russia and Ukraine was published in the Official Journal of the European Union.

The Regulation expands the list of persons and entities subject to sanctions, including an asset freeze and travel restrictions.

• On 24 February 2025, Council Regulation (EU) 2025/392, amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and its involvement in the conflict between Russia and Ukraine, was published in the Official Journal of the European Union.

The Regulation expands existing sanctions, including asset freezes and travel restrictions on individuals and entities involved.

• On 24 February 2025, Council Regulation (EU) 2025/395, amending Regulation (EU) No 833/2014 on restrictive measures in view of the conflict between Russia and Ukraine, was published in the Official Journal of the European Union.

This Regulation strengthens existing sanctions, including the prohibition of exports of dual-use goods and technologies, as well as restrictions in the energy and financial sectors. 

• On 24 February 2025, Council Regulation (EU) 2025/398, amending Regulation (EU) 2022/263 concerning restrictive measures in response to the conflict between Russia and Ukraine, was published in the Official Journal of the European Union.

The Regulation strengthens existing sanctions, including a ban on the import of goods from the affected areas and restrictions on investments and related services.

• On 24 February 2025, Council Regulation (EU) 2025/401, amending Regulation (EU) No 692/2014 concerning restrictive measures in response to the situation of Crimea and Sevastopol, was published in the Official Journal of the European Union.

The Regulation strengthens existing sanctions, including a ban on the import of goods originating from Crimea or Sevastopol, as well as restrictions on the export of certain goods and technologies to these regions.

• On 24 February 2025, Council Implementing Regulation (EU) 2025/388, implementing Regulation (EU) No 269/2014 on restrictive measures in response to the conflict between Russia and Ukraine, was published in the Official Journal of the European Union.

This Regulation updates the list of individuals and entities subject to sanctions, including asset freezes and travel restrictions.

• On 24 February 2025, Council Implementing Regulation (EU) 2025/391, implementing Regulation (EU) No 269/2014 concerning restrictive measures in response to conflict between Russia and Ukraine, was published in the Official Journal of the European Union.

The Regulation updates the list of individuals and entities subject to sanctions, including asset freezes and travel restrictions.

• On 24 February 2025, Council Decision (CFSP) 2025/394, amending Decision 2014/512/CFSP concerning restrictive measures in view of the conflict between Russia and Ukraine, was published in the Official Journal of the European Union.

This Decision introduces additional sanctions, including further restrictions on the export of goods and technology, particularly software related to oil and gas exploration.

• On 24 February 2025, Council Decision (CFSP) 2025/396, amending Decision (CFSP) 2022/266 concerning restrictive measures in response to certain areas affected by the conflict between Russia and Ukraine, was published in the Official Journal of the European Union.

This Decision introduces additional sanctions, including restrictions on services and economic actors to integrate into Russia’s legal and financial system, particularly in the provision of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, IT consultancy, market research and public opinion polling, technical testing and analysis, and advertising services to the non-government-controlled areas.

• On 24 February 2025, Council Decision (CFSP) 2025/397, amending Decision 2014/386/CFSP concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol, was published in the Official Journal of the European Union.

The Decision introduces additional sanctions, including a ban on the export of certain goods and technologies, as well as restrictions on the provision of services in key sectors such as transport, telecommunications, and energy.

SYRIA

• On 24 February 2025, Council Regulation (EU) 2025/407, amending Regulation (EU) No 36/2012 on restrictive measures in view of the situation in Syria, was published in the Official Journal of the European Union.

In response to the situation in Syria, this Regulation updates existing restrictive measures, including asset freezes and travel restrictions for individuals and entities involved in activities undermining the country’s stability.

• On 24 February 2025, Council Implementing Regulation (EU) 2025/408, implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria, was published in the Official Journal of the European Union.

In response to developments in Syria, this Regulation updates the list of individuals and entities subject to sanctions, including asset freezes and travel restrictions. Notably, six entities have been removed from the sanctions list, with assets of one of those entities remaining frozen.

• On 24 February 2025, Council Decision (CFSP) 2025/406, amending Decision 2013/255/CFSP concerning restrictive measures in view of the situation in Syria, was published in the Official Journal of the European Union.

This Decision suspends certain restrictive measures to encourage a transition, support humanitarian aid delivery, economic recovery, reconstruction, and stabilisation. Notably, six entities have been removed from the list of those subject to asset freezes and economic restrictions, although the assets of one of these entities remain frozen. Additionally, exemptions to prohibitions on establishing banking relations and exporting luxury goods to Syria have been introduced to facilitate these objectives.

SUDAN

• On 24 February 2025, Council Implementing Regulation (EU) 2025/376, implementing Regulation (EU) 2023/2147 concerning restrictive measures in view of activities undermining the stability and political transition of Sudan, was published in the Official Journal of the European Union.

This Regulation updates the list of individuals and entities subject to sanctions, including asset freezes and travel restrictions.

• On 24 February 2025, Council Decision (CFSP) 2025/377, amending Decision (CFSP) 2023/2135 concerning restrictive measures in view of activities undermining the stability and political transition of Sudan, was published in the Official Journal of the European Union.

This Decision updates the list of individuals and entities subject to sanctions, including asset freezes and travel restrictions.

BELARUS

• On 24 February 2025, Council Implementing Regulation (EU) 2025/386, implementing Article 8a of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and its involvement in Russia’s conflict, was published in the Official Journal of the European Union.

The Regulation updates the list of individuals and entities subject to sanctions, including asset freezes and travel restrictions.

• On 24 February 2025, Council Decision (CFSP) 2025/385, amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and its involvement in the Russian aggression against Ukraine, was published in the Official Journal of the European Union.

In response to Belarus’s actions in the conflict between Rusia and Ukraine, this Decision introduces additional sanctions, including asset freezes and travel restrictions on individuals and entities involved.

 

UNITED STATES

IRAN

• On 6 February 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of individuals and companies in China, India, and the UAE for facilitating the shipment of Iranian oil to China. The sanctions also targeted vessels involved in these operations. The U.S. claims Iran uses the revenue to fund its nuclear program and terrorist groups.

CYBER-RELATED DESIGNATIONS

• On 11 February 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with Australia and the United Kingdom, sanctioned individuals and entities linked to ransomware attacks. The designations include two Russian nationals and the company ZSERVERS, which provides technological infrastructure for cyberattacks. This action reinforces the international commitment to combat cyber threats and protect critical infrastructure.

INTERNATIONAL CRIMINAL COURT-RELATED DESIGNATION

• On 13 February 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the issuance of Executive Order 14203, titled “Imposition of Sanctions on the International Criminal Court”. This order, signed by the President on February 6, 2025, imposes sanctions on the ICC. As a result, OFAC has added Karim Asad Ahmad Khan, Chief Prosecutor of the ICC, to the Specially Designated Nationals and Blocked Persons List (SDN List).

DEMOCRATIC REPUBLIC OF THE CONGO

• On 20 February 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions related to the crisis in the Democratic Republic of the Congo (DRC), including James Kabarebe and Lawrence Kanyuka. It also designated “Carteles Unidos” in Mexico as a transnational terrorist organization. Additionally, OFAC launched the “File Finder” tool to improve access to its website content, including general licenses, executive orders, and regulatory notices.

IRAN

• On 24 February 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on over 30 entities and individuals involved in Iran’s oil trade, targeting intermediaries, tanker operators, and shipping companies in UAE, Hong Kong, India, and China. These measures aim to disrupt Iran’s shadow fleet, restrict oil revenue funding its nuclear and missile programs, and increase risks for those engaging in Iranian oil trade.
• On 26 February 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned six entities in China and Hong Kong for supplying components for Iranian drones and ballistic missiles. The sanctions target firms linked to Pishtazan Kavosh Gostar Boshra, freezing their U.S. assets and prohibiting transactions. The move is part of U.S. efforts to disrupt Iran’s weapons programs amid ongoing pressure on its economy.

 

UNITED KINGDOM

• As of 27 February 2025, the following entry has been added to the consolidated list and is now subject to an asset freeze and fiduciary service sanctions: Vladimir Vladimirovich PUTIN (Group ID: RUS1800).
• As of 27 February 2025, the following entry has been added to the consolidated list and is now subject to an asset freeze and fiduciary service sanctions: Mikhail Vladimirovich MISHUSTIN (Group ID: RUS1797).
• As of 27 February 2025, the following entry has been added to the consolidated list and is now subject to an asset freeze and fiduciary service sanctions: Abdullah al-Senussi (Group ID: LIB0042).

 

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In Madrid, 28 February 2025

Trade and International Sanctions Department

Lupicinio International Law Firm