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International Sanctions · July 2025

2025-07-31 International SanctionsNewsletters

European Union

South Sudan

In accordance with the European Union, these actions are due to the continued existence of barriers that hinder the implementation of the Revitalised Agreement for the Resolution of the Conflict in South Sudan and the involvement of senior officials of the Transitional Government in obstructing that process. The sanction against Michael Makuei Lueth, Minister of Information and Broadcasting since 2013, is maintained and his entry on the list of persons subject to measures is updated.

Haiti

These amendments extend until 29 July 2026 the restrictive measures already established in 2022 and reinforced in 2023. The decision is adopted in response to the continuing deterioration of the political, economic, humanitarian and security situation in Haiti, and underlines the seriousness of the crisis, justifying the extension of the existing instruments without changes to their specific content.

The amendments are due to the increase in gang violence and the lack of punishment for those involved in these acts in the country. Three armed gang leaders —Wharf Jérémie, Ti Bwa and Canaan— responsible for massacres, targeted killings, kidnappings, rape, extortion, drug trafficking and the forced recruitment of minors have been added.

Human rights violations

These measures add eight natural persons and one legal entity linked to the so-called “Zindashti Network”, allegedly linked to the Iranian Ministry of Intelligence and the IRGC. They are alleged to have planned and executed extrajudicial killings and enforced disappearances of dissidents abroad.

Republic of Moldova

Seven individuals and three entities linked to politician and oligarch Ilan Shor have been added, accused of bribery, vote buying, propaganda and electoral manipulation in the 2024 elections and referendum. The designated entities include A7 OOO, the Victory/Pobeda Political Bloc and The Cultural Educational Centre of Moldova.

Russia and Belarus

The measures add five Russian judges and former judges accused of imposing disproportionate sentences, authorising closed-door hearings and contributing to procedural violations against opponents and protesters. They are held responsible for supporting the repression of civil society and the democratic opposition in Russia.

Nine individuals and six entities accused of contributing to sabotage, cyberattacks, information manipulation and interference in democratic processes have been added. Notable entities include RTRS, the 841st Separate Electronic Warfare Center of the Baltic Fleet, the BRICS Journalist Association, the Centre for Geopolitical Expertise, the Foundation to Battle Injustice and Tigerweb. These measures reinforce the EU’s condemnation of the Russian hybrid threat.

  • On 18 July 2025, the Council of the European Union adopted its 18th package of sanctions in response to the conflict between Russia and Ukraine, which includes the adoption of four Decisions and four Regulations published on the same day in the Official Journal of the European Union. These measures, both economic and individual, focus on key sectors such as energy, banking and the Russian military, reinforcing the pressure on the Russian Federation.

This sanctions package introduces several relevant provisions, including a reduction in the maximum price cap for Russian oil, new bans on imports of energy products and financial transactions, and a total block on Russian banking operations through international systems. In addition, controls on exports of dual-use goods and technologies are strengthened, and measures to prevent sanctions evasion by third countries are expanded. Taken together, these actions seek to severely limit Russia’s economic and financial capacity, while aligning with similar sanctions against Belarus and protecting Ukrainian cultural property affected by the war.

The Lupicinio International Law Firm website provides an in-depth explanation of this eighteenth package of European Union sanctions against Russia. The article details the main decisions and regulations, which include economic and individual measures targeting key sectors such as the Russian energy, banking and military sectors, as well as restrictions to make it more difficult to evade sanctions.

Sudan

These measures respond to the escalation of violence in Sudan, particularly the fighting between the Sudanese Armed Forces and the Rapid Support Forces and associated militias. Specifically, Decision 2025/1481 adds two individuals and two entities to the list of persons subject to sanctions in Regulation 2023/2147.

Mali

These measures follow a review of the list of persons subject to sanctions under the regime on Mali. Specifically, both acts remove Mr Choguel MAÏGA, who is allegedly involved in activities that threaten the peace and stability of Mali, from the list.

Iran

These measures respond to the assessment that Iran continues to provide significant military support to Russia in its conflict with Ukraine, as well as to armed groups in the Middle East and the Red Sea region. Regulation 2025/1548 updates the entries for two natural persons and one entity already included in Annex III to the basic Regulation 2023/1529, in line with the review of the list carried out by the EU. Similarly, Decision 2025/1547 extends the validity of the sanctions until 27 July 2026 and incorporates equivalent updates to the list of persons subject to sanctions included in the 2023 CFSP Decision.

Under the new package, one natural person is removed from the list of those subject to sanctions, but the restrictive measures against forty-five persons and entities linked to both nuclear and missile development and to the Islamic Revolutionary Guard Corps (IRGC) and key scientific, industrial and technological bodies of the Iranian regime are updated and strengthened. The new entries mainly affect university management, scientists, senior IRGC officials and companies in the defence, nuclear research, maritime and technology industries, and the logistical financing of the sanctioned programmes.

United States

Treasury Department sanctions Aeza Group for providing key IT infrastructure to cybercriminals

  • On 1 July 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Aeza Group, a bulletproof hosting (BPH) service provider, along with two affiliated companies and four individuals for their involvement in illicit cyber activities targeting victims in the United States and globally.

According to the Treasury, Aeza Group provided specialised infrastructure used by ransomware actors such as Meduza and infostealer networks, as well as darkweb drug marketplaces such as BlackSprut, facilitating detection evasion and resistance to law enforcement actions.

Treasury sanctions illegal oil trade networks financing IRGC-Q

  • On 3 July 2025, the Office of Foreign Assets Control (OFAC) updated its Specially Designated Nationals and Blocked Persons List (SDN), designating several companies, commercial networks, and vessels operated by Iraqi-British businessman Salim Ahmed Said, as well as related companies and vessels of the so-called “shadow fleet” for facilitating the transport and purchase of billions of dollars in Iranian oil, part of which allegedly financed the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), considered a foreign terrorist organisation.

According to information released by the Treasury Department, these companies mixed Iranian crude oil with Iraqi crude oil and sold it on the international market as if it were exclusively Iraqi, using ship-to-ship transfers and falsified documentation to conceal its true origin. In addition, several vessels involved in these illicit operations and entities that facilitated these transactions were included in the designation.

Washington blocks clandestine network of North Korean IT experts key to Pyongyang’s financing

  • On 8 July 2025, the Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned Song Kum Hyok (Song), linked to North Korea’s Reconnaissance General Bureau (RGB) hacking group Andariel, along with one additional individual and four entities involved in schemes to recruit North Korean workers in China and Russia to generate clandestine revenue for the North Korean regime.

According to Treasury Department information, these workers were hired using false identities and fabricated nationalities to work at companies unaware of their origin. They often also introduced malware into corporate networks. The network operated through companies and individuals based in Russia that recruited and transferred workers abroad to generate revenue to fund North Korea’s missile and mass destruction weapons programmes.

The Treasury Department is sanctioning additional elements of the Iranian “shadow banking” network linked to the IRGC-QF.

  • On 9 July 2025, the Office of Foreign Assets Control (OFAC) designated 22 entities based in Hong Kong, the United Arab Emirates, and Turkey for their involvement in a “shadow banking” network used by the Iranian regime’s elite and the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to channel funds derived from Iranian oil sales and finance terrorist activities.

According to the Treasury, these entities acted as front companies outside Iran, operating offshore accounts that received transfers from refineries that purchased Iranian oil, allowing them to evade sanctions and transfer profits to accounts controlled by the IRGC-QF. Among the designated companies are Pulcular Enerji (Turkey), Amito Trading, Shelf Trading, Cetto International, Peakway Global, JTU Energy, among others. Some also transferred tens or hundreds of millions of dollars to the IRGC-QF.

Treasury sanctions top leaders of Tren de Aragua, considered a terrorist organisation

  • On 17 July 2025, the Office of Foreign Assets Control (OFAC) sanctioned Hector Rusthenford Guerrero Flores (alias “Niño Guerrero”), leader of Tren de Aragua, along with five important lieutenants and key affiliates of this organisation, including Yohan José Romero (“Johan Petrica”), Wilmer José Pérez Castillo (“Wilmer Guayabal”), Wendy Marbelys Ríos Gómez, and Felix Anner Castillo Rondón (“Pure Arnel”).

According to the Treasury, Tren de Aragua—designated by the State Department as a Foreign Terrorist Organisation (FTO) on 20 February 2025 and previously sanctioned as a transnational criminal organisation—is involved in drug trafficking, human trafficking, extortion, sexual exploitation, kidnapping, and money laundering. The designations are made pursuant to Executive Orders 13581 and 13224 (both as amended). The sanctions include the freezing of all assets in the United States or under the control of U.S. persons, as well as the prohibition of any transactions with the designated persons or entities indirectly controlled by them, unless expressly authorised by the OFA.

Treasury sanctions network linked to oil imports benefiting the Houthis (Ansarallah)

  • On 22 July 2025, the Office of Foreign Assets Control (OFAC) sanctioned two individuals and five entities located in Yemen and the United Arab Emirates for participating in an oil smuggling and money laundering scheme that generates significant annual revenue for the Houthis (Ansarallah), a group designated as a foreign terrorist organisation.

The U.S. Treasury sanctioned a network that operated as a key importer of petroleum products to Houthi-controlled areas in Yemen, collecting taxes and generating hundreds of millions of dollars to finance destabilising activities. This network coordinated the massive delivery of crude oil, including a transaction of approximately $12 million in Iranian oil. Sanctions were also imposed on entities used for money laundering and direct financial support to the group.

Treasury sanctions clandestine IT network financing North Korea’s nuclear weapons programmes

  • On 24 July 2025, the Office of Foreign Assets Control (OFAC) designated the Korea Sobaeksu Trading Company (also known as Sobaeksu United Corporation) and three individuals —Kim Se Un, Jo Kyong Hun, and Myong Chol Min— for facilitating the evasion of U.S. and United Nations sanctions through fraudulent schemes involving IT workers who generate revenue for North Korea’s nuclear and ballistic missile programmes.

According to the Treasury, this network hired North Korean IT workers operating abroad under false identities to infiltrate legitimate companies, including in the United States, generating hundreds of millions of dollars retained by the regime. Some employees also introduced malware into corporate networks to extract sensitive data.

United Kingdom

Chemical Weapons

  • On 7 July 2025, the United Kingdom added two individuals and one entity linked to the Russian defence sector to its official sanctions list under the Chemical Weapons regime.

According to the British authorities, these designations are due to their direct involvement in activities related to chemical weapons, including transfers and use in Ukraine. The sanctions include the freezing of assets, a ban on fiduciary services, restrictions on holding management positions and a ban on international travel for the individuals named.

The Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 were established to prevent the proliferation and use of these prohibited weapons, in line with the 1993 Chemical Weapons Convention.

Haiti

  • On 10 July 2025, the United Kingdom added two entities to its Haiti sanctions regime (Haiti (Sanctions) Regulations 2022, as amended): VIV ANSANM (ID HAI0009) and GRAN GRIF (ID HAI0010).

According to the official notice from the British government, these designations follow new additions to the UN Security Council sanctions regime, which included the same entities.

Cybersecurity

  • On 18 July 2025, the United Kingdom added 19 new designations (18 individuals and 1 entity) under the Cyber sanctions regime and also amended two existing designations (Main Centre for Special Technologies – Sandworm and 85th Main Special Service Centre).

These measures target GRU officers and associated units that carried out sustained campaigns of malicious cyber activities against critical infrastructure in the United Kingdom, media, energy, telecommunications and Western political processes, including attacks on the Skripal family and disruptive operations in Ukraine.

The cyber sanctions regime was designed to counter serious transnational threats arising from cybercrime and state espionage, strengthening the UK’s resilience to sophisticated digital attacks.

Russia

  • On 18 July 2025, the United Kingdom added four new subjects to the sanction’s regime against Russia: three GRU officers (Artyom Sergeevich Kureyev, Anna Sergeevna Zamaraeva and Victor Aleksandrovich Lukovenko) and the entity African Initiative.

These designations target actors directly linked to Russian military operations, cyberattacks, sabotage and disinformation campaigns, including actions such as the bombing of the Mariupol theatre in 2022 and the poisoning of Yulia Skripal.

  • On 21 July 2025, the United Kingdom implemented 137 new specifications (essentially “shadow fleet” vessels) and designated two additional entities under the same sanctions regime as Russia: INTERSHIPPING SERVICES LLC and LITASCO MIDDLE EAST DMCC.

The action focuses on blocking the infrastructure of illegal Russian oil trade: 135 vessels involved in the transport of crude oil worth billions of dollars since 2024 were designated as part of the so-called “shadow fleet”. The sanctioned entities are related to the registration and operation of these vessels and the trade in oil. Asset freezes, sanctions on trust services, transport bans, and travel restrictions or disqualification of directors were applied.

  • On 24 July 2025, two administrative amendments were made under the sanction’s regime against Russia: the specification of an already designated entity (LITASCO MIDDLE EAST DMCC) was modified and the designation of a specific ship, the Victor Konetsky (IMO 09301421, Unique ID RUS2465), was corrected.

These corrections do not imply new substantive sanctions, but rather technical adjustments to the official records while maintaining the existing sanctions.

Global irregular migration

  • On 23 July 2025, the United Kingdom issued the first designations under its new Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025, including 25 individuals and entities linked to human trafficking networks and facilitators of irregular smuggling of migrants.

The designated entities include gang leaders involved in human trafficking, informal financial intermediaries operating through the hawala system, companies supplying boats for Channel crossings (such as a Chinese manufacturer), as well as corrupt officials and false documentation operators in countries such as Serbia, Belgium, Iraq and Kurdistan.

This new regime, established by the Sanctions Act 2018 and activated in July 2025, represents the first global framework dedicated exclusively to countering irregular migration networks and human trafficking.

 

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

In Madrid, 31 July 2025

International Trade and Sanctions Department

Lupicinio International Law Firm

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  • International Sanctions · July 2025
    Fátima Rodriguez

    Compliance, Criminal, International Sanctions

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