International Sanctions · June 2025

European Union

Guatemala

• On 12 June 2025, Council Implementing Regulation (EU) 2025/1198 was adopted, implementing Council Regulation (EU) 2024/287 of 12 January 2024 concerning restrictive measures in view of the situation in Guatemala, and Council Decision (CFSP) 2025/1199 was adopted, amending Council Decision (CFSP) 2024/254 of 12 January 2024 concerning restrictive measures in view of the situation in Guatemala.

According to the EU, these measures respond to the growing concern about the deterioration of democracy, the rule of law and the peaceful transfer of power in the Central American country. Specifically, three individuals and one new entity are added to the list of sanctioned persons and entities, and the entries of five other persons already designated are updated. The sanctions target senior officials of the Public Prosecutor’s Office, judges and the Foundation Against Terrorism (FCT), involved in attempts to allegedly delegitimise the 2023 election results, as well as in the political persecution of journalists, prosecutors, judges, activists and representatives of the legitimate government. The measures include an asset freeze and a ban on entry into EU territory.

Russia

• On 16 June 2025, Council Decision (CFSP) 2025/1204 was adopted, amending Decision 2014/386/CFSP concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol.

By this Decision, the Council of the European Union extends until 23 June 2026 the restrictive measures adopted in response to the illegal annexation of Crimea and Sevastopol by the Russian Federation. The Decision reflects the EU’s position, reiterating its policy of non-recognition and its support for Ukraine’s sovereignty and territorial integrity. This renewal keeps in place the sanctions imposed since 2014 as part of the European response to Russian Ukrainian conflict.

• On 19 June 2025, a corrigendum to Council Regulation (EU) 2025/395 of 24 February 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in respect of restrictive measures caused by actions of Russia which destabilise the situation in Ukraine was published.

This correction rectifies a clerical error in Article 1(9)(c) of Regulation (EU) 2025/395, which amended Article 3 (e) of Regulation (EU) 833/2014. The correction concerns the list of CN codes of products (numeric codes used in the European Union for the classification of goods and the application of the Common Customs Tariff) whose purchase, import or transfer may be authorised by the competent authorities for specific purposes related to the maintenance of the Budapest metro. The listing is rectified by deleting code 8415 which was included in error. This technical amendment does not alter the substance of the restrictive measures but ensures the correct application of the exemption foreseen for contractual commitments prior to 24 June 2023 with Metrowagonmash.

• On 25 June 2025, the corrigendum to Council Regulation (EU) 2025/932 of 20 May 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures caused by actions of Russia destabilising the situation in Ukraine was published.

The correction published in the Official Journal of the European Union rectifies an error in the listing of restricted goods in Part B of Annex VII to Regulation (EU) No 833/2014 concerning energetic materials and their precursors. In particular, the order of several CN codes is rearranged to ensure proper technical interpretation, affecting products such as chlorates, perchlorates and boron derivatives, as well as certain metal powders and fibre pulp. This purely technical correction does not introduce substantive changes to the sanctioning regime, but ensures regulatory consistency in the application of restrictive measures against Russia.

ISIL (Daesh) and Al-Qaida

• On 17 June 2025, Commission Implementing Regulation (EU) 2025/1233 was adopted, amending for the 347th time Regulation (EC) No 881/2002 concerning restrictive measures against persons and entities associated with Da’esh and Al-Qaida organisations.

The European Commission has adopted a one-off amendment to Regulation (EC) No 881/2002, following a decision adopted on 9 June 2025 by the Sanctions Committee of the United Nations Security Council. By Implementing Regulation (EU) 2025/1233, the entry for Hajjaj Bin Fahd al Ajmi is deleted.

Syria

• On 23 June 2025, Council Decision (CFSP) 2025/1255 amending Council Decision (CFSP) 2020/1999 and Council Implementing Regulation (EU) 2025/1256 implementing Council Regulation (EU) 2020/1998, both concerning restrictive measures against serious violations and abuses of human rights, were adopted.

In response to violence in March 2025 in the coastal region of Syria, the European Union has expanded its comprehensive human rights sanctions regime. Five individuals are added to the list of those sanctioned for their alleged involvement in acts considered by the EU as serious human rights violations, such as torture, extrajudicial killings, arbitrary detention or financial support for activities defined as crimes against humanity. Those sanctioned include former senior military officers of the al-Assad regime and businessmen who allegedly facilitated the maintenance of the al-Assad regime from Russia. The measures include asset freezes and bans on entry into the EU.

 

United States

Treasury Department sanctions Iranian network allegedly laundering billions for the regime through a shadow banking system

• On 6 June 2025, OFAC updated its Specially Designated Nationals and Blocked Persons (SDN) List to include more than 30 individuals and entities for their alleged ties to an international financial network used by Iranian nationals, including the Zarringhalam brothers.

According to information released by the Treasury Department, the network allegedly handled transactions involving the transfer of funds derived from trade in Iranian oil and petrochemical products. The designations entail the freezing of assets under US jurisdiction and the prohibition of transactions with persons subject to US jurisdiction.

Counter-narcotics and counter-terrorism designations and designation updates

• On 9 June 2025, the Office of Foreign Assets Control (OFAC) updated its Specially Designated Nationals and Blocked Persons (SDN) List to include several individuals linked to the Sinaloa Cartel known as “Los Chapitos-Mazatlán Network”, including Joaquín “El Chapo” Guzmán’s sons, Archivaldo and Jesús Alfredo Guzmán Salazar.

These designations are related to fentanyl trafficking, extortion, kidnapping, money laundering and violence linked to this criminal organisation. As a result, all assets of the designees under US jurisdiction have been blocked and transactions with them are prohibited under Executive Orders 14059 and 13224. Concurrently, the Treasury Department offered rewards of up to $10 million for information leading to the capture or conviction of the Guzmán Salazar brothers.

• On 18 June 2025, the Office of Foreign Assets Control (OFAC) updated its Specially Designated Nationals (SDN) List to include five Mexico-based leaders of the Jalisco Cartel – New Generation (CJNG), including Rubén Oseguera Cervantes, alias “El Mencho”, and another commander allegedly responsible for a high-profile homicide.

According to the US, these individuals are linked to fentanyl trafficking, extortion, money laundering and violence related to the organisation. The designations result in the freezing of assets under US jurisdiction and the prohibition of transactions with US citizens or entities, pursuant to Executive Orders 14059 (illicit drugs) and 13224 (terrorism). In addition, the Treasury Department offers rewards of up to $10 million for information leading to the capture or conviction of the designees.

Counterterrorism designations

• On 10 June 2025, the Office of Foreign Assets Control (OFAC) updated its Specially Designated Nationals and Blocked Persons (SDN) List to include five individuals and five alleged entities considered “charities” linked to Hamas and the Popular Front for the Liberation of Palestine (PFLP), accused of serving as fronts for allegedly funding the activities of the military wings of these groups.

These designations entail the freezing of the assets of those concerned under US jurisdiction, as well as a prohibition on transactions with persons or entities subject to these sanctions.

Designations for links to armed groups in Iraq and Syria

• On 12 June 2025, the Office of Foreign Assets Control (OFAC) updated its List of Specially Designated Nationals and Blocked Persons (SDN), adding Nasr Mohsen Ali Huthele, also known as Al-Shammari, allegedly linked to the Harakat al-Nujaba group, as well as the Kata’ib al-Imam Ali organisation (Imam Ali Brigades), active in Iraq and Syria.

Both designations were made pursuant to the authority conferred by Executive Order 13224, concerning individuals and entities identified as participating in or cooperating with activities considered by the US government to be terrorist activities. The measures involve the freezing of all assets and rights under US jurisdiction, as well as a prohibition on US persons or entities from engaging in transactions with those designated.

Issuance of general licence related to Venezuela

• On 20 June 2025, the Office of Foreign Assets Control (OFAC) issued the Venezuela-related General License 5S, authorising certain transactions related to Petróleos de Venezuela, S.A. (PdVSA) bonds issued in 2020, including their purchase, sale, payment or default, as of 20 June 2025.

The licence allows US persons and entities to engage in these specific transactions without violating existing sanctions, thereby facilitating greater financial flexibility within the regulatory framework of US policy towards Venezuela.

Nonproliferation-related designations; Iran and counterterrorism-related designations, designation updates, and de-designations

• On 20 June 2025, the Office of Foreign Assets Control (OFAC) updated the Specially Designated Nationals and Blocked Persons (SDN) List with several actions under its counterterrorism and nuclear proliferation control programme.

Four individuals and four entities were designated for alleged links to Ansarallah in Yemen, as well as a Chinese national and several Chinese companies involved in the supply of sensitive equipment related to Iranian nuclear infrastructure, under the authority of Executive Order 13224 and the non-proliferation regulation (IFSR). These measures involve the freezing of assets under US jurisdiction and prohibit financial or commercial transactions with those designated. In addition, the names and structures of a number of previously sanctioned entities were updated.

Combating terrorism and transnational criminal organisations

• On 24 June 2025, the Office of Foreign Assets Control (OFAC) announced the addition of Giovanni Vicente Mosquera Serrano, alias “El Viejo”, to its Specially Designated Nationals (SDN) List pursuant to Executive Orders 13581 and 13224.

Mosquera Serrano, allegedly a fugitive leader of the Tren de Aragua organisation, was flagged for his alleged involvement in trafficking in illicit substances, extortion and money laundering. The measure involves the freezing of all his assets under US jurisdiction and a ban on transactions with US persons or entities. Rewards of up to $3 million are offered for information leading to his arrest or conviction.

  

United Kingdom

Human Rights Violations

• On 10 June 2025, the UK included Bezalel Smotrich and Itamar Ben-Gvir in the sanctions regime established by the Global Human Rights Sanctions Regulations 2020.

According to official information published by the UK authorities, the designation is based on their alleged involvement in activities that would constitute a serious violation of the right not to be subjected to cruel, inhuman or degrading treatment or punishment under those regulations, in particular for acts of violence in the West Bank.

Designation for support for ISIL (Da’esh) and Al-Qaeda in Eastern and Southern Africa

• On 16 June 2025, the UN Security Council Sanctions Committee added Abubakar Swalleh to its list under resolution 2734 (2024) for his links to the Islamic State in Iraq and the Levant (ISIL), also known as Al-Qaida in Iraq.

Swalleh was designated for involvement in the financing, planning, facilitation, and logistical support of ISIL activities, as well as for recruiting members on its behalf. As of 2018, he reportedly acted as a facilitator for ISIL in Eastern and Southern Africa, providing financial, logistical, and technological support. As a result of this designation, sanctions were imposed on him consisting of an arms embargo, asset freeze and travel ban.

 Twenty new ship specifications have been added to the Russia sanctions regime.

• On 17 June 2025, the UK extended the sanctions regime against Russia with the addition of 20 new ship specifications.

According to the UK authorities, the vessels identified are involved in activities the purpose or effect of which would be to destabilise Ukraine or to undermine or threaten its territorial integrity, sovereignty or independence, or to obtain a benefit from or provide support to the Government of Russia. These vessels would be involved in the transport of oil or petroleum products originating in Russia from Russian territory to third countries. Under the maritime sanction’s regime, the specified vessels may be refused access to UK ports, ordered to be detained or banned from entering, and their registration on the UK Ship Register may be cancelled.

 

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In Madrid, 30 June 2025

Departamento de Comercio y Sanciones Internacionales

Lupicinio International Law Firm