European Union

Turkey

• On 11 March 2025, Council Implementing Regulation (EU) 2025/487 implementing Council Regulation (EU) 2019/1890 and Council Decision (CFSP) 2025/484 amending Council Decision (CFSP) 2019/1894 were adopted.

The initial regulation, (EU) 2019/1890, was established on 11 November 2019, in response to Turkey’s unauthorised drilling activities in the Eastern Mediterranean. Following a review by the Council, it has been decided that the entry for the person specified in Annex I to Regulation (EU) 2019/1890, Mehmet Ferruh Akalin, should be removed from the list of sanctioned persons.

Russia

• ^On 14 March 2025, Council Implementing Regulation (EU) 2025/527 implementing Regulation (EU) No 269/2014 and Council Decision (CFSP) 2025/528 amending Decision 2014/145/CFSP were adopted.

This Regulation updates the information concerning 126 persons and 36 entities listed in Annex I to Regulation (EU) No 269/2014. In addition, entries for three deceased persons, four other persons and three duplicate entries have been removed from that Annex.

The restrictive measures are in response to actions that undermine or threaten the territorial integrity, sovereignty and independence of Ukraine. The changes were introduced following a review by the Council. The initial Regulation (EU) No 269/2014 was established on 17 March 2014.

Terrorism in the Middle East and North Africa

• On 17 March 2025, Council Decision (CFSP) 2025/514 amending Decision (CFSP) 2016/1693 and Council Implementing Regulation (EU) 2025/515 implementing Regulation (EU) 2016/1686 were adopted.

This Regulation adds one entity, the Al-Azaim Media Foundation, to the list of persons, groups, undertakings and entities subject to restrictive measures set out in Annex I to Regulation (EU) 2016/1686 and in the Annex to Decision (CFSP) 2016/1693.

The restrictive measures respond to the threat posed by ISIL (Da’esh) and Al-Qaida, as well as associated individuals, groups, undertakings and entities. The initial Regulation, (EU) 2016/1686, was established on 20 September 2016.

Congo (Democratic Republic of the)

• Council Implementing Regulation (EU) 2025/509 implementing Regulation (EC) No 1183/2005 and Council Implementing Decision (CFSP) 2025/510 implementing Decision 2010/788/CFSP were adopted on 17 March 2025.

This Regulation adds nine persons and one entity to the list of persons subject to restrictive measures contained in Annex Ia to Regulation (EC) No 1183/2005 and in Annex II to Decision 2010/788/CFSP.

These measures are in response to the situation in the Democratic Republic of Congo (DRC), in particular the latest escalation of the conflict in eastern DRC, aggravated by the renewed offensive of the armed group M23, allegedly supported by the Rwandan Defence Forces (RDF). The European Union considers that revenues from the illegal extraction and trafficking of natural resources in eastern DRC finance, inter alia, the M23 armed group and its operations, thus contributing to the escalation of the conflict.

Decision 2010/788/CFSP was initially established on 20 December 2010; Regulation (EC) No 1183/2005 was initially established on 18 July 2005.

Central African Republic

• On 24 March 2025, Council Decision (CFSP) 2025/604 amending Decision 2013/798/CFSP and Council Regulation (EU) 2025/610 amending Regulation (EU) No 224/2014 concerning restrictive measures in relation to the situation in the Central African Republic were adopted.

The new regulation prohibits the sale, supply, transfer or export of goods and technology listed in the Common Military List of the European Union, as well as firearms, their parts and ammunition, to armed groups and associated persons operating in the Central African Republic.

The amendment follows UN Security Council Resolution 2745 (2024), which lifted the arms embargo on the CAR government, but imposed it until 31 July 2025 on armed groups and associated individuals operating in the country.

Decision 2013/798/CFSP was issued on 23 December 2013, while Regulation (EU) No 224/2014 was issued on 10 March 2014.

Haiti

• On 24 March 2025, Council Decision (CFSP) 2025/601 amending Council Decision (CFSP) 2022/2319 and Council Regulation (EU) 2025/608 amending Council Regulation (EU) 2022/2309 concerning restrictive measures in view of the situation in Haiti were adopted.

The amended Regulation prohibits the sale, supply, transfer or export to Haiti of goods and technology listed in the Common Military List of the European Union, as well as firearms, their parts and ammunition. It also prohibits financing, technical assistance and related brokering services. However, the regulation includes exemptions for UN-authorised missions, security units under the command of the Haitian government and non-lethal military equipment for humanitarian use, subject to prior approval.

These measures are intended to further the objectives of peace and stability in Haiti. This Regulation clarifies the actions threatening the peace, stability and security of Haiti and amends the scope of the arms embargo in accordance with UN Security Council Resolution 2752 (2024). Decision (CFSP) 2022/2319 was initially established on 25 November 2022; Regulation (EU) 2022/2309 was established on 25 November 2022.

Belarus

• Council Implementing Regulation (EU) 2025/631 implementing Article 8a(1) of Regulation (EC) 765/2006 and Council Implementing Decision (CFSP) 2025/632 implementing Decision 2012/642/CFSP were adopted on 27 March 2025.

These Regulations add 25 natural persons and seven legal persons to the list of persons subject to restrictive measures contained in Annex I to Regulation (EC) No 765/2006 and in Annex I to Decision 2012/642/CFSP.

The restrictive measures are in response to the situation in Belarus and the country’s involvement in the situation in Ukraine. The initial decision, 2012/642/CFSP, was adopted on 15 October 2012.

United States

Venezuela

• 4 March 2025, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 41A, which authorises the liquidation of certain transactions related to Chevron Corporation’s joint ventures in Venezuela, providing specific permissions to conclude the commitments.

Fight against drugs

• 4 March 2025, OFAC updated its Specially Designated Nationals and Blocked Persons (SDN) List, adding Behrouz Parsarad, an Iranian national, for sanctions related to illicit drug activities under Executive Order 14059. Parsarad has multiple aliases, email addresses, phone numbers, and numerous digital currency addresses associated with Bitcoin (XBT) and Monero (XMR).

Cyber-attacks

• 5 March 2025, a Chinese individual, Zhou Shuai, and Shanghai Heiying Information Technology Company, Limited, were added to the SDN list for cyber-related sanctions.
• On 21 March 2025, OFAC removed the designation of the virtual currency mixer Tornado Cash, along with numerous associated digital currency addresses, from the SDN list.

Transnational crime

• 12 March 2025, OFAC updated its Specially Designated Nationals and Blocked Persons (SDN) List to include actions against the FOXTROT Network. These sanctions target criminal activities and focus on disrupting the operations of transnational criminal organisations. OFAC has placed an individual, Rawa Majid, also known as Miran Rekawt Othman and “Kurdish Fox”, and an entity, the FOXTROT NETWORK, on the SDN list. The FOXTROT NETWORK is based in Sweden and was established between 2015 and 2019.

Iran

• 20 March 2025, OFAC updated the SDN list to include one individual, ten entities, and eight vessels, all linked to Iran’s petrochemical industry. These additions are part of ongoing efforts to enforce sanctions related to Iran’s petroleum trade, specifically under Executive Order 13902. The listed entities and vessels, located in various countries including China, Hong Kong, Panama and others, are accused of engaging in activities contrary to existing sanctions.
• 13 March 2025, OFAC added several entities and vessels to its SDN List, focusing on those involved in facilitating sales of Iranian petroleum and petrochemical products. The restrictive measures include the designation of one individual, 17 entities and 12 vessels.
• On 25 March 2025, OFAC designated three Iranian individuals, Taqi Daneshvar, Reza Amiri Moghadam, and Gholamhossein Mohammadnia, for being associated with the Iranian Ministry of Intelligence and Security (MOIS). These individuals are now subject to secondary sanctions. The Iranian Ministry of Intelligence and Security (MOIS) has been sanctioned for its involvement in the hostage-taking.

These measures are consistent with Executive Order 13902 and Executive Order 13846, which are intended to prevent Iran from circumventing sanctions. These designations freeze any assets of the designated parties within US jurisdiction and generally prohibit US persons from dealing with them.

General

• On 20^th March 2025, OFAC published a Final Rule to extend the recordkeeping requirements from five to 10 years. This change coincides with the extension of the statute of limitations for violations of certain OFAC-administered sanctions.

Counter-terrorism

• On 5 March 2025, OFAC issued a number of general anti-terrorism licences (22A, 23A, 24A, 25A, 26A and 28A) relating to Ansarallah-related transactions. These licences cover areas such as agricultural commodities, telecommunications, remittances, fuel offloading, port and airport operations, and diplomatic missions. OFAC has also published a new counterterrorism FAQ (FAQ 1219).
• On the same day, OFAC added nine individuals and two entities to the Specially Designated Nationals and Blocked Persons (SDN) List. Eight of the individuals and one entity, Al-Jabri General Trading and Investment Co, are linked to Ansarallah. These designations include individuals involved in the management and operations of the group.
• On 18 March 2025, OFAC issued a new counterterrorism-related alert regarding the designation of international cartels as Foreign Terrorist Organisations and Specially Designated Global Terrorists. In addition, one individual, Jumilca Sandivel Hernandez Perez, operating out of Mexico, was added to the Specially Designated Nationals and Blocked Persons (SDN) List due to her ties to the Lopez People Smuggling Organization.

This measure targets international cartels and associated persons involved in terrorism-related activities. The aim is to disrupt their operations and financial networks by designating them as Foreign Terrorist Organisations and Specially Designated Global Terrorists.

United Kingdom

Global Human Rights

• On 24 March 2025, the UK designated Vinayagamoorthy Muralitharan, also known as Colonel Karuna Amman, under the Global Human Rights Sanctions Regulations 2020. The UK government declared that Muralitharan is responsible for serious human rights violations, including unlawful killings and torture during the 26-year armed conflict in Sri Lanka.
• On 24 March 2025, the UK designated Jagath Jayasuriya under the Global Human Rights Sanctions Regulations 2020. Under his command, Sri Lankan army personnel committed extrajudicial killings and acts of torture or cruel, inhuman and degrading treatment during the final stages of Sri Lanka’s civil war.
• On 24 March 2025, the UK designated Wasantha Karannagoda under the Global Human Rights Sanctions Regulations 2020, imposing an asset freeze and travel ban. The UK Government declared that Karannagoda, as commander of the Sri Lankan Navy from September 2005 to July 2009, has command responsibility for unlawful killings and acts amounting to torture or cruel, inhuman and degrading treatment during Sri Lanka’s civil war.
• On 24 March 2025, the UK designated Vinayagamoorthy Muralitharan, also known as Colonel Karuna Amman, under the Global Human Rights Sanctions Regulations 2020. The sanctions imposed include an asset freeze and travel ban. The British government stated that Muralitharan is responsible for serious human rights violations, including unlawful killings and acts of torture during Sri Lanka’s 26-year civil war.

The Global Human Rights Sanctions Regulations 2020 were introduced to deter and ensure accountability for serious human rights abuses, such as violations of the right to life and freedom from torture. Sanctions imposed include asset freezes and travel bans. The designations reflect the UK’s commitment to tackling serious human rights violations around the world.

 

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In Madrid, 31 March 2025

International Trade and Sanctions Department

Lupicinio International Law Firm