International Sanctions · May 2025

2025-05-30 International Sanctions Newsletters

Tabla de contenidos

1 European Union
2 United States
3 United Kingdom

European Union

Russia

On the 13^th of May 2025, the European Union adopted Council Regulation (EU) 2025/903, amending Regulation (EU) No 269/2014, and Council Decision (CFSP) 2025/904, amending Decision 2014/145/CFSP, concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine.

This amendment introduces a new listing criterion targeting natural or legal persons, entities, or bodies that have participated in or enabled transfers of ownership, control, or economic benefit of the business interests of leading businesspersons operating in Russia, thereby significantly frustrating existing sanctions. Additionally, it stipulates that leading businesspersons who claim to have transferred their business interests after 24 February 2022 will remain on the sanctions list unless sufficient, recent, and reliable information demonstrates they no longer meet the listing criteria.

On the 20th of May 2025, the Council of the European Union adopted Council Implementing Regulation (EU) 2025/965, which implements Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilising activities.

This implementing regulation adds 21 natural persons and six legal entities to the list of designated persons and entities subject to restrictive measures.

On the same day, the Council of the European Union adopted Council Implementing Regulation (EU) 2025/958, which implements Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia.

This implementing regulation adds 28 natural persons to the list of designated individuals subject to restrictive measures.

On the same day, the Council of the European Union adopted Council Decision (CFSP) 2025/931, amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, and Council Regulation (EU) 2025/932, amending Regulation (EU) No 833/2014, on the same subject.

This decision introduced several significant changes: 31 new entities were added to Annex IV, targeting those supporting Russia’s military-industrial complex, including certain entities in third countries indirectly contributing to Russia’s military and technological enhancement. Additionally, 189 vessels were listed in Annex XVI, identified as part of the ‘shadow fleet’ contributing to Russia’s energy revenues, and are now banned from accessing EU ports and locks. The decision also expanded the list of restricted items to include those such as chemical precursors to energetic materials and spare parts for machine tools. Furthermore, it extended the duration of an exemption from the oil price cap for the transport of crude oil from the Sakhalin-2 Project in Russia to Japan.

On the same day, the Council of the European Union adopted Council Regulation (EU) 2025/964, amending Regulation (EU) 2024/2642, and Council Decision (CFSP) 2025/963, amending Decision (CFSP) 2024/2643, concerning restrictive measures in view of Russia’s destabilising activities.

This amendment introduces several significant changes: it prohibits transactions involving tangible assets—such as vessels, aircraft, real estate, ports, airports, and physical elements of digital and communication networks—that are used in activities endangering critical infrastructure or violating international regulations and are attributable to or benefit the Russian government. Additionally, the regulation bans transactions with certain non-EU financial institutions and crypto asset service providers supporting destabilising activities. It also suspends broadcasting licences and prohibits the dissemination of content from designated media outlets involved in Russia’s disinformation campaigns within the EU.

On the same day, the Council of the European Union adopted Council Implementing Regulation (EU) 2025/933, which implements Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine.

This regulation adds 17 natural persons and 58 entities to the list of designated persons and entities subject to restrictive measures. Among the newly designated individuals are individuals involved in the manufacture of electronics and other high-tech components used by the Russian armed forces.

On the 26th of May 2025, the Council of the European Union adopted Council Implementing Regulation (EU) 2025/1081, which amends Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia.

This implementing regulation updates the list of designated persons by modifying the entries for two individuals.

The EU’s restrictive measures against Russia were established in response to the annexation of Crimea in 2014 and the subsequent destabilization of Ukraine. The legal framework for these measures is provided by Council Decision (CFSP) 2024/1484 and Council Regulation (EU) 2024/1485. The measures include asset freezes, travel restrictions, and limitations on economic relations with specific sectors and regions.

Non-proliferation of chemical weapons

On the 20^th of May 2025, the Council of the European Union adopted Council Implementing Regulation (EU) 2025/959, implementing Regulation (EU) 2018/1542 concerning restrictive measures against the proliferation and use of chemical weapons.

This regulation adds three entities to the list of designated persons: Radiological, Chemical and Biological Defence Troops of the Ministry of Defence of the Russian Federation, the 27th Scientific Centre of the Ministry of Defence of the Russian Federation and the 33rd Central Scientific Research and Testing Institute of the Ministry of Defence of the Russian Federation.

The EU’s restrictive measures under Regulation (EU) 2018/1542 and Council Decision (CFSP) 2018/1544, both adopted on 15 October 2018, were established to address the threat posed by the proliferation and use of chemical weapons. These measures encompass asset freezes, travel bans, and prohibitions on making funds or economic resources available to listed individuals and entities.

Cyber attacks

On the 12^th of May 2025, the European Union published Council Implementing Regulation (EU) 2025/886, which implements Regulation (EU) 2019/796 concerning restrictive measures against cyber-attacks threatening the Union or its Member States.

This regulation updates the identifying information and statements of reasons for six individuals already listed under Annex I, Section A of Regulation (EU) 2019/796. The individuals are a Russian military intelligence officers or otherwise affiliated with GRU.

The EU’s restrictive measures under Regulation (EU) 2019/796 and Council Decision (CFSP) 2019/797, both adopted on 17 May 2019, were established to counter cyber-attacks that threaten the Union or its Member States. These measures encompass asset freezes, travel bans, and prohibitions on making funds or economic resources available to listed individuals and entities.

United States

Burma

On the 5^th of May 2025, the U.S. Department of the Treasury’s Ofice of Foreign Assest Control (OFAC) updated the Specially Designated Nationals List (SDN) including the designation of Saw Chit, Saw Htoo Eh Moo (A.K.A. Saw Eh Mhu), Saw Chit Thu (A.K.A. Maung Chit, Saw San Myint), linked to transnational criminal activities in Karen State, Burma, and Karen National Army (A.K.A. Karen Border Guard Force, Kayin Border Guard Force), which is furthermore engaged in armed trafficking and illegal resource exploitation.

The designations aim to disrupt the exacerbation of Burma’s political and humanitarian crises. These individuals and groups are accused of undermining governance through violence, corruption, and illicit resource extraction, which perpetuates instability in the region.

Haiti

On the 2^nd of May 2025, OFAC updated the SDN including the designations of Gran Grif (a.k.a. Baz Gran Grif; Gran Grif De Savien) and Viv Ansanm (a.k.a. Fos Revolisyone G9 An Fanmi E Alye; G9 Fanmi E Alye; G-Pep; “G-9”), groups accused of engaging in criminal activities that undermine democratic processes and security in Haiti, and Involved in destabilizing governance through violent and illicit operations.

These sanctions aim to disrupt networks contributing to Haiti’s political and humanitarian crises. The U.S. government emphasized its commitment to countering transnational terrorism and organized crime, particularly groups exploiting instability for financial gain or territorial control. Recent updates to the SDN List reflect ongoing scrutiny of Caribbean-based threats, reinforcing the Treasury’s strategy to isolate malign actors through financial restrictions.

Iran

On the 8^th of May 2025, OFAC updated the SDN including the designations of Ketan Rajendra Agarwal, and Lincoln Francisco Viegas, Indian nationals; and of China Chlorate Tech Co. Ltd.; Baogang Dongying Donggang Logistics and Warehousing Co., Ltd. (China), Hebei Xinhai Chemical Group Co., Ltd. (China), Saman Tejarat Barman Trading Company (Iran) and and furthermore, of six crude oil tankers, all linked to evade restrictive measures regarding the trade of Iranian oil and the provision of military aid to Iran.
On the 12^th of Mar 2025, OFAC updated the SDN including the designations of Sayyed Mohammad Reza Seddighi Saber, head of SPND’s Shahid Karimi Group, which conducts explosives-related research applicable to nuclear explosive devices. Ahmad Haghighat Talab, a senior SPND official and nuclear scientist previously involved in Iran’s Amad Project, was sanctioned for coordinating dual-use nuclear research. Mohammed Reza Mehdipur, head of SPND’s Shahid Chamran Group, was designated for his role in advancing nuclear and explosives research. The entity Fuya Pars Prospective Technologists (also known as Ideal Vacuum), an SPND-affiliated company, was sanctioned for attempting to procure and fabricate equipment usable in nuclear weapons development.
On the 13^th of May 2025, OFAC updated the SDN including the designations of Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), an Iranian oil firm identified as a front for Iran’s Armed Forces General Staff (AFGS); and Mohammad Khorasani Niasari, an Iranian national who served as a financial inspector for Sepehr Energy and its affiliates. The sanctions also target several entities and two vesselsthat assisted Sepehr Energy in its operations.
On the 14^th of May 2025, OFAC updated the SDN including the designations of Iranian nationals Mohammad Rezai and Hamed Dehghan, as well as Chinese nationals Qin Jinhua, Qin Dehui, Wang Chao, and Wang Piao. The sanctioned entities encompass Iran-based companies such as Advanced Fiber Development Company (AFDCO), Pishtazan Kavosh Gostar Boshra LLC (PKGB), Sarmand Sazeh Sazan Soroush, Sharif Hamrah Science and Technology Researchers (SHSTR), and Narin Sepehr Mobin Isatis (NSMI). Additionally, furthermore several China-based firms were designated. The action aims to disrupt Iran’s efforts to indigenize the production of carbon fibre and related materials essential for its ballistic missile program, thereby impeding the capabilities of the Islamic Revolutionary Guard Corps (IRGC) and its associated entities.

These actions align with broader U.S. sanctions programs which target Iran’s activities and WMD proliferation. Sanctions on shipping firms and vessels address Iran’s use of covert maritime networks to bypass oil export restrictions.

Venezuela

On the 21st of May 2025, OFAC updated the SDN removing the designation of Alejandro Antonio Fleming Cabrera, who previously held various positions within the Venezuelan government, including Vice Minister for Europe of the Ministry of Foreign Affairs.

Counter-narcotics

On the 1^st of May 2025, OFAC updated the SDN including the designations of Alvaro Noe Morfin Morfin, Cesar ‘Primito’ Morfin Morfin, and Remigio Morfin Morfin, Mexican nationals and key figures in the operations of the Carte; de Jalisco Nueva Generación (CJNG), and Grupo Jala Logistica S.A. de C.V. and SLA Servicios Logisticos Ambientales S.A. de C.V., Mexican companies linked with the logistic operations of CJNG.
On the 21^st of May 2025, OFAC updated the SDN including the designations of Miguel Angel de Anda Ledezma, residing in Nuevo Laredo, Tamaulipas, oversees the procurement of firearms and ammunition for of the Mexico-based Cartel del Noreste (CDN), and Ricardo Gonzalez Sauceda, who served as the second-in-command of CDN until his arrest by Mexican authorities in February 2025.

The CDN, has been involved in narcotics trafficking, human trafficking, arms trafficking, money laundering, and acts of terrorism, including a 2022 attack on the U.S. Consulate in Nuevo Laredo. In addition to the May 21^st designations, OFAC updated its SDN List to reflect changes concerning the Cartel del Noreste. The organization, previously listed under the alias “Los Zetas,” is now primarily identified as “Cartel del Noreste,” with “Los Zetas” and “Northeast Cartel” recognized as alternate names. This entity is classified as a transnational terrorist group and a criminal organization.

The designations target individuals and entities linked to the drug cartels and thereby disrupting the cartel’s operations, responsible for trafficking fentanyl and other drugs into the U.S., and thus exacerbating the opioid crisis.

Counter-terrorism

On the 1^st of May 2025, OFAC updated the SND including the designations of Bagsak Shipping Inc. (Mauritius), Zaas Shipping & Trading Co (Lebanon/Marshall Islands), Great Success Shipping Co (Lebanon), and the vessels owned by such companies for providing material support to Ansarallah, the Houthi movement in Yemen.
On the 15^th of May 2025, OFAC updated the SDN including the designations of Mu’in Daqiq Al-‘Amili, a senior Hizballah representative based in Qom, Iran, who coordinated cash transfers from Iran to Hizballah officials in Lebanon; Jihad Alami, responsible for receiving and distributing these funds; Fadi Nehme, an accountant and business associate of Hizballah’s Central Finance Unit chief, involved in managing financial services for the group; and Hasan Abdallah Ni’mah, who facilitated funding and networking opportunities for Hizballah across Africa, including coordinating substantial financial support to the Hizballah-aligned Islamic Movement of Nigeria.

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.

General Licences

On the 15^th of May 2025, OFAC has issued Russia-related General License 124, “Authorizing Petroleum Services Related to the Caspian Pipeline Consortium and Tengizchevroil” and has updated FAQ 1216 accordingly.

United Kingdom

Russia

On the 1^st of May 2025, one variation under the Russia sanctions regime.
On the 9^th of May 2025, 101 new specifications and 9 new designations were added. Romarine AS was designated for its involvement in the Russian energy sector, specifically through its trade of Russian oil, thereby supporting the Russian government.
On the 20^th of May 2025, the UK added 82 new designations and 18 new specifications under the Russia sanctions regime. The sanctions targeted entities and individuals supporting Russia’s military machine, energy exports, and information war, as well as financial institutions aiding Russia in circumventing existing sanctions.
On the 23^rd of May 2025, an administrative amendment was made.

The UK’s Russia sanctions regime was established in response to Russia’s annexation of Crimea in 2014 and significantly expanded following the intervention of Ukraine in February 2022. The sanctions aim to pressure the Russian government to cease actions undermining Ukraine’s sovereignty and territorial integrity by targeting individuals and entities supporting the Russian government, particularly in the military, energy, and financial sectors.

Zimbabwe

On the 27^th of May 2025, the UK made 5 delisting: Owen Ncube, Isaac Moyo, Godwin Matanga, Anselem Sanyatwe, and the entity Zimbabwe Defence Industries (ZDI). The revocations follow a similar move from the European Union in February 2025, when they delisted their last remaining entity (ZDI) whilst renewing their existing Zimbabwe sanctions framework.

The UK’s Zimbabwe sanctions regime targets individuals and entities responsible for human rights violations and undermining democracy and the rule of law in Zimbabwe.

Isil (Da’esh) and Al-Qaeda

On the 23^rd of May 2025, the UK made 12 administrative amendments and 1 delisting under the Isil (Da’esh) and Al-Qaeda sanctions regime.

The UK’s ISIL (Da’esh) and Al-Qaeda sanctions regime implements United Nations sanctions targeting individuals and entities associated with these terrorist organizations. The sanctions aim to prevent terrorism and protect UK national security interests.

Global Human Rights

On the 20^th of May 2025, the UK added 7 new designations for threatening, perpetrating, promoting and supporting, acts of aggression and violence against Palestinian individuals.

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 human rights violations.

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In Madrid, 31 May 2025

International Trade and Santions Department

Lupicinio International Law Firm