Tabla de contenidos
European Union
Russia and Belarus
On 23 October 2025, the European Union adopted the nineteenth package of sanctions against Russia, one of the most forceful actions to date aimed at strengthening economic, energy and technological restrictions that limit the financing of the conflict in Ukraine.
Among the most significant measures is a total ban on imports of Russian liquefied natural gas (LNG), effective immediately for short-term contracts and, from 2027, for long-term contracts. Controls on Russia’s ‘ghost fleet’ are also being extended, with the inclusion of 117 new vessels and sanctions on third-country registries and companies that assist in the evasion of energy measures.
In the financial sphere, sanctions are extended to banks, energy companies and crypto-asset service providers, with transactions involving the Russian cryptocurrency A7A5 being prohibited.
Restrictions on the movement of Russian diplomats are also being tightened and the list of individuals and entities linked to the military effort and the deportation of Ukrainian minors is being expanded.
In trade and technology, the EU is tightening the ban on exports of dual-use goods and technologies and adding 45 new entities, mainly in Russia, China, India and Thailand.
A comprehensive analysis of the nineteenth package is available in the alert issued by the International Trade and Sanctions Department of Lupicinio International Law Firm here.
Proliferation and use of chemical weapons
On 13 October 2025, the EU adopted Council Decision (CFSP) 2025/2072 amending Decision (CFSP) 2018/1544 concerning restrictive measures against the proliferation and use of chemical weapons, extending sanctions until 16 October 2026.
Council Decision (CFSP) 2018/1544 of 15 October 2018 focuses on the adoption of restrictive measures by the European Union aimed at preventing the proliferation and use of chemical weapons. It establishes the freezing of assets of natural or legal persons who provide financial, technical or material support to activities related to chemical weapons, their manufacture, transport or use. The decision also prohibits the provision of funds or economic resources to these persons or entities and provides for certain exceptions, such as covering basic needs or medical expenses, among others.
ISIL (Daesh) and Al-Qaida
On 27 October 2025, the EU adopted Council Decision (CFSP) 2025/2207 amending Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda, thereby extending this sanctions regime until 31 October 2026.
Decision (CFSP) 2016/1693 constitutes the fundamental framework for European sanctions against terrorism linked to ISIL (Daesh) and Al-Qaida. The aim of these measures is to strengthen the fight against international terrorism by imposing sanctions on those who participate in or collaborate with these groups.
Niger
On 17 October, Council Decision (CFSP) 2025/2136 amending Decision (CFSP) 2023/2287 concerning restrictive measures in view of the situation in Niger was adopted by the European Union.
This amendment extends the sanctions until 24 October 2026, as established under Decision (CFSP) 2023/2287, which introduced restrictive measures in response to the political and security situation in Niger following the coup d’état of 26 July 2023.
United States
Russia
On 22 October 2025, the US Treasury Department imposed new sanctions on the Russian energy sector in response to Russia’s lack of commitment to a peace process to end the war in Ukraine. These sanctions seek to increase pressure on the Kremlin’s ability to finance its war machine and support a weakened economy, with the aim of promoting a peaceful resolution to the conflict.
Specifically, the actions sanction the two largest Russian oil companies: Open Joint Stock Company Rosneft Oil Company (Rosneft is an energy company specialising in the exploration, production, refining, transportation and sale of oil, natural gas and related products) and Public Joint-Stock Company Oil Company Lukoil (engaged in the exploration, production, refining, commercialization and distribution of oil and gas both in Russia and internationally).
These companies and their numerous subsidiaries in Russia are designated under Executive Order E.O. 14024, which prohibits all transactions with persons or entities operating in the energy sector of the Russian economy.
The sanctions mean that all property and interests owned by the designated persons and entities that are in the possession or control of US persons are blocked and must be reported to the Office of Foreign Assets Control (OFAC). Consequently, any transaction involving these assets, unless authorised, is prohibited.
In addition, these measures provide for the possibility of secondary sanctions for foreign financial institutions that maintain significant transactions or provide services related to the Russian military and industrial base.
Colombia
On 24 October, the US Treasury Department sanctioned President Gustavo Petro and members of his government for links to drug trafficking, extending asset freezes, travel bans and trade restrictions to family members and close associates.
Specifically, OFAC sanctioned the Colombian president and his wife and son, as well as the Minister of the Interior, justifying the sanction in the context of the fight against drug trafficking. The president’s son is accused of money laundering and illicit enrichment; his wife had her diplomatic appointment annulled on the grounds of unconstitutionality; and the Minister of the Interior is under investigation for corruption. Since Mr Petro took office in 2022, cocaine production in Colombia has reached its highest levels in decades, leading to a significant increase in the amount of the drug entering the United States. Treasury Secretary Scott Bessent maintains that the Colombian president has allowed drug cartels to flourish and has failed to take action to stop this situation.
These sanctions are applied in accordance with Executive Order (E.O.) 14059, which targets foreign nationals involved in international drug trafficking. It should be noted that in September 2025, the United States claimed that Colombia was not fulfilling its responsibilities in the area of drug control.
The sanctions consist of freezing all assets that these individuals have in the United States or under the control of US citizens. In addition, any type of transaction with them is prohibited, unless special authorisation has been granted. OFAC may also sanction foreign banks that have ties to these individuals.
Iran
On 9 October, the US Treasury Department announced through its Office of Foreign Assets Control (OFAC) that it had intensified its sanctions against the Iranian oil and petrochemical sector by designating more than 50 individuals, entities and vessels involved in facilitating sales and shipments of oil and liquefied petroleum gas (LPG) from Iran. These measures seek to curb a network that has enabled the export of petroleum products worth billions of dollars, which finance the Iranian regime and its support for terrorist groups.
Among those sanctioned are companies with registered offices in the United Arab Emirates and Hong Kong. Other companies that have facilitated transactions and cargo movements, including an oil terminal and a refinery in China, are also being sanctioned. Finally, multiple vessels from Iran’s so-called ‘ghost fleet’ are designated, which use techniques to conceal the origin of exported oil by transferring it between ships in the Persian Gulf and waters near Singapore and Malaysia.
These sanctions are based on Executive Orders 13902 and 13846, which target the Iranian oil sector and seek to dismantle its ability to generate revenue, in line with the maximum economic pressure campaign established by the Trump Administration in its ‘National Security Presidential Memorandum.’
Treasury Secretary Scott Bessent has stated that the action seeks to ‘disrupt Iran’s financing by dismantling key elements of its energy export machinery.’
United Kingdom
Russia
The United Kingdom expanded sanctions on Russia on 15 October, imposing its most severe sanctions package to date, with the aim of disrupting the energy revenues that finance Russian military capabilities. These measures mainly affect Russia’s two largest oil companies, Rosneft and Lukoil, which together export 3.1 million barrels of oil per day, with Rosneft alone accounting for 6% of global production and almost half of Russian production.
The British government has withdrawn Russian oil from the market, announcing a total of 90 sanctions that also include measures against four oil terminals located in China, 44 ships in the so-called ‘ghost fleet’ that transport Russian oil, and Nayara Energy Limited, which imported 100 million barrels of Russian crude oil in 2024 worth more than $5 billion.
These sanctions were announced in Parliament by Yvette Cooper, Minister for Foreign Affairs. Cooper highlighted the intensification of joint pressure with international partners to get Putin to end the military operation, as well as reaffirming the commitment to keep Russian oil off the market and prosecute those who facilitate the illegal invasion of Ukraine.
The measures also include sanctions on seven specialised methane tankers and the Chinese liquefied natural gas terminal Beihai, linked to the Russian Arctic LNG2 project, already sanctioned in February 2024. In addition, a ban on imports of refined petroleum products in third countries based on Russian crude oil was announced.
The UK has invested in the production of more than 85,000 military drones delivered to Ukraine this year, strengthening collaboration between the two countries. British sanctions also include restrictions on companies supplying essential electronic components for Russian drones and missiles, operating in Asia and the Middle East.
Since February 2022, sanctions implemented by the United Kingdom have frozen Russian assets worth £28.7 billion, reflecting the UK’s intention to block Russian financing.
Global irregular migration and human trafficking
On 22 October 2025, the Foreign Office added 13 individuals to the UK’s sanctions list. This list contains individuals or entities designated under regulations adopted pursuant to the UK Sanctions Act.
The Irregular Global Migration and Human Trafficking Regulations 2025 (S.I. 2025/902) were adopted under the ‘Sanctions and Anti-Money Laundering Act 2018’ and provides for the imposition of financial sanctions, specifically the freezing of funds and economic resources of persons who are or have been involved in the smuggling of migrants, trafficking in human beings or the exploitation of migration for destabilisation purposes.
Haiti
On 20 October 2025, the UK Foreign Office added two individuals to the sanctions list.
The Haiti Regulations 2022 (S.I. 2022/1281) (“the Regulations”) were approved on the basis of the ‘Sanctions and Anti-Money Laundering Act 2018’ and provide for the adoption of financial sanctions, in particular the freezing of funds and economic resources belonging to persons designated as being responsible for, complicit in or participating, directly or indirectly, in activities that threaten the peace, security or stability of Haiti.
Iran
On 30 October 2025, the Foreign Office updated its list of sanctioned persons, adding one person. This list contains details of persons or entities designated in accordance with the regulations adopted under the 2023 Iran Regulations (S.I. 2023/1314), which were adopted on the basis of the ‘Sanctions and Anti-Money Laundering Act 2018’ and establishes the application of financial sanctions, specifically the freezing of funds and economic resources of persons who are or have been involved in the commission of serious human rights violations or abuses in Iran, or in hostile activities by the Government of Iran or armed groups supported by that Government.
United Nations
Haiti
On 17 October, the Security Council renewed the arms embargo on Haiti and updated the list of those subject to sanctions in light of the worsening political and security crisis.
On 17 October 2025, the United Nations Security Council unanimously adopted a resolution extending the sanctions regime imposed on Haiti for another year. These sanctions include an arms embargo, travel bans and asset freezes, with the aim of stopping the illicit flow of arms to armed criminal groups responsible for serious acts of violence, especially in the capital, Port-au-Prince.
The resolution stresses that the situation in Haiti continues to pose a threat to peace and security in the region, exacerbated by a complex humanitarian crisis, natural disasters, economic instability and the impunity of armed gangs. It is estimated that between 270,000 and 500,000 illegal weapons are in circulation in Haiti.
The Council urges Member States to prevent the supply, sale or transfer of arms, as well as any technical assistance or financial support linked to military activities, to any non-state actors in Haiti. It also emphasises the need to strengthen customs, maritime and border controls, promoting regional cooperation to combat illicit arms trafficking.
The United Nations Office on Drugs and Crime provides technical assistance to Haiti and its partners to strengthen arms tracing, border control and financial investigations. The fight against corruption and illicit financial flows is essential to ensure effective compliance with the embargo.
The Council thus reaffirms its commitment to the sovereignty, independence, territorial integrity and unity of Haiti, with the aim of weakening armed groups and protecting the civilian population.
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In Madrid, 31 October 2025
International Trade and Sanctions Department
Lupicinio International Law Firm
