Sanctions Watch | Weekly Vol. 107

Sanctions Watch Vol 107

In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

1. U.S. Extends Authorization for Civil Nuclear Transactions Involving Russian Banks Until December 2025

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 115B under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587). This license authorizes specific transactions related to civil nuclear energy that would otherwise be prohibited under Executive Order (E.O.) 14024. The authorization extends until 12:01 a.m. EST on December 19, 2025.

The license applies to a group of major Russian financial institutions, including Gazprombank, Sberbank, VTB Bank, Alfa-Bank, Rosbank, Sovcombank, and others. It also covers any entity in which these banks hold a 50% or greater interest, directly or indirectly, as well as the Central Bank of the Russian Federation.

The authorization only pertains to transactions necessary to maintain or support civil nuclear energy projects that were initiated before November 21, 2024. It explicitly excludes transactions such as opening or maintaining correspondent or payable-through accounts for entities under Directive 2 of E.O. 14024, and any debits from U.S. financial institutions to accounts of the Russian Central Bank, National Wealth Fund, or Ministry of Finance.

Additionally, any transaction not expressly covered—particularly those involving blocked persons not listed under the license—remains prohibited unless otherwise authorized. This license replaces and supersedes the prior General License No. 115A issued on January 10, 2025.

2. U.S. Issues Sanctions Targeting International Criminal Court Over Alleged Overreach in Investigations Involving U.S. and Israeli Officials

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the International Criminal Court-Related Sanctions Regulations (31 CFR Part 528) to implement Executive Order (E.O.) 14203, signed by President Donald J. Trump on February 6, 2025. These sanctions respond to what the U.S. deems as “illegitimate and baseless” actions by the International Criminal Court (ICC), particularly its efforts to investigate and prosecute U.S. and Israeli personnel.

The rule declares a national emergency to counter the perceived threat posed by the ICC to U.S. sovereignty and national security. It blocks the assets of individuals and entities engaged in or supporting ICC investigations without U.S. or allied consent. Sanctioned individuals are also barred from entry into the United States. These include ICC officials, employees, agents, and potentially their family members. The only named individual in the annex is Karim Khan, Prosecutor of the ICC.

The regulation includes General Licenses 2–7, which allow for limited legal services, emergency medical care, U.S. government official business, and humanitarian provisions such as food, medicine, and medical devices for personal use. These rules are immediate, bypassing typical public consultation due to their national security nature.

The measure underscores the U.S. stance that ICC jurisdiction is not recognized over its nationals or those of its allies unless consent is provided, reaffirming U.S. opposition to international legal actions that could undermine its autonomy or endanger its personnel.

3. U.S. Lifts Broad Sanctions on Syria Following Leadership Change, Maintains Targeted Actions Against Assad Regime Crimes

The U.S. President issued an Executive Order revoking multiple Syria-related sanctions, reflecting a major shift in U.S. foreign policy in response to changes in Syrian leadership. The order terminates the national emergency declared in Executive Order 13338 (2004) and revokes several subsequent orders targeting the former Bashar al-Assad regime. This move acknowledges recent positive developments, including political reforms by the new Syrian government under President Ahmed al-Sharaa and increased regional stability.

However, the order simultaneously expands sanctions under Executive Order 13894 (2019), targeting individuals responsible for war crimes, narcotics trafficking, human rights abuses, and actions that undermine Syria’s peace and sovereignty. Notably, those linked to captagon production and the disappearance of U.S. nationals during the Assad regime remain sanctioned. The Caesar Syria Civilian Protection Act (2019) sanctions may now be suspended, and specific export and aid restrictions under the Syria Accountability Act and the Chemical and Biological Weapons Control and Warfare Elimination Act have also been waived, based on determinations of leadership change.

While economic restrictions are easing, the order reinforces strict counterterrorism designations, reaffirming the status of Hay’at Tahrir al-Sham (formerly al-Nusrah Front) and its leader, Ahmed al-Sharaa, as global terrorists. Additionally, it orders a review of Syria’s designation as a State Sponsor of Terrorism and calls for U.S. action at the United Nations to support sanctions relief aligned with counterterrorism and non-proliferation goals.

This dual approach aims to reward reform while ensuring accountability for past atrocities and ongoing threats to regional and U.S. security.

4. UK Issues Guidance to Non-UK Businesses on Sanctions Compliance

The UK government issued updated guidance for non-UK businesses operating outside the UK and Russia, focusing on compliance with UK sanctions related to Russia. This guidance addresses the risks of inadvertently circumventing UK sanctions, which can lead to significant consequences, including being designated under UK sanctions and facing restrictions on accessing UK financial services and markets. The guidance highlights that even businesses not directly under UK jurisdiction can be affected if they facilitate sanctioned activities. It provides practical steps for businesses to assess and mitigate these risks, emphasizing the importance of due diligence in supply chains and awareness of end-use destinations.

The UK government underscores its commitment to enforcing sanctions and preventing their circumvention through third countries. Non-UK businesses are advised to implement robust compliance measures to avoid unintended breaches of UK sanctions, which could result in severe disruptions to their operations and reputational damage. The guidance serves as a resource to help these businesses navigate the complexities of international sanctions and maintain compliance with UK regulations.

Know more about the product: PreScreening.io

Click here to book a free demo. 

Sanctions Watch is a weekly recap of events and news related to sanctions around the world.