Sanctions Watch | Weekly Vol. 108

Sanctions Watch Vol 108

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

1. U.S. Treasury Issues Final Rule Imposing Sanctions on the International Criminal Court

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the final rule implementing sanctions against the International Criminal Court (ICC) under Executive Order (E.O.) 14203, signed by President Donald J. Trump on February 6, 2025. This action follows accusations that the ICC has engaged in “illegitimate and baseless” proceedings targeting U.S. and Israeli personnel. The sanctions were enacted in response to ICC arrest warrants against Israeli Prime Minister Benjamin Netanyahu and former Defense Minister Yoav Gallant.

The rule codifies sanctions under 31 CFR Part 528 and blocks property and interests in property of designated individuals associated with the ICC, including Prosecutor Karim Khan. It prohibits U.S. persons from engaging in transactions with such individuals and includes penalties for violations. OFAC also incorporated six general licenses (GLs 2 through 7) authorizing certain exceptions such as legal representation, medical services, and transactions necessary for U.S. government business.

The rule was published without prior notice under exemptions applicable to foreign affairs functions and national emergency actions, as declared by the President. These measures reflect a broader U.S. policy to oppose ICC jurisdiction over U.S. and allied personnel, affirming that such actions by the ICC represent a threat to U.S. national security and sovereignty. OFAC intends to supplement this rule with more detailed regulations and interpretive guidance in the future.

2. UN Security Council Unanimously Renews Sanctions on Democratic Republic of the Congo until July 2026

The United Nations Security Council unanimously adopted Resolution 2783 (2025), renewing the sanctions regime on the Democratic Republic of the Congo (DRC) until 1 July 2026. The resolution, enacted under Chapter VII of the UN Charter, maintains measures related to arms embargoes, financial restrictions, and travel bans to curb violence and destabilization, particularly in the eastern region of the country.

The Council also extended the mandate of the Group of Experts monitoring the sanctions until 1 August 2026. The Group is tasked with submitting a mid-term report by 30 December 2025, a final report by 15 June 2026, and monthly updates to the Council.

France, which drafted the resolution, emphasized that the sanctions and monitoring regime are essential tools for peace in the Great Lakes region. The French representative referenced recent progress, including the 27 June peace agreement draft signed by the foreign ministers of the DRC and Rwanda under U.S. mediation.

The resolution reiterated that the DRC government’s armed and security forces are exempt from the arms embargo and notification procedures, reaffirming decisions made on 2 May 2024.

Additionally, the resolution highlighted the UN’s ongoing commitment to justice for the killing of two UN experts and four Congolese nationals, urging continued support for the DRC’s national investigation. Guyana, the outgoing Council President, welcomed the consensus and praised collaborative efforts among Council members.

3. EU Renews Economic Sanctions on Russia Until January 2026 Over Ongoing War in Ukraine

The European Council extended its economic sanctions on the Russian Federation for six more months, until 31 January 2026, in response to Russia’s ongoing war of aggression against Ukraine. These restrictive measures, originally introduced in 2014 and significantly expanded since February 2022, are part of the EU’s continued efforts to counteract Russia’s destabilizing actions.

The sanctions package includes wide-ranging sectoral restrictions on trade, finance, energy, technology, dual-use goods, transport, and luxury goods. Notably, it bans the import of seaborne crude oil and certain petroleum products from Russia, disconnects key Russian banks from the SWIFT system, and suspends Kremlin-backed disinformation channels within the EU. Additional measures are in place to prevent sanctions circumvention.

The Council emphasized that Russia’s illegal military aggression continues to violate international law, particularly the UN Charter’s prohibition on the use of force. As such, the EU reaffirmed its position to uphold the current measures and impose additional sanctions if necessary.

Since 24 February 2022, the EU has introduced 17 sanction packages, reinforcing its stance through asset freezes, travel bans, and economic isolation of Russian-controlled regions, including Crimea, Sevastopol, and parts of Donetsk, Kherson, Luhansk, and Zaporizhzhia.

The European Council reiterated its unwavering support for Ukraine’s sovereignty, and backed the implementation of Ukraine’s Peace Formula, insisting no decisions on Ukraine be taken without its consent. The EU reaffirmed readiness to escalate pressure on Russia as the conflict continues.

4. UK Tightens Arms Controls on Armenia and Azerbaijan to Curb Regional Escalation

The UK Government announced a significant refinement of its long-standing arms embargo on Armenia and Azerbaijan, originally based on the OSCE’s 1992 request to halt arms transfers to combatants in the Nagorno-Karabakh region.

The updated embargo now targets specifically “weapons, ammunition, and munitions”, aligning with entries ML1–ML4 of the UK Military List. Unlike the broader interpretation from 2014, this revision removes previous geographic restrictions, notably eliminating the condition that restricted arms only if intended for use in Nagorno-Karabakh. Now, the embargo covers any relevant arms that may be used along the Armenia-Azerbaijan land border by their military, police, security forces, or associated government entities.

Key exemptions remain in place. Equipment destined for humanitarian, peacekeeping, research, or media organizations is not automatically subject to the embargo unless there is a risk of diversion to military use. The UK continues to assess all export and trade license applications on a case-by-case basis under its Strategic Export Licensing Criteria.

Additionally, transit and transshipment controls have tightened: military goods passing through or transiting via the UK en route to Armenia or Azerbaijan require a UK export license, with the standard transit exemptions not applicable.

This shift reflects heightened UK scrutiny and a targeted approach to arms control in a persistently volatile region, aligning with international diplomatic concerns and export control principles.

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