Sanctions Watch | Weekly Vol. 128

Sanctions Watch Vol 128

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

US Treasury Authorizes Certain Transactions for Paks II Nuclear Power Plant Project in Hungary

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 132, authorizing certain transactions involving the Paks II civil nuclear power plant project in Hungary. This includes financial transactions related to Paks II and affiliated entities, despite broader sanctions targeting Russian institutions under Executive Order 14024. The license specifically allows operations involving Russian banks such as Gazprombank, Vnesheconombank, Otkritie, and several others, alongside any entities in which these banks hold a 50% or greater interest.

However, the general license excludes transactions like maintaining correspondent accounts with certain Russian financial institutions and prohibits debits from U.S. financial institutions’ accounts related to the Russian Central Bank, National Wealth Fund, or Ministry of Finance. This action is part of ongoing efforts to manage sanctions while maintaining energy cooperation with Hungary.

UK Grants Temporary General License for Continued Business with Lukoil Bulgaria Entities Amid Ongoing Sanctions

The UK government issued General Licence INT/2025/7895596 under the Russia (Sanctions) (EU Exit) Regulations 2019, allowing continued business operations with Lukoil Bulgaria entities. The licence, granted by HM Treasury’s Office of Financial Sanctions Implementation, permits activities that would otherwise breach prohibitions set by UK sanctions against Russia. Specifically, it authorizes the Lukoil Bulgaria entities—including Lukoil Bulgaria EOOD, Lukoil Neftochim Burgas AD, Lukoil Aviation Bulgaria EOOD, and Lukoil Bunker Bulgaria EOOD—and their subsidiaries to engage in certain business transactions.

Under this licence, individuals and businesses may continue to make payments to and from Lukoil Bulgaria entities under existing or new contracts. This also includes the provision and receipt of economic resources. Relevant UK institutions, such as financial service providers and payment system operators, are authorized to process payments tied to these transactions.

The licence is effective from November 14, 2025, until February 14, 2026, with the possibility of amendments, revocation, or suspension at any time by HM Treasury. However, it does not authorize any actions that would violate other UK sanctions regulations. This decision provides a temporary exception to the sanction’s regime, allowing specific transactions to continue during the validity period, while still adhering to broader financial and legal constraints imposed on Russian entities under UK law.

The general licence emphasizes the UK’s ongoing compliance with international sanctions, specifically in the context of the geopolitical situation involving Russia.

Statement by the High Representative on the EU’s Alignment with Restrictive Measures on Niger

The European Union Council adopted Decision (CFSP) 2025/21361, which extended the application of existing restrictive measures regarding the situation in Niger until 24 October 2026. This decision represents the EU’s continued commitment to address the ongoing crisis in Niger through targeted sanctions. Countries including Albania, Armenia, Bosnia and Herzegovina, Iceland, Liechtenstein, Moldova, Montenegro, North Macedonia, Norway, Serbia, and Ukraine have aligned themselves with this decision. These countries have committed to ensuring that their national policies are in line with the EU’s stance and will abide by the sanctions measures outlined in the Council Decision.

The European Union has acknowledged and welcomed this alignment, signaling a unified international approach to the situation in Niger. By extending these measures, the EU aims to exert pressure on those responsible for undermining stability in Niger, while also promoting a coordinated response across Europe and its partners.

United Nations Security Council Extends Yemen Sanctions Mandate, Adopts Resolution 2801 (2025)

The United Nations Security Council voted to extend the mandate of the Yemen Sanctions regime, renewing the travel ban and asset freeze on designated individuals and entities until 14 November 2026. Resolution 2801 (2025) was adopted by 13 votes in favor, with 2 abstentions (China and Russia). The resolution also extends the mandate of the Panel of Experts, which assists the Council’s Yemen Sanctions Committee, until 15 December 2026, with plans for a review before 14 November 2026.

The resolution includes new measures, such as requiring the Panel of Experts to report by April 2026 on the flow of dual-use components and precursor chemicals, which are integral to the Houthi weapons program. It also calls for improved maritime interdictions to prevent vessels suspected of carrying arms from entering Yemen. Council members expressed concerns about the growing Houthi smuggling operations and their connections to terrorist groups like Al-Shabaab.

The United States and the United Kingdom highlighted the need for stronger measures against the Houthis, particularly concerning the smuggling of dual-use components, while expressing frustration that the resolution did not address Houthi ties with terrorist groups more explicitly. The Russian Federation and China, which abstained, raised concerns about the politicization of sanctions, urging a more diplomatic approach to resolving the conflict.

The resolution underscores the Council’s continued commitment to pressuring the Houthis while calling for a political solution to the ongoing conflict in Yemen.

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