Sanctions Watch | Weekly Vol. 102

Sanctions Watch Vol 102

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

1. OFAC Grants Conditional License for Sanctioned Iranian Vessel ‘Tinos I’ Under OFAC Oversight

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License Q under Executive Order 13902, allowing limited transactions involving the Iranian-linked vessel M.V. Tinos I (IMO: 9969821) while it remains in U.S. waters. The license permits essential operations such as safe docking, crew safety maintenance, emergency repairs, and environmental protection measures. Furthermore, it authorizes the sale of the vessel, provided that all proceeds are deposited into a blocked interest-bearing account at a U.S. financial institution.

The license also applies to Meisam Emamjomeh and Pearl Petrochemical FZE, both connected to the sanctioned vessel. However, it explicitly prohibits entry into new commercial contracts, transactions outside U.S. jurisdiction, debits to blocked accounts, or any action otherwise restricted under E.O. 13902 without further authorization.

This move reflects a strategic balancing act by the U.S. government—facilitating maritime safety and environmental precautions while strictly enforcing sanctions against Iranian-affiliated entities. The case underscores the complexity of sanction enforcement in global trade and highlights OFAC’s nuanced approach to compliance and humanitarian considerations in high-stakes geopolitical contexts.

2. U.S. Treasury Eases Sanctions: Broad General License Authorizes Key Transactions Involving Syria

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 25, marking a notable shift in its Syrian sanctions framework. The license authorizes certain transactions previously prohibited under the Syrian Sanctions Regulations (31 CFR part 542) and related sanctions targeting weapons proliferation, global terrorism, and financial networks associated with Iran and North Korea. Under the new license, individuals and entities may now engage in transactions that were previously restricted with specific Syrian entities and individuals listed in the license’s annexe, provided they are not separately listed on OFAC’s Specially Designated Nationals (SDN) list.

Notable entities now authorized for transactions include the Commercial Bank of Syria, Central Bank of Syria, Syrian Petroleum Company, and even state institutions like the Syrian Ministry of Petroleum and Mineral Resources and the Ministry of Tourism. However, the license does not permit dealings with SDNs not listed in the annex or with governments of Iran, Russia, or North Korea. This development signals a calibrated policy maneuver, potentially aimed at fostering controlled economic engagement while maintaining core national security restrictions. OFAC clarified that all other U.S. laws, including ITAR and EAR, still apply, and unblocking of assets remains unauthorized under this license.

3. OFSI issued Temporary License to Wind Down Financial Ties with Russian Entities

The UK’s Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, issued General License INT/2025/6275812 under regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019. This license authorises a time-limited exemption, allowing individuals and regulated financial institutions to wind down transactions involving two designated Russian entities: the St. Petersburg Currency Exchange (JSC SPCEX) and the Non-Bank Credit Organisation Joint-Stock Company Petersburg Settlement Centre (JSC PSC).

The license permits the closure of existing positions, transactions, or relationships involving these entities. Activities undertaken must be limited strictly to those necessary for winding down obligations. The license also outlines that persons, relevant institutions, or the designated parties (DPs) may execute related actions, provided these do not breach other sanctions, unless explicitly permitted under this or other issued licenses.

This license is valid from 20 May 2025 until 23:59 on 19 June 2025. OFSI retains the authority to revoke, vary, or suspend it at any time. All actions under this license must comply with the UK’s data protection laws. This step reflects the UK’s continuing sanctions strategy while facilitating an orderly disengagement from prohibited Russian financial relationships.

4. OFSI issued General License for Insurance Premium Payments to Russia’s Deposit Insurance Agency

The Office of Financial Sanctions Implementation (OFSI) under HM Treasury issued a General License (INT/2025/6279615) permitting specific financial interactions involving Russia’s State Corporation Deposit Insurance Agency. This license is granted under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, a legal framework established to enforce sanctions post-Brexit. The license authorizes individuals and entities, including various UK-regulated financial institutions, to make or process “Permitted Payments”—specifically, insurance premiums owed to the Russian Deposit Insurance Agency.

Institutions qualified under the Financial Services and Markets Act 2000, Payment Services Regulations 2017, Electronic Money Regulations 2011, and operators of recognized payment systems under the Banking Act 2009 are classified as “Relevant UK Institutions” and are permitted to process these payments. Strict compliance is mandatory. Any activity under this license must be meticulously recorded—either electronically or on paper—for a minimum duration of six years. However, this license does not waive other prohibitions under the Russia Regulations beyond what is expressly permitted. The license, effective from 20 May 2025, may be revoked, varied, or suspended at any time by HM Treasury. It reflects a controlled approach to managing sanctioned financial flows while ensuring necessary regulatory oversight and transparency.

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