Sanctions Watch | Weekly Vol. 105

Sanctions Watch Vol 105

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

1. OFAC released a quarterly licensing report for Iran-related transactions under Trade Sanctions Reform and export enhancement act (TSRA)

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published its quarterly report detailing licensing activities conducted under the Trade Sanctions Reform and Export Enhancement Act (TSRA) for the first quarter of 2025. The report covers OFAC’s authorization of exports of agricultural commodities, medicine, and medical devices to Iran, as mandated by Section 906 of the TSRA.

The TSRA allows for the export of these goods to Iran, provided they are intended to meet humanitarian needs and are not diverted for military or other prohibited uses. OFAC processes license applications to ensure compliance with U.S. sanctions while facilitating the flow of essential goods to the Iranian populace. The quarterly report serves to maintain transparency and accountability in the licensing process, aligning with the U.S. government’s commitment to humanitarian objectives amidst ongoing sanctions.

During this period, OFAC received a total of 31 license applications—8 for agricultural commodities and 23 for medical devices. Notably, no applications were submitted for medicine. Despite this volume, no new licenses were issued. OFAC did process 23 licensing determinations: 2 resulted in license amendments, 15 concluded with “return-without-action” letters, and 4 were resolved through general license guidance letters. There were zero denials or issued licenses, highlighting a cautious and procedural approach by the agency.

This report underscores the U.S. Treasury’s efforts to balance sanctions enforcement with humanitarian considerations, providing a framework for lawful trade that supports the Iranian people without compromising national security or foreign policy objectives.

2. OFSI amends GTLK general license to strengthen sanctions compliance and reporting requirements

The UK government amended General Licence INT/2023/3263556, which governs certain insolvency-related activities for the GTLK companies and their subsidiaries under UK sanctions regulations. The key changes to the licence included the addition of new regulation 18A, expanding the list of exemptions under the General Licence, and introducing several new definitions. Notably, the amendments included enhanced provisions on the handling of economic resources, with clearer instructions for freezing funds and treating transactions related to UK Prohibited Persons. A new reporting requirement was also added, mandating those involved in permitted activities to notify HM Treasury and provide up-to-date contact details within 14 days of making the first payment under the licence.

The next day, on June 13, 2025, the UK Treasury made a clarificatory update to Permission 4.2 under the licence, ensuring that any funds made available to designated persons (DPs) must be held in a frozen account. This change aims to tighten oversight and prevent the illicit transfer of resources in violation of UK sanctions.

The General Licence, initially issued in August 2023, now includes more stringent measures designed to ensure greater compliance and oversight over financial activities related to the insolvency proceedings of GTLK entities. It has been extended until 2030, allowing for continued regulation of these critical financial processes in alignment with international sanctions. The new requirements underscore the UK’s commitment to maintaining rigorous enforcement of sanctions.

3. Australia’s Sanctions Office issued 10 new guidance and advisory notes to strengthen compliance

The Australian Sanctions Office (ASO), operating under the Department of Foreign Affairs and Trade (DFAT), introduced 10 updated guidance and advisory notes aimed at assisting regulated entities in understanding and adhering to Australian sanctions obligations. These documents are designed to provide clarity on compliance requirements across various sectors, including maritime, remittance services, fintech, artificial intelligence, and employment with designated individuals or entities.

The guidance notes offer detailed information on specific sectors, outlining potential risks and compliance strategies. For instance, the advisory note on the information technology sector highlights the importance of customer identification and transaction monitoring to mitigate sanctions risks. Similarly, the note on touring companies, musicians, and sports professionals emphasizes the need for due diligence when engaging in activities in sanctioned countries.

Additionally, the ASO has issued advisory notes focusing on low-risk sectors, information technology, touring professionals, and holders of political office, providing tailored advice to these groups. These notes are part of the ASO’s ongoing efforts to support compliance and prevent inadvertent violations of sanctions laws. While these documents serve as valuable resources, they are not a substitute for legal advice. The ASO advises entities to seek independent legal counsel to assess how their specific activities may be affected by Australian sanctions laws.

4. EU proposed tough new sanctions on Russia targeting energy, banks, and military

The European Commission proposed its 18th sanctions package against Russia in response to the ongoing invasion of Ukraine. The sanctions primarily target Russia’s energy revenues, its financial sector, and its military industry. The proposal includes a full transaction ban on 22 additional Russian banks, extending beyond their removal from SWIFT to a complete restriction on financial dealings. It also aims at banks from third-party countries involved in circumventing existing sanctions, while designating the Russian Direct Investment Fund (RDIF) and its subsidiaries as targets. Furthermore, the package advocates for a reduction of the Group of Seven (G7) price cap on Russian crude oil from $60 per barrel to $45, attempting to curb Russia’s energy profits.  

Ukrainian President Zelenskiy welcomed the package but called for a lower price cap of $30 per barrel to intensify pressure on Russia. The proposal also includes measures to curb Russia’s shadow fleet of over 400 vessels and prohibit the import of refined products derived from Russian oil. The package is set to be discussed at a G7 leaders’ meeting in Canada. EU nations are expected to begin debating the proposal soon, with decisions expected to have significant implications for Russia’s financial and energy sectors.

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