Sanctions Watch | Weekly Vol. 111

Sanctions Watch Vol 111

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

UK Treasury Issues Wind-Down Licence for Intershipping Services LLC Amid Russia Sanctions Compliance

The UK’s Office of Financial Sanctions Implementation (OFSI), under HM Treasury, issued a Wind-Down General Licence (INT/2025/6397444) allowing Intershipping Services LLC—the designated representative of the Gabonese Maritime Administration—to disengage from existing financial and contractual relationships legally. This measure was granted under Regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019.

The licence authorizes persons, relevant UK financial institutions, and the designated party (DP) to undertake activities reasonably necessary to wind down or divest from transactions involving Intershipping Services LLC. Permitted actions include terminating contracts, closing financial positions, and completing related transactions within the licence’s timeframe.

Importantly, this wind-down authority applies only to transactions that would otherwise be prohibited under Regulations 11 to 15 of the Russia Regulations. It does not allow for new business operations or activity that contravenes other sanction regulations.

The licence is strictly time-bound, becoming effective from 21 July 2025 and expiring on 18 September 2025. All activities conducted under this licence must be fully documented and retained for six years, either digitally or in physical form, ensuring accountability and transparency.

This action reflects the UK government’s effort to enforce sanctions against Russia while enabling an orderly disengagement from affected business relationships, thereby reducing disruption to global maritime and financial operations linked to Gabon’s shipping administration

UK Issues General Licence for Intershipping Services LLC Amid Russian Sanctions

The UK’s Office of Financial Sanctions Implementation (OFSI), under HM Treasury, issued General Licence INT/2025/6403704 to Intershipping Services LLC, a UAE-based entity representing the Maritime Administration of the Gabonese Republic. The licence provides limited exemptions under Regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019.

This authorization permits Intershipping Services LLC—referred to as the Designated Person (DP)—to carry out certain business operations that would otherwise violate Regulations 11 to 15 of the Russia Regulations. Specifically, “Relevant Ships” (those owned or operated by the Gabonese Government) are allowed to continue business dealings with Intershipping Services LLC, including making and receiving payments under existing or new contracts.

Furthermore, UK-regulated financial institutions are authorized to process these payments, provided they comply with the licence’s conditions. However, the licence explicitly does not permit actions that would breach other provisions of the Russia Regulations outside the granted scope.

The licence is valid from 21 July 2025 and may be varied, suspended, or revoked by HM Treasury at any time. This move reflects the UK’s ongoing effort to enforce targeted sanctions while allowing critical maritime and financial operations to continue under strict regulatory oversight.

UK Government Issues New Sanctions Regulations Targeting Human Trafficking and Irregular Migration

The UK government has introduced the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025, accompanied by official guidance issued under Section 43 of the Sanctions and Anti-Money Laundering Act 2018. These regulations aim to deter and disrupt individuals and entities engaged in people-smuggling, human trafficking, or facilitating irregular migration for destabilizing purposes.

Applicable throughout the UK and extraterritorially to all UK persons—including companies and individuals—the regulations empower ministers to designate those involved in such activities for targeted financial, immigration, and director disqualification sanctions. Designated individuals face asset freezes and prohibitions on the use or provision of funds or economic resources, both directly and indirectly. Travel bans are also enforced, denying entry, visas, or continued stay in the UK.

Additionally, director disqualification sanctions prohibit designated persons from participating in UK company management. Enforcement measures include severe penalties: up to seven years’ imprisonment for breaches of financial sanctions and up to two years for contraventions of director disqualification rules.

The Office of Financial Sanctions Implementation (OFSI) is responsible for financial enforcement, while the Insolvency Service handles director disqualifications. The Home Office oversees immigration sanctions. The regulations also impose mandatory reporting and record-keeping duties on relevant firms, including financial institutions. Certain exceptions apply automatically under defined conditions, while others require formal licences from OFSI or the Insolvency Service.

These may cover basic needs, legal fees, humanitarian assistance, and prior contractual obligations. The guidance encourages entities and individuals to seek legal advice when in doubt about compliance. This sanctions regime highlights the UK’s broader strategic intent to combat organized exploitation of vulnerable migrants and uphold global human rights and rule of law through a robust and enforceable legal framework.

UK Grants General Licence for Wind-Down of Litasco Middle East DMCC Transactions

The Council of the European Union adopted Council Decision (CFSP) 2025/1555, amending its earlier Decision (CFSP) 2021/1277 concerning restrictive measures in response to the ongoing situation in Lebanon. Originally enacted on 30 July 2021, Decision 2021/1277 established a framework for targeted sanctions to address the deteriorating political, economic, and humanitarian conditions in Lebanon, including corruption and the obstruction of reforms. The initial measures were set to expire on 31 July 2025.

However, following a formal review of the existing policy and the persistent instability within Lebanon, the Council decided to extend the validity of the sanctions by one additional year. As a result, the new expiry date for these restrictive measures is now set for 31 July 2026.

The decision formally replaces the original expiration clause in Article 9 of the 2021 decision. This move reflects the EU’s continued commitment to encouraging accountability and good governance in Lebanon. The updated decision entered into force the day after its publication in the Official Journal of the European Union, reinforcing the EU’s readiness to maintain pressure where political progress is lacking. The extension signals the EU’s ongoing concern over Lebanon’s crisis and underscores its willingness to keep sanctions in place as a tool of foreign policy and diplomatic leverage.

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