Sanctions Watch | Weekly Vol. 125

Sanctions Watch Vol 125

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

South Africa Removed from FATF ‘Grey List’ After Major Anti-Money Laundering Reforms

South Africa has been officially removed from the Financial Action Task Force’s (FATF) “grey list,” nearly three years after being placed under increased monitoring for deficiencies in its anti-money laundering and counter-terrorist financing systems. The FATF, a global watchdog for money laundering and terrorist financing, announced the decision in Paris following its three-day plenary meeting.

Countries on the grey list are subject to heightened scrutiny until they address strategic gaps in their financial systems. Over the past 32 months, South Africa worked closely with FATF assessors to meet its Action Plan obligations. According to the National Treasury, an on-site evaluation in July 2025 confirmed the sustainability of reforms implemented across government and regulatory institutions.

The Treasury described the delisting as a “major policy and institutional achievement,” acknowledging progress made to rebuild and strengthen key law enforcement and oversight bodies weakened during the state capture era. However, it warned that the country must maintain vigilance to avoid future relisting.

Authorities and private sector entities were urged to continue improving compliance, investigations, prosecutions, and sanctions under the Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) framework. FATF expects ongoing measurable outcomes as proof of South Africa’s commitment.

Alongside South Africa, Nigeria, Mozambique, and Burkina Faso were also delisted, marking significant progress across the African region in strengthening financial integrity and countering illicit financial flows.

U.S. Treasury Grants Temporary Authorization for Transactions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued General License No. 129 under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587). The license authorizes all transactions that would otherwise be prohibited under these sanctions when involving Rosneft Deutschland GmbH (RN Germany) and RN Refining & Marketing GmbH, along with any entities in which they hold a 50% or greater ownership interest, either directly or indirectly.

This authorization is valid until April, allowing companies to continue engaging in certain activities with these entities for an extended compliance period. However, the license does not extend to other Rosneft affiliates or any individuals or entities that remain blocked under the Russian Harmful Foreign Activities Sanctions Regulations.

OFAC clarified that this measure aims to ensure an orderly transition for energy-related and operational activities while maintaining the broader sanctions pressure on Russia.

Switzerland Adopts EU’s 18th Sanctions Package Against Russia and Belarus

The Swiss Federal Council announced the adoption of further measures from the European Union’s 18th package of sanctions against Russia and complementary measures against Belarus, taking effect on 30

October 2025. These actions reinforce Switzerland’s alignment with EU policies responding to Russia’s ongoing war in Ukraine.

The new sanctions intensify restrictions in trade, finance, and energy. Export bans now include chemicals for propellants, metals, and plastics that could enhance Russian military or industrial capacity. The Council also introduced an administrative system enabling SECO to monitor and prevent sanctions circumvention through third countries.

In the financial sector, Switzerland converted the partial restriction on financial messaging services for 23 Russian banks into a complete transaction ban, adding 22 more banks. It also extended existing measures to a total prohibition on all dealings with the Russian Direct Investment Fund (RDIF) and its subsidiaries, further isolating Russia from global financial markets.

The energy measures ban imports of refined petroleum products made from Russian crude oil in third countries (excluding Canada, Norway, the UK, and the U.S.) and impose a transaction ban on Nord Stream 1 and 2 pipelines.

Additionally, Switzerland implemented safeguards to block arbitration claims by Russian entities and fully adopted new EU measures against Belarus, further closing potential circumvention gaps and reaffirming Switzerland’s commitment to EU-aligned sanctions enforcement.

UK Issues Interim General Licence Allowing Limited Financial Operations for Designated Iranian Banks

The UK’s Office of Financial Sanctions Implementation (OFSI), under HM Treasury, issued a General Licence (INT/2025/7628424) under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019. The licence, effective from 23 October 2025 to 22 April 2026, grants temporary permissions to specific designated Iranian financial institutions—including Bank Melli, Bank Saderat Iran, Bank Tejarat, Persia International Bank Plc, and Iran Insurance Company—to carry out limited financial activities within the UK.

The licence allows these institutions (and their UK subsidiaries) to make payments for remuneration, pensions, IT and accountancy services for UK-based employees and directors, provided that all transactions occur through UK-regulated financial institutions. Payments to or from designated persons remain strictly prohibited. Additionally, entities must report monthly to HM Treasury with detailed records of transactions, including amounts, purposes, and payment routes, while maintaining documentation for six years.

This interim measure aims to facilitate essential domestic operations of these sanctioned entities in compliance with UK law, ensuring employment and business continuity while maintaining broader sanctions integrity against Iran. The licence may be revoked, varied, or suspended at any time by HM Treasury.

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