RegRally Insights: Sanctions Essentials

ECOVIS ProventusLaw welcomes you to its monthly newsletter on Sanctions, which is dedicated to everyone who wants to understand the latest trends and developments, get tips from our experts, and deepen their knowledge.

Europol Boosts Sanctions Enforcement with Operation OSCAR

On the third anniversary of Russia’s invasion of Ukraine, Europol reinforces its commitment to tracking sanctioned assets through Operation OSCAR. Launched in April 2022, the initiative enhances financial investigations, intelligence sharing, and international cooperation with 44 partners, including Eurojust and Frontex. With over 90 investigations and 300+ operational contributions, Europol’s new Target Group on Sanctions within the EFECC strengthens enforcement efforts, ensuring a more coordinated response to sanctions evasion under the EU’s harmonised legal framework.

OFAC Expands Sanctions on Iran’s Oil Sector

The U.S. Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned Iranian individuals, maritime companies, and vessels involved in Iran’s oil trade to curb sanctions evasion under Executive Orders 13846 and 13902. The measures target key Iranian oil officials and a network of shipping and trading firms across the UAE, India, China, and other jurisdictions. Several crude oil and chemical tankers linked to these entities have also been blacklisted. These sanctions aim to disrupt Iran’s petroleum exports, restrict illicit financial flows, and reinforce compliance with U.S. economic measures.

OFAC SDN List Update

Newly Sanctioned Individuals:

Aleksandr Sergeyevich Bolshakov (Russia) – Linked to ZSERVERS.
Alexander Igorevich Mishin (Russia) – Also linked to ZSERVERS; associated with cryptocurrency transactions.

Newly Sanctioned Entity:

ZSERVERS (Russia & Netherlands) – IT service provider involved in cyber activities linked to multiple Bitcoin addresses.

Issuance of Executive Order Imposing Sanctions on the International Criminal Court.

New Executive Order:

O. 14203 (Feb 6, 2025) – Imposes sanctions on the International Criminal Court (ICC).

Newly Sanctioned Individual:

Karim Asad Ahmad Khan (UK) – ICC official, sanctioned under E.O. 14203.

EU Adopts 16th Sanctions Package Against Russia.

The European Union has introduced its 16th round of sanctions against Russia, further tightening restrictions in response to its ongoing war against Ukraine. The package targets key sectors: energy, trade, transport, infrastructure, and banking. A full transaction ban has been imposed on major Russian infrastructures, including two Moscow airports and key Volga ports. Nearly 200 individuals and entities face asset freezes, while 74 vessels and 53 companies linked to Russia’s military industry have been sanctioned. These measures aim to weaken Russia’s economic and military capabilities while reaffirming the EU’s commitment to supporting Ukraine.

G7 Foreign Ministers Reaffirm Support for Ukraine and Global Security

Meeting at the Munich Security Conference under Canada’s 2025 Presidency, G7 Foreign Ministers and the EU High Representative reinforced their commitment to Ukraine, financial support using Russian assets, and further sanctions if Russia refuses diplomacy. They condemned military aid to Russia from China, North Korea, and Iran.

The ministers emphasised peace efforts in the Middle East, condemned Hamas and Iran’s destabilising actions, and called for a ceasefire between Israel and Hamas. They opposed China’s coercive actions in the Indo-Pacific, demanded North Korea abandon its nuclear weapons, and addressed global crises in the DRC, Sudan, Haiti, and Venezuela. Their next meeting is set for March 12-14, 2025, in Charlevoix, Quebec.

EU Reaffirms Unwavering Support for Ukraine at Kyiv Summit

At the International Summit on the Support of Ukraine in Kyiv, European Commission President Ursula von der Leyen reaffirmed the EU’s steadfast commitment to Ukraine’s sovereignty, security, and European integration. Emphasising that Russia’s aggression threatens all of Europe, she stressed the need to resist any notion of capitulation.

The EU and Member States have provided EUR 134 billion in aid, securing Ukraine’s 2025 budget, with an additional EUR 3.5 billion set for March. Military assistance, alongside efforts to enhance European arms production, remains a top priority. Energy security is also crucial, with plans to fully integrate Ukraine and Moldova’s electricity markets with the EU by 2025. As part of ongoing pressure on Russia, the EU’s sixteenth sanctions package will reinforce economic and political measures to deter further aggression.

EU Commission Issues Payment Guidelines for Ukraine’s Government-Controlled Areas

The European Commission has issued guidelines to ensure secure and compliant financial transactions involving Ukraine’s government-controlled areas. To mitigate risks and enhance due diligence, stakeholders are advised to:

Include the Ukrainian payer or payee’s postal code in payment details.
Refer to the latest updates on the line of contact provided by the Ukrainian government.
Review Ukraine’s list of key businesses operating in government-controlled Zaporizhzhia.
Verify the recipient’s location through official attestations from Ukrainian authorities.

These measures aim to facilitate safe and transparent payments while aligning with regulatory requirements.