RegRally Insights: Sanctions Essentials

Welcome to the monthly newsletter on sanctions, September 2025 edition, which is dedicated to everyone who wants to understand the latest trends and developments, get tips from our experts, and deepen their knowledge. We wish you a good read!

U.S. Extends National Emergency and Imposes New Tariff on India-linked Russian Oil Imports

On 6 August 2025, the U.S. President confirmed the continuation of the national emergency under Executive Order 14066, citing Russia’s ongoing aggression against Ukraine as a threat to U.S. national security and foreign policy. As part of the measures, the Order introduces a 25% ad valorem tariff on imports from India linked to Russian-origin oil, effective 21 days from issuance (with exemptions for goods already in transit before 17 September 2025). Oversight and enforcement will be coordinated by the Departments of State, Treasury, and Commerce, among others.

Recommendations for companies:

Update sanctions and trade compliance systems to flag Indian counterparties with potential exposure to Russian-origin oil.
Review supply chains and contracts for affected goods to ensure tariff compliance and mitigate financial exposure.
Engage with counterparties proactively to clarify sourcing and avoid inadvertent breaches.

European Leaders Reaffirm Support for Ukraine Following Trump–Putin Alaska Summit

On 16 August 2025, European leaders — including President Macron, Prime Ministers Meloni and Starmer, Chancellor Merz, President von der Leyen, and others — issued a joint statement regarding the Alaska summit between Presidents Trump and Putin. While welcoming President Trump’s commitment to pursue peace, they stressed that negotiations must include President Zelenskyy and involve European partners. The leaders reaffirmed their unwavering support for Ukraine’s sovereignty, rejected any settlement legitimising territorial changes by force or granting Russia influence over Ukraine’s EU or NATO path, and confirmed their determination to maintain sanctions and economic pressure on Russia until a just and durable peace is achieved.

Additional Restrictive Measures Against Belarus: Wider EU Alignment

On 11 August 2025, the EU’s High Representative confirmed that Albania, Bosnia and Herzegovina, Iceland, Liechtenstein, Montenegro, North Macedonia, Norway, and Ukraine have aligned with the Council Decision (CFSP) 2025/1471 of 18 July 2025, which introduced new restrictive measures in response to Belarus’s role in Russia’s aggression against Ukraine.

Key measures include:

Expanded export controls, with optional prior authorisation where Belarus may be the end destination or end user.
Extended ban on specialised financial messaging services for Belarusian credit institutions — now elevated to a full transaction ban.
Broader restrictions on goods and technologies with potential military or industrial applications in Belarus.

OFAC Announces New Sanctions on North Korea and Issues Russia-Related General License

On 27 August 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) introduced new sanctions targeting individuals and entities linked to North Korea’s weapons programs and issued a Russia-related General License.

Sanctions Designations

Individuals: Vitaliy Sergeyevich Andreyev (Russia); Kim Ung Sun (North Korea)
Entities: Korea Sinjin Trading Corporation (North Korea); Shenyang Geumpungri Network Technology Co., Ltd. (China)

General License Issuance

Russia-related General License 104A authorises certain transactions related to imports of diamonds prohibited by Executive Order 14068, providing limited exemptions for specified activities.

Recommendations for businesses:

Integrate the new designations into sanctions screening systems.
Review counterparties and transactions to identify and mitigate potential exposure to listed individuals or entities.

UK Updates Guidance on Russian Sanctions Evasion and Export-Control Risks

On 4 August 2025, the UK Government issued updated guidance on tackling Russian sanctions evasion and export-control circumvention. The guidance highlighted how Russia exploits front companies, shell entities, falsified documentation, and third-country routing to obtain high-priority goods such as microelectronics, machinery, and other dual-use items.

The guidance draws attention to the Common High Priority List of 50 sensitive items across four tiers and stresses that facilitation of circumvention may constitute a criminal offence. It also sets out red flags businesses should monitor, including unusual product suitability, suspicious counterparties, complex transaction structures, and atypical routing.

Recommendations for businesses:

Apply enhanced due diligence for high-risk buyers and jurisdictions, verifying end-use and re-export risks clearly.
Scrutinise intermediaries and ownership structures using corporate registry data and adverse-media screening.

U.S. Sanctions ICC Officials Over Investigations Into U.S. and Israeli Nationals

On 20 August 2025, the U.S. Treasury and State departments imposed sanctions on four International Criminal Court (ICC) officials—judges Nicolas Yann Guillou (France) and Kimberly Prost (Canada), and deputy prosecutors Nazhat Shameem Khan (Fiji) and Mame Mandiaye Niang (Senegal). The designations, which include asset freezes and restrictions on U.S. financial system access and travel, reflect ongoing U.S. opposition to ICC inquiries into American and Israeli nationals. While the ICC and U.N. condemned the move as a threat to judicial independence, Israel welcomed it.

Recommendations for businesses:

Refresh sanctions screening databases to include the newly designated ICC officials.
Conduct exposure reviews for clients or counterparties with potential links to the individuals, especially in legal, diplomatic, or international justice sectors.

OFAC Targets Iranian Sanctions-Evasion Networks and Surveillance Infrastructure

On 7 August 2025, the U.S. Department of the Treasury’s OFAC designated 18 Iranian entities and individuals involved in sanction-evasion schemes funding the regime and its surveillance apparatus.

Key designations include:

RUNC Exchange System Company – developer of the Cross-Border Interbank Messaging System used to bypass conventional payment channels.
Cyrus Offshore Bank – a shadow banking entity masked by the Central Bank of Iran.
FANAP – a tech company enabling repressive surveillance, including private messaging apps and facial recognition tools for the police state.

All designated entities and officials are now subject to asset freezes and U.S. financial restrictions.

Recommendations for businesses:

Update sanctions screening systems to include RUNC, Cyrus Offshore Bank, FANAP, and associated individuals.
Apply heightened due diligence for counterparties linked to cross-border financial messaging or tech-driven banking infrastructure with possible ties to Iran.

U.S. Escalates Sanctions on Iranian Oil Network

On 21 August 2025, the U.S. Treasury and State Departments announced a new sanctions package targeting Iran’s oil export channels.

Key designations include:

Greek facilitator Antonios Margaritis and his shipping network, including Ares Shipping Limited, Comford Management, and Hong Kong Hangshun Shipping Limited.
Sanctioned vessels: Adeline G, Kongm, Lafit.
Chinese terminal operators: Qingdao Port Haiye Dongjiakou Oil Products Co and Yangshan Shengang International Petroleum Storage and Transportation Co.

The measures aim to cripple Iran’s oil revenue, which funds nuclear, missile, and terrorism-related activities, particularly amid stalled nuclear negotiations and recent strikes on Iranian sites.

Recommendations for compliance teams:

Update screening protocols to capture new designations across companies, vessels, and individuals.
Enhance monitoring of counterparties tied to Iran’s maritime, oil transport, or terminal operations.
Use multi-hop tracing to uncover indirect cross-border payment and trade chain links.
Strengthen due diligence by requiring ownership/control transparency for logistics and shipping entities.
Train staff to identify red flags in commodity trade, maritime financing, and shipping documentation.