Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

On January 10, 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the Department of State, designated PJSC Gazprom Neft and PJSC Surgutneftegas as Specially Designated Nationals (SDNs) under Executive Orders 13662 and 14024, alongside more than 180 oil-carrying vessels (the bulk of Russia's "shadow fleet"), dozens of opaque oil traders, two major Russia-based oilfield service providers, marine insurance companies, and senior Russian energy-sector officials. The package included a new EO 14024 sectoral determination authorizing future designations against any person operating in the Russian energy sector, plus a new EO 14071 determination prohibiting the provision of US petroleum services (extraction, drilling, production support) to persons located in the Russian Federation, effective 12:01 a.m. EST on February 27, 2025. OFAC simultaneously issued General Licenses 117 (wind-down of transactions with the newly blocked entities) and 118 (debt/equity/derivatives wind-down), both expiring February 27, 2025. The action was the largest single Russia energy-sector designation since the 2022 invasion regime began and was coordinated with parallel UK OFSI shadow-fleet designations issued the same week. The action was finalized in the closing days of the Biden administration as a deliberate tightening of the oil-revenue and shadow-fleet vectors before the January 20 transition. Subsequent enforcement and any rollback decisions fell to the incoming Trump administration.

The Sanctions and Anti-Money Laundering Act 2018 (SAMLA, Chapter 13) received Royal Assent on 23 May 2018 and established the UK's autonomous post-Brexit sanctions legal framework. Part 1 empowers Ministers (FCDO, HM Treasury) to impose financial, trade, immigration, aircraft, and shipping sanctions by statutory instrument for purposes including UN compliance, national security, foreign-policy objectives, and promotion of human rights and democracy. Part 2 grants Ministers authority to make AML and counter-terrorist-financing regulations aligned with FATF standards, previously derived from EU Anti-Money-Laundering Directives. SAMLA is the parent enabling statute for every UK sanctions regime in force post-Brexit, including 30+ thematic and geographic regulations covering Russia (SI 2019/855), Iran, DPRK, Belarus, Myanmar, Syria, Venezuela, cyber, chemical weapons, global anti-corruption, and global human rights; under SAMLA, OFSI (HM Treasury) holds civil monetary-penalty and criminal-referral enforcement powers. Structurally peer to US IEEPA, EU Council Regulation framework, CN AFSL 2021, and JP FEFTA as the G7+CN foundational sanctions-statute cluster.