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Structured register of government actions in the geoeconomic space — export controls, tariffs, sanctions, FDI screening, subsidies, industrial-policy laws — cross-referenced into the country, minerals, and ETF surface. Charter: docs/IPTM_CHARTER.md.
Severity 1-5 is the qualitative impact rating (1=minor, 5=structural). The bilateral-trade-grounded quant scorer is the next IPTM milestone. RBI (Register Breadth Index) is a complementary structural-breadth indicator from scripts/py/iptm/breadth.py; divergence between RBI and severity is itself informative (high-sev / low-RBI = strategic chokepoint; low-sev / high-RBI = broad but shallow). Every action has at least one primary source URL. Verify-or-don't-file. See also themes, timeline, graph, sankey, map, country exposure, sector exposure, material exposure (+ graph), weekly briefs, portfolio scan, escalation monitor, trans-shipment hubs. Internal triage tools (RSS-poller candidate feed, source-feed health) live under /admin/candidates + /admin/sources. Subscribe via Atom feed (accepts ?country=CN, ?material=lithium, ?issuer=BIS, ?type=export_control, ?etf=SOXX, ?company=NVDA, ?minSeverity=4, ?year=2026, ?q=…) or pull /api/iptm/actions.
The Council of the European Union adopted Regulation (EU) 2025/2618 on 18 December 2025, amending Regulation (EU) No 833/2014, to add 41 vessels to Annex XLII of the Russia sanctions regime. Of these, 36 vessels are designated for transporting Russian crude oil and petroleum products while engaging in irregular and high-risk shipping practices characteristic of the "shadow fleet," 5 vessels are designated for transporting stolen Ukrainian grain and cultural property, and 1 vessel (GT HONOR) is designated for facilitating violation or circumvention of EU sanctions. Listed vessels are banned from access to EU member-state ports and locks and from a broad range of maritime-transport-related services, effective 19 December 2025. The measure is an incremental listing update between the 19th (Regulation 2025/2033, October 2025) and 20th (Regulation 2026/506, April 2026) numbered sanctions packages, rather than a new package itself.
HM Treasury's Office of Financial Sanctions Implementation (OFSI) published a Russia-regime notice on 18 December 2025 designating five individuals and 19 entities under the Russia (Sanctions) (EU Exit) Regulations 2019. Of the 19 entities, six are based in Russia, eight in the United Arab Emirates, four in Uzbekistan and one in Kyrgyzstan — reflecting OFSI's continued focus on third-country intermediaries used to route sanctioned Russian trade and finance. Designated persons are subject to a full asset freeze and are barred from commercial transactions and investment instruments with UK persons.
The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into a $3,103,360 settlement with Exodus Movement, Inc., a U.S.-incorporated non-custodial / self-custody crypto wallet software company, to resolve 254 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560) committed between October 17, 2017 and January 4, 2019. Exodus customer-support staff provided technical and account-related support — and in 12 of the 254 instances recommended the use of virtual private networks (VPNs) to circumvent partner-exchange geoblocking controls — to users who self-identified as located in Iran, in violation of the ITSR's prohibition on the export of services to Iran (§ 560.204) and, for the 12 egregious cases, the facilitation prohibition (§ 560.203). OFAC deemed the 12 VPN-coaching cases "egregious" because Exodus personnel were generally aware of U.S. sanctions and the company's own terms of use prohibited Iran usage, yet support staff actively helped Iranian users evade controls. Exodus separately committed to invest $630,000 in additional sanctions compliance controls. The settlement is structurally novel as the first OFAC enforcement action against a Web3-infrastructure / non-custodial wallet-software vendor and establishes that OFAC will assert jurisdiction over self-custody software providers based on customer-support facilitation conduct, not just custodial flow control.
On 12 December 2025 the Swiss Federal Council adopted the first tranche of listings aligning with the EU's 19th Russia sanctions package (Council Regulation (EU) 2025/2033, 23 October 2025), amending the Ordinance on Measures in Connection with the Situation in Ukraine and the Belarus Ordinance with effect from 13 December 2025. The decision adds asset freezes and entry/transit bans for 22 natural persons and 42 entities tied to Russia's military-industrial complex, energy sector and shadow-fleet vessel management; extends purchase/sale/insurance bans to over 100 additional tankers; imposes transaction restrictions on 5 Russian banks and 4 Russian-bank branches in Belarus and Kazakhstan for use of specialised financial-messaging services; sanctions Chinese and Hong Kong trading companies and refineries implicated in circumventing the G7 oil price cap; and designates 5 Belarusian persons linked to military-industrial activities. Divestment-exemption deadlines for Swiss persons winding down Russian holdings are extended to end-2026. This is a partial, listings-only tranche — the more substantive measures of the EU's 19th package (Russian LNG import ban, crypto-services prohibition, AI/HPC service bans) were not adopted until the Federal Council's follow-on decision of 25 February 2026.
The UK Foreign, Commonwealth & Development Office designated two China-based commercial cyber companies — Sichuan Anxun Information Technology Co Ltd (known as i-Soon) and Integrity Technology Group Incorporated — under the UK's Cyber sanctions regime, freezing their UK assets and imposing controls on commercial transactions and investment instruments involving them. i-Soon was designated for targeting over 80 government and private-sector IT systems worldwide, including UK public-sector and private-industry networks. Integrity Tech was designated for operating a covert botnet of more than 260,000 compromised devices globally and supplying access to it to enable unauthorised intrusion into UK public-sector systems.
OFAC settled civil liability of USD 1,092,000 with an unnamed individual (a former US government official and attorney) for 122 apparent violations of Russia-related sanctions programs spanning April 2018 to June 2022. The individual served as fiduciary and trustee of a US-based family trust established for the benefit of a sanctioned Russian oligarch (SDN-listed under EO 13662 and EO 14024) and in that capacity dealt in the blocked property of — and provided prohibited trust-administration services to — the oligarch without OFAC authorisation. OFAC assessed the conduct as non-egregious and not voluntarily self-disclosed, but credited substantial cooperation in fixing the penalty below the base amount.
The U.S. Treasury's Office of Foreign Assets Control designated four individuals and four entities under Executive Order 14098 ("Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition") for operating a transnational network that recruits former Colombian military personnel to fight for Sudan's Rapid Support Forces (RSF) paramilitary. Designated persons include retired Colombian officer Alvaro Andres Quijano Becerra, his wife Claudia Viviana Oliveros Forero, the Colombia-based recruitment agency International Services Agency (A4SI), and Panama-based intermediary Talent Bridge, S.A. (formerly Global Staffing S.A.). All property and interests in property of the designated persons subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from transacting with them.
The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into an $11,485,352 settlement with IPI Partners, LLC — a US private-equity data-center fund manager (~$10.5bn AUM) — to resolve 51 apparent violations of the Ukraine-/Russia-Related Sanctions Regulations between July 2018 and June 2022. IPI solicited and accepted two $25 million fund subscriptions in September 2017 and March 2018 from Definition Services, Inc. — a British Virgin Islands entity ultimately owned by Heritage Trust, a Delaware family trust established by sanctioned Russian oligarch Suleiman Kerimov — and continued processing 18 capital calls, 20 distributions, and 13 management-fee payments for four years after Kerimov's April 2018 SDN designation. OFAC simultaneously issued an unusually direct sectoral warning to the private-equity industry, marking the first major OFAC enforcement against a US PE-fund administrator in the data-center / AI-infrastructure segment and the second Kerimov-linked PE/VC settlement of 2025 (after the June 2025 $216M GVA Capital statutory-maximum penalty).
Canada made SOR/2025-228, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-11-06 and announced by Minister Anand on 2025-11-12. The regulations add 13 individuals to Part 1 of Schedule 1, 11 entities to Part 2 of Schedule 1, and 100 vessels (by IMO number) to Schedule 1.1, freezing their Canadian assets and prohibiting dealings. Targets include Russian LNG-trading entities, drone-programme developers, cyber-infrastructure suppliers for hybrid operations against Ukraine, and Kyrgyzstan-based financial enablers (including Capital Bank of Central Asia and the A7 payments platform) used to evade earlier Russia sanctions. The 100-vessel designation targets Russia's "shadow fleet" used to move crude oil, LNG and arms while evading the G7 price cap and flag-state controls.
New Zealand's 33rd sanctions round under the Russia Sanctions Act 2022 designated 65 "shadow fleet" tanker vessels involved in transporting Russian-origin crude oil, together with seven entities and two individuals based in Russia, Belarus, North Korea and Iran that refine or transport Russian oil or facilitate oil-related payments. Designated parties are subject to asset freezes and prohibitions on the supply of services (including port access, insurance, chartering and cargo handling) by New Zealand persons. The measure targets the revenue chain funding Russia's war in Ukraine rather than imposing a new tariff or trade-flow control.
On 29 October 2025 the Swiss Federal Council amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 662, completing Switzerland's alignment with the remaining goods, finance and services elements of the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025) and tightening the parallel Belarus regime. The amendment took effect 30 October 2025 and adds: an export ban covering additional structural-metal, general-purpose-machinery and machine-tool goods; an import ban on further petroleum-oil products and waste/scrap categories; and expanded controls on commercial transactions and investment instruments spanning financial services, investment banking, crude-petroleum trade and motor-vehicle/trailer goods. The Federal Department of Economic Affairs (WBF) had already taken over the measures within its own competence on 12 August 2025; this decision closes the remainder. In parallel, the Federal Council's asset-freeze annexes were extended to 14 individuals and 41 companies/organizations.
On 23 October 2025, the Council of the European Union adopted the 19th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/2033 amending Regulation 833/2014 (sectoral sanctions), Council Implementing Regulation (EU) 2025/2035 amending Regulation 269/2014 (asset-freeze listings — 22 individuals + 42 entities, total 69 listings), and Council Regulation (EU) 2025/2041 (parallel Belarus measures). The package closes the Russian-LNG import loophole left open by the 18th package and establishes the architectural template for crypto-asset sanctions. Headline measures: (i) full prohibition on imports of Russian-origin LNG into the EU — short-term contracts banned six months from entry into force (effective 25 April 2026), long-term contracts (> 1 year, executed before 17 June 2025) phased out by 1 January 2027; (ii) full transaction ban on Rosneft and Gazprom Neft (tightening prior partial measures); (iii) five additional Russian banks added to Annex XIV transaction ban (Alfa-Bank, MTS Bank among them; effective 12 November 2025); (iv) full transaction bans on the Mir card payment system and the Faster Payments System (SBP), effective 25 January 2026; (v) first-ever EU sanctions on a stablecoin — the rouble-backed A7A5 (issuer + developer designated) — and a Paraguay-based cryptocurrency exchange used as a circumvention rail; (vi) prohibition on EU operators contracting with 11 listed Russian Special Economic Zones (Annex LII), with mandatory divestment from Alabuga (Tatarstan) and Technopolis Moscow effective 25 January 2026 — no five-year wind-down available; (vii) 45 entities added to Annex IV military end-user list (28 Russian + 17 third-country: 12 Chinese/Hong Kong, 3 Indian, 2 Thai); (viii) new export restrictions on electronic components, microelectronics, acyclic hydrocarbons, pneumatic rubber tires and propellant chemicals (~EUR 155 m of EU 2024 exports); (ix) prohibition on supply of AI, HPC, and quantum-computing services to Russian persons (effective 25 November 2025); (x) tourism-services ban (1 January 2026 wind-down); (xi) 117 additional shadow-fleet vessels listed (cumulative 557, exceeding the 18th package's 444); (xii) four Belarus + Kazakhstan banks listed for SPFS use (effective 2 December 2025); (xiii) binding ownership/control definitions added to Reg. 269/2014 (50 % proprietary-rights threshold + eight-criterion control test). Entry into force on 24 October 2025 (day following publication in OJ L_202502033), except for measures with explicit deferred application dates.
On 23 October 2025, the Council of the European Union adopted Council Regulation (EU) 2025/2041 (amending Regulation (EC) No 765/2006) and Council Decision (CFSP) 2025/2040 (amending Decision 2012/642/CFSP), widening the EU's Belarus restrictive-measures regime in lockstep with the 19th Russia sanctions package adopted the same day. The package widens the export ban to industrial goods (salts, ores, rubber articles, tyres, millstones, construction materials, electronic components, rangefinders, propellant chemicals, metals/oxides/alloys), extends the import ban to all acyclic hydrocarbons, introduces a new prior-licensing requirement for services supplied to Belarus, its government, or public bodies, and mirrors the Russia regime's space, AI, and high-performance/ quantum-computing service restrictions. A companion instrument, Council Implementing Regulation (EU) 2025/2039, adds 5 new asset-freeze listings (2 individuals + 3 entities, including JSC Holography Industry, Horizont Holding, and ICT Horizont). Entered into force 24 October 2025.
On 15 October 2025 the UK Foreign, Commonwealth & Development Office, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated 39 entities and specified 51 vessels — including, for the first time, Russia's two largest integrated oil majors PJSC Rosneft Oil Company and PJSC Oil Company Lukoil — for supporting Russia's energy, defence and financial sectors. 51 vessels (44 identified as "shadow fleet" tankers) were specified for transporting Russian crude oil and LNG in evasion of the G7 price cap. The package also introduced a ban on importing oil products refined in a third country from Russian-origin crude, closing a refined-product loophole in the price-cap regime.
The US Treasury's Office of Foreign Assets Control designated Burma-based arms procurement company Royal Shune Lei Company Limited, its three Burmese executives, and two North Korean nationals linked to the Korea Mining Development Trading Corporation (KOMID) for operating an arms-trafficking and revenue-generation network supporting DPRK weapons of mass destruction and ballistic missile programs. Royal Shune Lei brokered sales of aerial bomb guidance kits, bombs, and airborne monitoring equipment to Burma's military junta on behalf of KOMID starting in 2022. Designations were made under Executive Order 13687 (DPRK), Executive Order 13551 (DPRK arms trade), and Executive Order 14014 (Burma), blocking all US-jurisdiction property of the six designated parties and barring US persons from transactions with them.
On 22 September 2025, OFAC designated Lex Instituto de Estudos Juridicos LTDA (Lex Institute) and Viviane Barci de Moraes — wife of Brazilian Supreme Federal Court (STF) Justice Alexandre de Moraes and the Institute's Managing Partner — pursuant to Executive Order 13818 (the Global Magnitsky Human Rights Accountability Act authority). The Lex Institute is a family holding company that owns de Moraes' residence and other properties; Treasury designated it for materially supporting de Moraes, who was himself designated under the same authority on 30 July 2025 for authorizing arbitrary pre-trial detentions and suppressing freedom of expression, including in the prosecution of former President Jair Bolsonaro. All US property and interests of the designated persons are blocked and U.S. persons are generally barred from transacting with them.
On 19 September 2025 the UK Foreign, Commonwealth and Development Office designated two Georgian nationals — Otar Partskhaladze and Levan Vasadze — and two companies, UK-based Aeza International Ltd and Russia-based HeliCo Group LLC, under the Russia (Sanctions) (EU Exit) Regulations 2019, citing their roles in supporting Russian disinformation and Georgia's Kremlin-aligned political network. In the same package OFSI proscribed two oil tankers, Bavly and Karakuz, for allegedly delivering Russian-origin crude to the port of Batumi, Georgia, barring both vessels from UK ports and the UK Ship Register. Designated individuals face asset freezes, travel bans and director-disqualification sanctions.
The US Treasury's Office of Foreign Assets Control designated two Iranian financial facilitators — Alireza Derakhshan and Arash Estaki Alivand — along with more than a dozen Hong Kong- and UAE-based individuals and entities for operating a shadow-banking network that laundered proceeds from Iranian oil sales through front companies and cryptocurrency. The designated addresses account for over $600 million in total inflows, including more than $100 million in cryptocurrency purchases tied to oil sales between 2023 and 2025. Proceeds are alleged to benefit the IRGC-Qods Force and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). This is the second round of OFAC sanctions targeting Iran's shadow-banking infrastructure since National Security Presidential Memorandum 2 (NSPM-2) directed a maximum-pressure campaign on Iran in February 2025.
Japan lowered its price cap on Russian-origin crude oil from USD 60 to USD 47.60 per barrel, effective for contracts concluded on or after 12 September 2025, aligning with the EU's July 2025 cut under its 18th sanctions package. The measure bars Japanese entities from importing, or providing shipping, insurance, financing or other services for, Russian crude priced above the new cap. In the same package Japan added 47 Russian entities and 9 individuals, 6 Crimea/Donbas-linked persons and entities, and 3 third-country entities to its asset-freeze list (transactions now require Ministry of Finance approval), and imposed export prohibitions on 2 Russian entities and 9 entities in third countries. Japan's own Russian crude imports are minimal (~0.1% of total crude imports, Jan-Jul 2025), so the measure is primarily a coalition-alignment and shipping/insurance-chokepoint action rather than a material change to Japan's own energy sourcing.
New Zealand's 32nd sanctions round under the Russia Sanctions Act 2022 (Russia Sanctions Amendment Regulations (No 4) 2025, SL 2025/195) lowered the price cap on Russian-origin crude oil (HS 2709) from US$60/bbl to US$47.60/bbl, a roughly 21% cut, aligning New Zealand with the EU, UK and Canada's most recent price-cap reductions. The same instrument designated 19 individuals and entities plus 19 vessels, including Russia's GRU cyber unit 29155 (implicated in malware attacks on Ukrainian government networks), actors involved in chemical-weapons use and disinformation, additional "shadow fleet" tankers, alternative payment providers, and third-country facilitators based in North Korea and Iran supporting Russia's war effort.
On 11 September 2025, the US Treasury's Office of Foreign Assets Control designated 32 individuals and entities and identified four vessels in what Treasury described as its broadest sanctions action to date against Iran-aligned Ansarallah (Houthi) support networks. The designated network — companies, owners, and operatives located in Yemen, China, the UAE, and the Marshall Islands — is accused of running oil and commodity smuggling through Houthi-controlled Yemeni ports, laundering the proceeds, and using them to finance a global weapons procurement supply chain of front companies and shipping facilitators. The action was taken pursuant to Executive Order 13224 (as amended) and builds on nine prior 2024-2025 OFAC actions against Houthi leaders, smugglers, financiers, and suppliers.
The US Treasury's Office of Foreign Assets Control designated a Russian national (Vitaliy Sergeyevich Andreyev), a Russia-based DPRK economic and trade consular official (Kim Ung Sun), a Chinese front company (Shenyang Geumpungri Network Technology Co., Ltd), and a DPRK trading company subordinate to the DPRK Ministry of People's Armed Forces General Political Bureau (Korea Sinjin Trading Corporation) for facilitating a fraudulent overseas IT-worker scheme that funds North Korea's weapons of mass destruction and ballistic missile programs. The action expands on the prior designation of Chinyong Information Technology Cooperation Company, an entity tied to the DPRK defense ministry that deploys IT worker delegations in Russia and Laos. Treasury said Andreyev and Kim Ung Sun facilitated cryptocurrency-to-cash conversions worth nearly USD 600,000 since December 2024, and that Shenyang Geumpungri's delegation of DPRK IT workers has earned Chinyong and Sinjin over USD 1 million in profits since 2021. Designations were made under Executive Order 13687, blocking all US-jurisdiction property of the four parties and barring US persons from transactions with them.
Presidential Decree No. 593 of 25 August 2025 amends the standing schedule of foreign-owned Russian assets under "temporary management" (established by Decree No. 302 of 25 April 2023), adding as item 44 the 314,949 thousand ordinary shares of JSC Chelyabenergoremont held by Fortum Holding B.V. (the Dutch holding vehicle of Finnish state-controlled utility Fortum), transferring control to Rosimushchestvo (Federal Agency for State Property Management). Fortum was the sole shareholder, so the decree effectively nationalises the entire company — a 70-year-old turbine and boiler-equipment maintenance and repair service provider for power plants, with reported 2023 revenue of RUB 2.35bn. The decree entered into force on its date of official publication and is one of a running series of company-specific amendments to Decree 302 following Fortum's 2022-23 exit announcement and the earlier seizure of its main generation subsidiary Fortum Russia B.V. (renamed Fora Energy) and of Unipro.
On 20 August 2025 the UK government, acting under the Russia (Sanctions) (EU Exit) Regulations 2019, designated three individuals and five entities — OJSC Capital Bank of Central Asia, Grinex LLC, CJSC Tengricoin, Old Vector LLC (all Kyrgyzstan-based) and Altair Holding SA (Luxembourg-based) — for helping Russia evade Western financial sanctions via opaque Kyrgyz banking channels and cryptocurrency rails. The designations target the A7A5 rouble-backed stablecoin network, which the FCDO says moved USD 9.3bn in transactions over four months, and the Grinex/Meer crypto exchanges used to convert and route the proceeds; designated parties face UK asset freezes and trust-services prohibitions.
On 14 August 2025 OFAC re-designated the cryptocurrency exchange Garantex Europe OU under its cyber authority (E.O. 13694, as amended) for processing over USD 100 million in transactions tied to ransomware and darknet-market actors since 2019, and designated its successor exchange Grinex — created by former Garantex staff to move customer deposits and continue operations after a March 2025 US Secret Service-led takedown of Garantex's infrastructure. OFAC also designated three Garantex executives, the A7A5 ruble-backed stablecoin issuer Old Vector (Kyrgyzstan), and Russian settlement-platform firm A7 and its subsidiaries A71 and A7 Agent — entities linked to sanctioned Moldovan oligarch Ilan Shor and sanctioned Promsvyazbank — for supplying the A7A5 token used to compensate Garantex customers and route funds through Grinex.
On 12 August 2025 Switzerland amended the Ordinance on Measures concerning Moldova (SR 946.231.156.5) — published as AS 2025 496 — adding the Russian company A7 LLC to Annex 2, the frozen-funds list. Under the ordinance, A7 LLC's funds and economic resources held in Switzerland are frozen and Swiss persons/entities are prohibited from making funds or economic resources available to it. The listing targets a single entity alleged to be involved in Russian-led efforts to influence Moldova's 2024 EU-membership referendum and presidential election; the EU had added the same entity to its own frozen-funds list roughly a month earlier, in July 2025.
On 12 August 2025 the Swiss Federal Department of Economic Affairs, Education and Research (WBF) amended the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), published as AS 2025 497, adopting — within its own delegated competence and ahead of the full Federal Council decision — an interim tranche of measures aligning Switzerland with the EU's 18th Russia sanctions package (Council Regulation (EU) 2025/1494, 18 July 2025). The amendment lowers the Russian-crude price cap and updates the associated Annex 28 price-threshold table, extends export prohibitions on transport services, adds port-access restrictions covering 105 additional shadow-fleet vessels, and widens controls on commercial transactions and investment instruments for Russian financial institutions. It also extends asset-freeze listings to entities in China, Hong Kong, Singapore, Mauritius, Azerbaijan, India and the UAE implicated in circumvention. The measure took effect 12 August 2025. The Federal Council closed out the remaining goods, finance and services elements of the 18th package on 29 October 2025 (see responds_to).
On 8 August 2025, Ukraine's President signed Decree No. 595/2025, enacting an NSDC decision "On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions)" against Russian state nuclear corporation Rosatom and its international corporate network. Sanctions were applied to 18 individuals and 17 legal entities identified as involved in attempts to integrate the occupied Zaporizhzhia Nuclear Power Plant into Russia's grid, participation in the seizure of the Chornobyl NPP, production and servicing of dual-use nuclear equipment, and export of enriched uranium through Rosatom subsidiaries registered in Switzerland, Cyprus, the Netherlands, and Finland. Named entities include Uranium One Holding N.V. (Netherlands), Rosatom Finance Ltd (Cyprus), and JSC Kirov-Energomash (Russia).
On 30 July 2025 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, published a civil monetary penalty of £300,000 against Markom Management Limited (MML UK), a London-incorporated provider of corporate-services and management functions to its parent Markom Management Cyprus. The penalty (decision dated 10 January 2025) relates to MML UK instructing the transfer of £416,590.92 from a Moscow-based bank account of its parent's client to a person designated under an EU Regulation 269/2014 asset freeze (Russia/Crimea-related), at a time when MML UK had knowledge of the recipient's designated status. OFSI initially proposed £400,000; MML's representations secured a reduction to £300,000, which was subsequently upheld on ministerial review under s.147 of the Policing and Crime Act 2017. At the time of publication this was the third-largest OFSI civil monetary penalty imposed since the powers were introduced under Part 8 of the Policing and Crime Act 2017, and the twelfth use of those powers in total.
On 30 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identified more than 50 vessels belonging to the shipping empire of Mohammad Hossein Shamkhani, son of Ali Shamkhani, a top political adviser to Iran's Supreme Leader. Treasury described the action — over 115 sanctions in total — as its largest Iran-related action since 2018. The network launders billions of dollars from sales of Iranian and Russian crude oil and petroleum products (mostly to buyers in China) through vessels and front companies registered across the UAE, Hong Kong, India, Cyprus, Panama, Romania, China, Liberia, the Marshall Islands and Seychelles. Concurrently, the State Department designated 20 entities and identified 10 vessels under E.O. 13846 and E.O. 13902 for trading and transporting Iranian petroleum and petrochemical products.
The US Treasury's Office of Foreign Assets Control designated the Korea Sobaeksu Trading Company (also known as Sobaeksu United Corporation) and three associated individuals — Kim Se Un, Jo Kyong Hun, and Myong Chol Min — for evading US and UN sanctions and clandestinely generating revenue for the DPRK government, including through fraudulent information-technology worker schemes. Sobaeksu operates as a front company for the US-designated Munitions Industry Department, which oversees North Korea's nuclear program and ballistic-missile development. The action was coordinated with a Department of Justice unsealing of indictments against seven DPRK nationals over counterfeit- cigarette sanctions evasion, and State Department reward offers of up to USD 7 million for information on the individuals involved. Designations block all US-jurisdiction property of the four parties and bar US persons from transacting with them.
On 22 July 2025, the US Treasury's Office of Foreign Assets Control designated two individuals and five entities under Executive Order 13224 for facilitating revenue generation and material support to the Houthis (Ansarallah) through petroleum importation and money laundering. The network — Muhammad Al-Sunaydar's Arkan Mars petroleum companies (Yemen/UAE) and Yahya Mohammed Al Wazir's Al-Saida Stone for Trading and Agencies and Amran Cement Factory — coordinated roughly $12 million of Iranian petroleum imports through the Houthi-controlled Ras Isa port with an Iranian IRGC-linked petrochemical trading entity, and laundered approximately €6 million through bulk-coal front-company transactions. The action builds on a cadence of OFAC designations against Houthi revenue and weapons-procurement networks running since mid-2024.
On 21 July 2025 the UK announced 137 new sanctions designations under its Russia regime, targeting 135 oil tankers identified as part of Russia's "shadow fleet" plus two enabling companies: Litasco Middle East DMCC (a Dubai-based trading arm linked to Lukoil, sanctioned for moving Russian oil on shadow-fleet vessels) and Intershipping Services LLC (sanctioned for registering shadow-fleet vessels under the Gabonese flag). FCDO states the targeted vessels have carried an estimated $24 billion of cargo since the start of 2024, and that Intershipping's flag-registration activity has enabled up to $10 billion/year in Russian state-linked shipping. The action was announced alongside a further lowering of the UK/EU Crude Oil Price Cap and runs as a companion measure to the EU's 18th sanctions package (Council Regulation 2025/1494), adopted three days earlier.
On 18 July 2025, the Council of the European Union adopted the 18th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/1494 amending Regulation 833/2014 (sectoral measures), Council Implementing Regulation (EU) 2025/1476 implementing Regulation 269/2014 (asset-freeze listings), Council Decision (CFSP) 2025/1495 (vessel listings), and Council Regulation (EU) 2025/1472 (parallel Belarus measures). The package is the largest energy-sector escalation since 2022 and pivots from new-perimeter creation toward enforcement and circumvention closure. Headline measures: (i) the Russian-crude price cap is lowered from USD 60 to USD 47.6 per barrel with a new automatic dynamic mechanism re-indexing the cap to global oil prices every six months at a 15 % discount to the 22-week trailing average (effective 3 Sep 2025, with a transitional exemption to 18 Oct 2025 for pre-20 Jul 2025 contracts compliant with the prior cap); (ii) full transaction ban extended to 22 additional Russian banks, bringing the total cut off from the EU financial system to 45; transaction ban extended to third-country financial institutions and crypto-asset service providers facilitating circumvention; (iii) full transaction ban on Nord Stream 1 and Nord Stream 2 pipelines; (iv) import ban on refined oil products derived from Russian crude processed in third countries; (v) 105 additional vessels added to the shadow-fleet port-access ban (cumulative total 444); (vi) 26 new entities added to Annex IV military end-user list (15 Russian + 11 from China/Hong Kong/Turkey); (vii) Council Implementing Regulation 2025/1476 lists 14 individuals + 41 entities under asset-freeze, including a major Indian refinery (Nayara Energy, part-owned by Rosneft), three Chinese suppliers of battlefield goods, shadow-fleet operators, and entities involved in the deportation of Ukrainian children; (viii) parallel Belarus complementary measures via Regulation 2025/1472. Wind-down periods vary: 90 days for oil-price-cap contracts; banking-software wind-down to 30 Sep 2025; trade-goods wind-downs Oct 2025–Jan 2026 by category. Entry into force on 19 July 2025 (day following publication in the Official Journal), except for measures with explicit deferred application dates.
On 15 July 2025 the Council of the European Union adopted Council Implementing Regulation (EU) 2025/1434, implementing the Moldova restrictive-measures framework (Council Regulation (EU) 2023/888), and listed seven individuals and three entities — including the Russian company A7 LLC — for actions destabilising the Republic of Moldova. The listing freezes A7 LLC's funds and economic resources within the EU and prohibits EU persons and entities from making funds or economic resources available to it, directly or indirectly.
The US Treasury's Office of Foreign Assets Control designated 22 entities based in Hong Kong (18), the UAE, and Türkiye under Executive Order 13224 for facilitating sales of Iranian oil that benefit the IRGC-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. The front-company network moves refinery payments for Iranian oil through offshore accounts to fund IRGC-QF activity; the action is the second round of sanctions under National Security Presidential Memorandum 2's "maximum pressure" campaign, following a June 6, 2025 action against Iranian exchange-house money-laundering networks. All property and interests of the designated entities within US jurisdiction are blocked, and US persons are generally prohibited from dealing with them.
On 3 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the other member states of the Terrorist Financing Targeting Center (TFTC), designated five entities and sixteen individuals forming the core of Hizballah's financial infrastructure, under Executive Order 13224 as amended. Newly designated entities include Tashilat SARL (a Lebanese lender that provided loans on behalf of Hizballah and operated as part of Al-Qard Al-Hassan (AQAH) and Bayt al-Mal), alongside senior AQAH officials Samer Hasan Fawaz and Ali Mohamad Karnib. The action reaffirms and expands sanctions on AQAH, Hizballah's shadow "benevolent loan association" bank, and Bayt al-Mal, its unofficial treasury, both previously designated by OFAC in 2007 and 2006 respectively. It is the ninth TFTC joint designation since the center's creation in May 2017 and the third under this Administration; designated persons are alleged to have moved over $500 million through the formal Lebanese banking system — including US-designated Jammal Trust Bank — via joint and shadow accounts despite existing sanctions.
On 25 June 2025, FinCEN issued three coordinated orders identifying CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. as foreign financial institutions of primary money-laundering concern in connection with illicit opioid trafficking, and prohibiting US covered financial institutions from engaging in certain transmittals of funds (including convertible virtual currency transmittals) to or from those three institutions or any account or CVC address administered on their behalf. The orders were published in the Federal Register on 30 June 2025 (FR docs 2025-11991 Vector, 2025-11993 CIBanco, 2025-11990 Intercam) with an original effective date of 21 July 2025. These are the first-ever orders issued under Section 2313a of the Fiscal Year 2024 NDAA (added by the FEND Off Fentanyl Act and Fentanyl Sanctions Act), and target Mexican counterparties tied by FinCEN to the Beltran-Leyva Cartel, Jalisco New Generation Cartel (CJNG), and the Gulf Cartel.
On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated four individuals, twelve entities, and two vessels in what Treasury called its single largest action to date against Iran-backed Ansarallah (the Houthis), pursuant to Executive Order 13224 as amended. The designated network — Sana'a- and Hudaydah-based oil-trading front companies (including Black Diamond Petroleum Derivatives, Star Plus Yemen, Tamco Establishment, Royal Plus Shipping, and Abbot Trading) and their Houthi operator-owners — facilitates black-market oil and oil-derivative sales that fund Houthi militant operations, while shipping firms Best Way Tanker Corp, Ocean Voyage LLC, and Atlantis M. Shipping Co were designated for discharging over 120,000 combined metric tons of gasoline and LPG at the Houthi-controlled Ras Isa port via the vessels Valente and Atlantis MZ after the April 2025 expiration of Counter Terrorism General License 25A. The action builds on OFAC's June 2024–April 2025 cadence of designations against Houthi leaders, weapons-procurement operatives, and suppliers.
On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated one individual, eight entities, and one vessel pursuant to Executive Order 13382 (WMD proliferators) for procuring and transshipping sensitive machinery to Iran's Rayan Roshd Afzar Company (RRA), a producer of UAV components and aerospace software for the IRGC. The vessel SHUN KAI XING, owned by Hong Kong-based Unico Shipping Co Ltd and chartered by Singapore-based V-Shipping Pte Ltd, was carrying the machinery for RRA and an affiliated firm when its cargo was inspected; the designated network — including China-based Shenzhen Xinxin Shipping, Dongguan Zanyin Machinery and Equipment, Athena Shipping, shipmaster Zhang Yanbing, and Turkiye-based Edisa Dis Ticaret Limited Sirketi — then falsified bills of lading to obscure the Iran-bound, RRA-consigned cargo after the inspection.
New Zealand's Russia Sanctions Amendment Regulations (No 3) 2025, made under the Russia Sanctions Act 2022, came into force on 19 June 2025 designating seven entities and ten individuals -- including North Korean, Iranian and Belarusian actors supporting Russia's war effort and Russian actors involved in drone and weaponry production. The same instrument created a new "restricted ship" category under Regulation 8 and sanctioned 27 vessels in Russia's shadow fleet under it, and expanded the Regulation 12 legal-services exception. Designated parties are subject to asset freezes and prohibitions on New Zealand persons supplying services to them.
The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced a $3,882,797 civil settlement with Unicat Catalyst Technologies LLC, an Alvin, Texas-based specialty catalyst supplier, resolving 13 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) and one apparent violation of the Venezuela Sanctions Regulations (VSR, 31 CFR Part 591). OFAC determined the conduct egregious; Unicat had voluntarily self-disclosed. The settlement was concurrent with separate actions by the U.S. Department of Justice and the Department of Commerce Bureau of Industry and Security (BIS). The violations, spanning 2016–2021, involved the supply of catalyst products and consulting services to Iranian customers via a Dutch affiliate and Chinese supplier, and the sale of catalysts to Orinoco Iron S.C.S., a blocked Venezuelan government-owned entity, routed through a Chinese intermediary.
Canada made SOR/2025-142, Regulations Amending the Special Economic Measures (Russia) Regulations, registered 2025-06-13. The regulations add 34 Russian entities to Part 2 of Schedule 1 alongside Keremet Bank Open Joint-Stock Company (Kyrgyzstan), three UAE-based entities, one Singapore-based entity, and two energy-commodity trading companies (Switzerland, Azerbaijan) — all designated as sanctions-evasion intermediaries for Russian trade. The amendments also add 201 vessels (by IMO number) to Schedule 1.1 as part of Russia's "shadow fleet," triggering a dealings ban, asset freeze, and a new prohibition on providing financial or other services to non-Canadians in relation to a listed vessel.
The U.S. Treasury's Office of Foreign Assets Control (OFAC) imposed a $215,988,868 civil monetary penalty — the statutory maximum applicable — on GVA Capital Ltd., a Silicon Valley early-stage venture capital firm, for willful violations of Russia-related sanctions and for failure to comply with an administrative subpoena. The penalty resolves conduct in which GVA, after its founding investor Suleiman Kerimov (a Russian oligarch and Federal Assembly member) was designated as a Specially Designated National in April 2018, continued for approximately three years to manage and attempt to liquidate Kerimov's $20 million investment in a Delaware special-purpose vehicle linked to Prosperity Investments, L.P. (a Guernsey-domiciled fund in which Kerimov retained a property interest). OFAC determined the conduct was egregious and not voluntarily self-disclosed. The action is the first public OFAC enforcement of the second Trump administration and the largest OFAC civil penalty since the November 2023 Binance Holdings settlement; it is also OFAC's first major enforcement action against a U.S. venture-capital / investment-adviser firm.
The US Treasury's Office of Foreign Assets Control designated more than 35 individuals and entities tied to Iranian brothers Mansour, Nasser, and Fazlolah Zarringhalam, whom OFAC says have collectively laundered billions of dollars through the international financial system using Iranian exchange houses (including Zarrin Ghalam, GCM Exchange, and Berelian Exchange) and foreign front companies based in the UAE and Hong Kong. The network is used to move revenue from Iranian oil and petrochemical sales that fund the regime's nuclear and missile programs and terrorist proxies. The action, taken pursuant to Executive Order 13902, is the first designation round under National Security Presidential Memorandum 2's "maximum pressure" campaign since its February 4, 2025 issuance; Treasury's FinCEN concurrently issued an updated advisory on Iranian shadow-banking and oil-smuggling red flags for financial institutions.
On 20 May 2025, the Council of the European Union adopted Council Implementing Regulation (EU) 2025/965 and Council Decision (CFSP) 2025/966, implementing the EU's dedicated hybrid-threats restrictive- measures regime (Regulation (EU) 2024/2642) rather than the sectoral Russia sanctions track. The package designates 21 individuals and 6 entities for enabling Russian state-sponsored destabilising activity, including information manipulation and interference and cyberattacks against the EU and its partners. Named entities include Stark Industries Solutions Ltd (UK-registered "bulletproof" web-hosting provider used as infrastructure for Russian cyberattacks) and its owner/CEO Ivan and Iurie Neculiti, Czech-based pro-Kremlin media outlet Voice of Europe, and Turkish media company AFA Medya and its founder Hüseyin Doğru. Designated parties are subject to an EU-wide asset freeze and prohibition on making funds available; designated individuals additionally face a travel ban. This is a distinct legal instrument from the same-day 17th Russia sectoral sanctions package (Regulation (EU) 2025/932/933), adopted under the separate hybrid- threats horizontal regime.
On 20 May 2025, the Council of the European Union adopted the 17th package of restrictive measures against Russia, anchored by Council Regulation (EU) 2025/932 amending Regulation 833/2014 (sectoral measures) and Council Implementing Regulation (EU) 2025/933 implementing Regulation 269/2014 (asset-freeze listings). Sectoral measures include the largest single-package expansion of the shadow-fleet port-access ban (additional vessel listings layered on top of the 153 designations carried over from the 16th package), the addition of 31 entities — including third-country (Chinese, Turkish, UAE, Hong Kong) firms — to the Annex IV list of military end-users barred from receiving dual-use and critical industry goods (covering chemical precursors used in missile propellants and spare parts for high-precision machine tools), and reinforced anti-circumvention "no-Russia" clause obligations on EU exporters. Council Implementing Regulation (EU) 2025/933 imposes asset freezes on 17 additional individuals and 58 additional entities, including shadow-fleet vessels and operators, a major Russian oil company, Russian military/defence-sector firms, and persons involved in the looting of Ukrainian cultural heritage. Parallel hybrid-threat, human-rights, and chemical-weapons designations were adopted under separate horizontal regimes on the same day. The Council noted EU shadow-fleet and oil-price-cap measures had reduced Russian revenues by approximately EUR 38 billion since introduction. Entry into force on 21 May 2025 (day following publication in the Official Journal).
On 20 May 2025 the UK Foreign, Commonwealth and Development Office updated the UK Sanctions List, adding 82 entries (20 individuals and 62 entities) under the Russia (Sanctions) (EU Exit) Regulations 2019. OFSI's accompanying Financial Sanctions Notice confirms all 82 are now subject to an asset freeze and trust services sanctions. The package covers three clusters: further members of the Kremlin-linked Social Design Agency (SDA) disinformation network (first designated in 2024); Russian financial institutions including the St Petersburg Currency Exchange, the Petersburg Settlement Center, and the State Corporation Deposit Insurance Agency; and individuals and companies supporting Russia's oil "shadow fleet" logistics, including a British national accused of ship procurement and two tanker captains. The measures were published in coordination with the EU's 17th sanctions package, announced the same day.
On 13 May 2025, the US Treasury's Office of Foreign Assets Control designated nearly two dozen firms and individuals — including Hong Kong-based intermediary Star Energy International Limited — for operating in Iran's illicit international oil trade on behalf of Sepehr Energy Jahan Nama Pars Company (Sepehr Energy), the Tehran-based oil-sales arm of Iran's Armed Forces General Staff (AFGS). The designated network spans commercial intermediaries and shipping counterparties across China, Hong Kong and Singapore, the last a hub for ship-to-ship transfers of Iranian-origin crude. Designations were made under counter-terrorism (SDGT) and Iran Financial Sanctions Regulations (IFSR) authorities as part of the administration's maximum-pressure campaign to cut off military and IRGC-linked revenue from Iran's oil exports.
On 8 May 2025, the US Treasury's Office of Foreign Assets Control designated China-based "teapot" refinery Hebei Xinhai Chemical Group Co., Ltd. and its Singapore-based broker subsidiary Xing AO Energy PTE. LTD., three firms tied to a Dongying Port (Shandong) terminal that has received Iranian crude from shadow-fleet tankers, and six Hong Kong-, UK-, and Marshall Islands-owned shadow-fleet vessels (STAR TWINKLE 6, LAMD, SKADI, BIG MAG, IMPALAS, THANE) plus their owning shipping companies and two vessel captains. It is OFAC's third action against an Iranian-oil teapot refinery and its first targeting Shandong port terminal operators, taken under E.O. 13902 (Iran petroleum/ petrochemical sector) and E.O. 13846 (NIOC support) as part of the administration's NSPM-2 maximum-pressure campaign.