Overview
The Sanctions Update is compiled by Steptoe’s International Trade and Regulatory Compliance team and Steptoe’s Strategic Risk team. You can subscribe to receive the Sanctions Update every week through Steptoe’s International Compliance Blog and Stepwise Risk Outlook publication home pages.
For more information or advice on any of the developments discussed below, please contact a member of our sanctions team here.
US Developments
Treasury Issues Designations Under New Fentanyl Authority
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying three Mexico-based financial institutions as being of primary money laundering concern in connection with illicit opioid trafficking. The financial institutions, CIBanco S.A., Institution de Banca Multiple (“CIBanco”), Intercam Banco S.A., Institución de Banca Multiple (“Intercam”), and Vector Casa de Bolsa, S.A. de C.V. (“Vector” ), which have billions of dollars in total assets or under management, allegedly “played a longstanding and vital role in laundering millions of dollars on behalf of Mexico-based cartels and facilitating payments for the procurement of precursor chemicals needed to produce fentanyl.” As a result of the designations, after the effective date, US financial institutions are prohibited from engaging in transmittals of funds from or to CIBanco, Intercam, or Vector, or from or to any account or convertible virtual currency address administered by or on behalf of CIBanco, Intercam, or Vector.
These orders are the first designations by FinCEN pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, which provide Treasury with additional authorities to target money laundering associated with the trafficking of fentanyl and other synthetic opioids. FinCEN expects covered financial institutions to implement procedures to ensure compliance with the terms of the orders and to exercise reasonable due diligence to prevent engaging in transmittals of funds involving CIBanco, Intercam, or Vector. FinCEN has published FAQs to help these financial institutions comply with the terms of the orders.
Shortly after FinCEN’s announcement, Secretary of State Marco Rubio announced a new visa restriction policy that will apply to family members and close personal and business associates of individuals sanctioned under Executive Order (E.O.) 14059, which targets persons alleged to be involved in the trafficking of illicit drugs.
OFAC Sanctions Tren de Aragua Leader
OFAC has sanctioned Giovanni Vicente Mosquera Serrano, an alleged leader of the Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT) Tren de Aragua (TdA). According to OFAC, Mosquera Serrano is involved in TdA’s drug trafficking and financial operations. Mosquera Serrano’s designation follows similar OFAC designations of alleged cartel leaders on June 9 and June 18. The Department of State, through its Transnational Organized Crime Rewards Program, is offering a reward of up to $3 million for information leading to the arrest or conviction of Mosquera Serrano. The Federal Bureau of Investigation has also placed Mosquera Serrano on its Top 10 Most Wanted List.
White House Discusses Iran Sanctions Relief; Chinese Purchases of Iranian Oil
After his announcement of a ceasefire between Israel and Iran, President Trump stated on Truth Social that “China can now continue to purchase Oil from Iran.” The announcement prompted speculation that sanctions relief on Iranian oil exports to China was part of the ceasefire negotiations. The Trump administration has repeatedly sanctioned Chinese oil refineries and importers as part of its “maximum pressure” strategy on Iran.
A senior official from the White House later said that President Trump was “simply calling attention to the fact that, [because of US strikes on Iranian nuclear facilities and the ceasefire], the Strait of Hormuz will not be impacted, which would have been devastating for China.” The official stated that “[t]he President continues to call on China and all countries to import our state-of-the-art oil rather than import Iranian oil in violation of US sanctions.”
On Friday, President Trump said that he had been “working on the possible removal of sanctions,” but that his administration has “immediately dropped all work on sanction relief” in response to Iranian Supreme Leader Ayatollah Ali Khamenei’s claim that Iran won the recent conflict with Israel and that the US strikes on Iranian nuclear facilities were ineffective.
Rubio: Sanctions Against Russia Still Possible at the “Right Time and Place”
Secretary of State Marco Rubio stated during an interview that increased sanctions such as those proposed by Senators Lindsey Graham (R-SC) and Richard Blumental (D-CT) via the Sanctioning Russia Act of 2025 (S. 1241/H.R. 2548) “may happen” if the President determines that the Kremlin is not seriously entertaining its negotiations with Ukraine. Specifically, Rubio stated that the Trump administration has talked about the Act with Congress, including how to frame and structure it such that it provides “flexibility” for the President. However, Rubio cautioned that imposing sanctions would cede leverage that the US possesses over Russia and effectively end negotiations, which the President is not yet willing to do. According to Rubio, the President “will know the right time and place” in which he may want to push for the Sanctioning Russia Act of 2025, specifically, or other sanctions on Russia, more generally.
UK Developments
First UK Conviction for Breach of Anti-Terrorism Sanctions
A UK magistrates’ court convicted Aozma Sultana of breaching the UK’s Counter Terrorism Sanctions Regulations by failing to provide information to OFSI. On February 6, 2025, UK prosecutors charged Ms. Sultana with an offence under the UK Counter-Terrorism Sanctions Regulations. Ms. Sultana, who was charged with failing to provide the UK Government with information about her finances, was sanctioned by the UK Government and made subject to an asset freeze on March 27, 2024, following her suspected involvement in providing financial support to Gaza Now, a news agency that the UK Government considers to promote Hamas and Palestinian Islamic Jihad terrorist groups. The UK Charity Commission previously announced a statutory inquiry to investigate funds raised for charitable purposes by and on behalf of Ms. Sultana. The case highlights an increased focus on the enforcement of sanctions breaches, as well as a willingness to pursue criminal enforcement in appropriate cases against sanctioned individuals.
New Sanctions Whistleblowing Protections Introduced
On June 26, 2025, the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 came into force, expanding whistleblowing protections in the context of UK sanctions enforcement. The amendments designate the Treasury, as well as the Secretaries of State for Business and Trade and for Transport, as prescribed persons for sanctions-related disclosures. These amendments mean that workers who report concerns about financial, transport, or certain trade sanctions to these departments will now qualify for whistleblower protections, strengthening enforcement by encouraging disclosures of potential sanctions breaches.
UK Publishes New Sanctions Guidance for Non-UK Businesses
On June 27, 2025, the Foreign, Commonwealth and Development Office published new guidance to support non-UK businesses by providing information about UK sanctions relevant to non-UK businesses operating outside the UK. The guidance summarises the scope and requirements of UK sanctions and outlines the risks of non-compliance for non-UK businesses, particularly if they have business dealings with the UK. The guidance also includes practical advice on how to implement good compliance practices and avoid becoming complicit in the circumvention of UK sanctions. The guidance includes country-specific guides for businesses in Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Uzbekistan, which contain additional information about local laws and regulations that may be relevant to sanctions compliance for businesses operating in those countries. The materials have been made available in Armenian, Georgian, Russian, Thai, and Turkish.
OFSI Amends Russia Oil-Related General Licences
On June 27, 2025, OFSI amended two Russian oil-related General Licences. The continuation of business operations with Gazpromneft-Sakhalin LLC and any entity owned or controlled by it in connection with the exempt Sakhalin 2 project under General Licence INT/2025/5635700 was extended until June 28, 2026. Additionally, General Licence INT/20244423849, which exempts certain projects and countries from oil price cap restrictions was extended with respect to Sakhalin 2 until June 28, 2026.
EU Developments
Slovakia Seeks Delay on EU Sanctions Over Energy Security Concerns
Slovakia has reportedly announced it will not support the European Union's proposed 18th package of sanctions against Russia until its concerns over gas supplies post-2027 are resolved. Slovak Prime Minister Robert Fico has called for a delay in the vote, citing potential risks of energy supply shortages, rising prices, and up to €20 billion in arbitration losses due to existing contracts with Russia's Gazprom.
The sanctions package, proposed on 10 June 2025 by the European Commission, targets Russia's energy revenues, banks, and military industry as part of ongoing responses to its invasion of Ukraine. However, Slovakia and Hungary oppose another proposal recently issued by the European Commission plan to phase out Russian energy imports by 2027 (see here), arguing that it would make it difficult for the two countries to find alternative energy sources.
Fico emphasized that Slovakia sees the sanctions package as inseparably linked to the energy import timeline and insisted that key issues must be addressed before moving forward. While European diplomats remain optimistic about resolving the impasse at the EU summit, Fico has stated that Slovakia will not vote on the sanctions package at this time.
EU Council Amends EU Global Human Rights Sanctions Regime
The EU Council has amended several pieces of sanctions legislations under the EU Global Human Rights Sanctions regime. Decision 2020/1999 and Regulation 2020/1998 were revised to include five individuals to the list of those subject to restrictive measures outlined in the Annex to Decision 2020/1999, due to their responsibility for serious human rights violations and abuses in Syria. These violations include participation in violent incidents in Syria's coastal region in March 2025, as well as supporting the use of chemical weapons against civilians under the al-Assad regime. The newly listed individuals consist of three former members of the Syrian Republican Guard and Armed Forces, along with two prominent businessmen who provided financial support for crimes against humanity committed under the al-Assad regime. These individuals are subject to restrictive measures, including asset freezes, travel bans within the EU, and prohibitions on the provision of funds or economic resources.
Third Countries Align with EU Sanctions Targeting Guatemala
The High Representative of the EU has announced that Albania, Armenia, Bosnia and Herzegovina, Iceland, Liechtenstein, the Republic of Moldova, Montenegro, North Macedonia, Norway and Ukraine have aligned themselves with Council Decision 2025/1199, the framework for sanctions on those responsible for undermining democracy, the rule of law and a peaceful transfer of power in Guatemala. As reported in our June 16 Sanctions Update, the Decision added three individuals and one entity to the list of individuals and entities subject to restrictive measures in the Annex to Decision 2024/254, while also updating the entries for five individuals involved in activities undermining democracy and the rule of law.
EU Council Updates Sanctions Listing Against Russia
The EU Council has updated the framework concerning restrictive measures in view of Russia’s destabilizing activities. Specifically, Council Decision 2024/2643 and Regulation 2024/2642 were amended to add a Swiss-Cameroonian social media influencer to the list of individuals and entities set out in Annex I to Regulation 2024/2642. The individual added to the sanctions list has been identified as a vocal supporter of Russia’s geopolitical agenda since her participation in the 2019 Sochi Summit. The restrictive measures imposed include asset freezes and restrictions on financial transactions.
