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
State Department Sanctions ICC Judges, Issues GLs
The Department of State designated four International Criminal Court (ICC) judges—Solomy Balungi Bossa, Luz del Carmen Ibáñez Carranza, Reine Adelaide Sophie Alapini Gansou, and Beti Hohler—for allegedly “directly engag[ing]” in efforts to investigate, arrest, detain, or prosecute US or Israeli nationals without the consent of either nation. Neither state is a party to the Rome Statute, which is the treaty that established the ICC. Specifically, according to the State Department, Judge Bossa and Judge Ibáñez Carranza authorized the ICC’s investigation against US personnel in Afghanistan, and Judge Alapini Gansou and Judge Hohler authorized the ICC’s issuance of arrest warrants targeting Israeli Prime Minister Benjamin Netanyahu and former Minister of Defense Yoav Gallant.
On the same day as the State Department’s designations, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued seven general licenses (GL) exempting certain persons or activities from the ICC-related sanctions. In response to the US’s designations, which follow the designation of ICC Prosecutor Karim A. A. Khan, the ICC issued a press release “deplor[ing]” the additional designations and labeling them a “clear attempt to undermine the independence of an international judicial institution.”
Congress Continues to Back Russia Sanctions as Trump Urges Restraint
Senator Jeanne Shaheen (D-NH), the Ranking Member of the Senate Foreign Relations Committee, has continued her call for greater pressure on Russia to bring an end to its ongoing war with Ukraine. “We need to maximize pressure on Putin,” Shaheen asserted. “That means new sanctions, like those in the Graham-Blumenthal legislation…[as well as] enforcing the sanctions already in place.” Shaheen’s remarks are the most recent push for Congress to consider and, ultimately, pass the Sanctioning Russia Act of 2025, which was introduced by Senators Lindsey Graham (R-SC) and Richard Blumental (D-CT) and currently has over 80 co-sponsors in the Senate (S. 1241) and nearly 60 co-sponsors in the House (H.R. 2548).
After recently visiting President Zelenskyy in Ukraine, Graham claimed that he will be “pushing the Senate to take action by using the expedited Rule 14 process to bring the sanctions bill to the floor,” and that he hopes to have new sanctions implemented by the G7 Summit (starting June 15 in Alberta). Notably, when asked about increasing pressure on Russia, Speaker of the House Mike Johnson (R-LA) expressed support, stating that “[t]here’s [sic] many members of Congress that want us to sanction Russia as strongly as we can…[a]nd I’m an advocate of that.”
Though the White House has grown increasingly frustrated with the Kremlin, the Wall Street Journal reported that the Trump administration has asked Graham to significantly weaken the bill while the White House seeks to repair its relationship with Putin. President Trump has called the bill “harsh” and said that the bill should not move forward without his approval.
OFAC Targets Iranian “Shadow Banking” Network
OFAC has sanctioned over 30 individuals and entities tied to an Iranian family that has allegedly laundered billions of dollars through the international finance system as part of Iran’s “shadow banking” network. According to OFAC, Iran’s government uses the network to evade sanctions and move money from its oil and petrochemical sales. The designees included 17 entities based in Hong Kong and 5 entities based in the United Arab Emirates.
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) concurrently issued an updated advisory on detecting Iran’s oil smuggling and shadow banking activities. Treasury Secretary Scott Bessent has said that “Treasury will continue to leverage all available tools to target” Iran’s shadow banking system. These developments are the latest steps in the Trump administration’s “maximum pressure” strategy set forth in National Security Presidential Memorandum 2.
OFAC Sanctions Cocaine Trafficking Network
OFAC has sanctioned two Colombian nationals and four Guyanese nationals for allegedly trafficking tons of cocaine from South America to the US, Europe, and the Caribbean. According to OFAC, the designees used “boats and narco-subs” and clandestine airstrips to traffic the drugs with the assistance of an allegedly corrupt Guyanese official from the Guyana Police Force (GPF). The designations continue the trend of the Trump administration targeting drug trafficking through the use of sanctions authorities.
Senator Expresses Concerns Over Terrorist Fundraising on X
Senator Elizabeth Warren (D-MA), the Ranking Member of the Senate Banking, Housing, and Urban Affairs Committee, sent a letter to Scott Bessent, the Secretary of the Treasury, and Marco Rubio, the Secretary of State and National Security Advisor, raising concerns about a recent investigative report from the Technology Transparency Project alleging that the social media platform “X” allows sanctioned individuals to pay for services or perks using cryptocurrencies, thereby circumventing US sanctions.
In the letter, Warren asks the Treasury Department to investigate X for alleged violations of US sanctions authorities and, more broadly, to report whether Treasury has conducted assessments about the increasing prevalence of cryptocurrencies and their impact on the efficacy of sanctions. Warren also raises concerns about the bipartisan GENIUS Act, which would regulate stablecoins and she claims would, if passed in its current iteration, “turbocharge sanctions evasion and other illicit activity.”
State Department Imposes Visa Restrictions for Exploiting Cuban Medical Professionals
The State Department has taken steps to impose visa restrictions on several Central American government officials and their family members for their alleged ties to Cuba’s forced labor scheme, particularly as they relate to Cuban medical mission programs. This follows an announcement from February 25, 2025, in which Secretary Rubio noted that the US would be expanding “an existing Cuba-related visa restriction policy that targets forced labor linked to the Cuban labor export program.”
UK Developments
OFSI Releases New Video Guidance on UK Financial Sanctions
On June 4, 2025, OFSI released a new video series to provide introductory guidance on UK financial sanctions to industry. The bite size guidance videos address a range of topics, including OFSI guidance, sanctions screening, reporting to OFSI, and the use of general and specific licences. The new guidance builds on the UK government’s recent commitment in its first cross-government review of sanctions implementation and enforcement to provide additional guidance for sectors less familiar with sanctions compliance.
UK Publishes Strategic Defence Review
On June 2, 2025, the UK government published the Strategic Defence Review 2025, a root and branch review of UK defence. Among other topics the review identifies Russia as “an immediate and pressing threat” and China, Iran, and North Korea as posing strategic challenges. The review also recommends the creation of a new Defence Exports Office within the Ministry of Defence to drive defence collaboration and trade with the UK’s allies, as well as a review of export licensing policies. The review represents a pivotal moment for UK security policy, however, much remains to be clarified with respect to the implementation and funding of the recommendations made in the review.
EU Developments
Discussions on EU-US Coordination on Russian Sanctions
On June 2, European Commission President Ursula von der Leyen met with US Senator Lindsey Graham in Berlin to discuss strengthening EU-US coordination on sanctions against Russia in response to its ongoing aggression in Ukraine. In the read-out of the meeting, the Commission stressed the need for a ceasefire and welcomed US Senator Graham’s bipartisan bill proposing steep tariffs on countries buying Russian energy, which aligns with the EU’s upcoming 18th sanctions package targeting Russia’s energy and banking sectors. The bill runs counter to President Trump’s attempts to bring Putin to the negotiating table, and the White House has reportedly sought to water down the Graham-Blumenthal package, despite rising momentum and EU support.
Third Countries Align with EU Sanctions
The High Representative of the EU has announced that Albania, Bosnia and Herzegovina, Iceland, the Republic of Moldova, Montenegro, North Macedonia, and Ukraine have aligned themselves with several Council decisions adopted on May 20. Specifically, these countries have aligned themselves with Decision 2025/963, which introduced economic measures targeting transactions involving tangible assets, as well as those of financial institutions, credit institutions, and entities providing crypto-asset services connected to Russia’s destabilizing activities. The same group of countries, along with Georgia, Liechtenstein, and Norway, have also aligned themselves with Decision 2025/960, which adds three entities to the annex of Decision 2018/1544 listing individuals and entities subject to restrictive measures against the proliferation and use of chemical weapons.
Additionally, Albania, Bosnia and Herzegovina, Iceland, Liechtenstein, Montenegro, North Macedonia, Norway, and Ukraine have aligned themselves with Decision 2025/931, which strengthened restrictions against Russia as part of the 17th sanctions package. This group of countries, together with the Republic of Moldova, have also aligned with two further Council decisions under the 17th sanctions package. The first alignment pertains to Decision 2025/957, which imposes restrictive measures on 28 individuals responsible for serious violations of human rights. The second alignment concerns Decision 2025/936, which added 17 persons and 58 entities responsible for actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine to the list of persons, entities and bodies subject to restrictive measures set out in the annex to Decision 2014/145/CFSP.
Asia-Pacific Developments
North Korea Condemns Multilateral Sanctions Monitoring Report While Reaffirming Support for Russia
In early June 2025, North Korea issued a strong rebuke against a report by the Multilateral Sanctions Monitoring Team that scrutinized the country’s expanding economic and military cooperation with Russia. The report, which highlighted potential violations of international sanctions regimes, particularly those imposed by the United Nations and the United States, was labeled by Pyongyang as “hostile” and “outrageous encroachment” on its sovereignty. North Korea emphasized that its bilateral engagements with Russia are lawful and framed the report as an attempt to interfere with sovereign economic activities. The statement did not directly address specific allegations related to sanctions evasion, such as arms transfers or financial transactions, but dismissed the Monitoring Team’s claims as politically motivated.
Shortly thereafter, on June 4, during a meeting between North Korean leader Kim Jong Un and Russian Security Council Sergei Shoigu, North Korea reiterated its full support for Russia’s military actions in Ukraine, describing the relationship as one of “unconditional support.” Pyongyang emphasized that its backing of Russia was rooted in shared strategic interests. Analysts note that the reaffirmation of ties between Pyongyang and Moscow could prompt closer monitoring by sanctions authorities, particularly regarding dual-use technologies, financial channels, and ballistic missile programme.
Operational Fallout in Asia from US Sanctions on Iranian Oil Smuggling Networks
In June 2025, US sanctions enforcement actions targeting Iranian oil smuggling networks have had direct operational consequences in Asia, notably impacting China Certification & Inspection Group (CCIC) Singapore. Following its sanctioning by OFAC for facilitating Iranian oil shipments to China, the company, a key player in commodity inspection and certification, reportedly laid off around 300 employees. According to OFAC, between late 2023 and 2024, CCIC Singapore provided inspection services for multiple sanctioned vessels transporting Iranian oil, including ship-to-ship transfers and alleged falsification of cargo documentation to disguise Iranian crude as Malaysian.
