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
OFAC Sanctions North Korean Money Laundering Networks
On November 4, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned eight individuals and two entities for their alleged roles in laundering funds from illicit North Korean schemes. According to Under Secretary John Hurley, the sanctioned parties “launder money to fund the [North Korean] regime’s nuclear weapons program… directly [threatening] U.S. and global security.”
Specifically, OFAC targeted two North Korean bankers who allegedly helped manage funds, including cryptocurrency, on behalf of OFAC-designated First Credit Bank; a North Korean information technology (IT) company and its president for obfuscating the origin of funds derived from IT-related illicit revenue schemes; and multiple individuals and an entity for facilitating sanctions evasion for the ultimate benefit of the North Korean regime.
OFAC’s designations follow a recent Multilateral Sanctions Monitoring Team (MSMT) report on North Korea’s violations and evasion of United Nations Security Council resolutions (UNSCRs) through cyber operations and IT worker schemes. They also follow similar designations made on September 25, August 27, July 24, and July 8.
OFAC Lifts Sanctions on Belarusian Airlines and Aircraft
On November 4, OFAC removed Open Joint Stock Company Belavia Belarusian Airlines (“Belavia”), as well as a private jet (EW-301PJ) operated by Belavia and allegedly used by officials and family members of the Belarusian President and OFAC Specially Designated National (“SDN”) Alexander Lukashenko, from the Specially Designated Nationals and Blocked Persons List (the “SDN List”). Belavia was previously designated by OFAC on August 9, 2023, for being the state-owned flagship carrier of the Government of Belarus. OFAC concurrently issued a general license (GL 12) to the Belarus Sanctions Regulations authorizing transactions related to certain blocked aircraft, including transactions related to the use of the aircraft by Lukashenko.
OFAC did not specify why it removed sanctions on Belavia and the private jet. OFAC previously issued a general license (GL 11) authorizing certain transactions involving Belavia on September 11, 2025, which outlets speculated was in exchange for Lukashenko’s release of 52 prisoners.
OFAC Targets Hizballah Operatives
On November 6, OFAC designated three individuals allegedly connected with laundering money from Iran to Lebanon in support of Hizballah, a Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT). OFAC said that Hizballah uses these funds to “support its paramilitary forces, rebuild its terrorist infrastructure, and resist the Lebanese government’s efforts to assert sovereign control over all Lebanese territory.”
OFAC previously designated Hizballah-related networks and officials on July 3, May 15, and March 28.
US and UN Provide Sanctions Relief for Syria Ahead of Meeting with al-Sharaa
On November 7, OFAC removed the Specially Designated Global Terrorist (“SDGT”) designations of Syria President Ahmed al-Sharaa and Interior Minister Anas Khattab. The removal follows a recent United Nations Security Council’s (UNSC) vote to remove sanctions on President al-Sharaa and Minister Anas Khattab, which were originally imposed by the ISIL and Al-Qaida Sanctions Committee, and comes just days ahead of President Trump’s scheduled meeting with President al-Sharaa on November 10.
The Trump administration has been searching for ways to provide sanctions relief to Syria following the toppling of the Bashar al-Assad regime. The Trump administration previously lifted a variety of sanctions and export controls on Syria in furtherance of President Trump’s Executive Order 14312, but has not yet fully lifted its economic restrictions on Syria.
According to the Wall Street Journal (WSJ), the Trump administration may push Congress for a full repeal of the Caesar Syria Civilian Protection Act of 2019 (the “Caesar Act”). Language for the repeal is currently present in the Senate’s version of the National Defense Authorization Act (NDAA) (S. 2296), but not in the House’s version, amid reported skepticism from members such as the Chairman of the House Foreign Affairs Committee, Representative Brian Mast (R-FL). Syria’s status as a State Sponsor of Terrorism (SST) has also not yet been removed.
UK Developments
UK Issues New Guidance on Countering Russian Sanctions Evasion
The UK Government has published new cross-departmental guidance on Countering Russian Sanctions Evasion, outlining how Russia continues to circumvent international sanctions and the steps UK businesses should take to prevent it. The guidance, issued by the Department of Business and Trade’s Office of Trade Sanctions Implementation (OTSI), highlights persistent evasion tactics such as complex trade routes, deceptive shipping practices, and the use of front companies to acquire restricted goods. It identifies the freight, shipping, and logistics sectors as particularly high risk and urges companies to strengthen due diligence, monitor for red flags such as vessel reflagging or falsified cargo documents, and adopt robust internal compliance controls. The guidance reflects the UK’s integrated enforcement approach, coordinated between the Office of Financial Sanctions Implementation (“OFSI”), OTSI, and law enforcement partners to detect and disrupt evasion networks. Businesses are reminded of their legal duty to report suspected breaches and encouraged to make voluntary disclosures through OFSI’s or OTSI’s reporting channels. Firms involved in transport, freight forwarding, or related financial services should invest in monitoring systems, staff training, and record-keeping to mitigate both enforcement and reputational risks while supporting the UK’s broader effort to cut off Russia’s access to trade and finance.
UK Government Publishes New Sanctions Enforcement Page
The Foreign, Commonwealth and Development Office (FCDO), OFSI, and OTSI announced the launch of a new Sanctions Enforcement Action page on GOV.UK. The change creates a single location for updates on penalties, enforcement actions, and public case summaries. The new resource consolidates information previously dispersed across multiple agency websites and forms part of the UK’s ongoing effort to improve transparency following its cross-government review of sanctions implementation and enforcement. The new page will feature OFSI monetary penalty notices, HM Revenue and Customs (HMRC) compound settlements, OTSI disclosures, and National Crime Agency (NCA) case studies, offering businesses a clearer view of enforcement trends and compliance expectations. It is also intended to encourage a learning-based approach by publishing anonymised case studies to illustrate how breaches occur and how they can be prevented. Businesses are encouraged to review this resource regularly as part of sanctions compliance training and internal audit processes.
OFSI Amends UK Payments Processing General Licence
OFSI has updated General Licence INT/2024/5394840, which allows certain UK financial institutions to process payments that were previously blocked because they passed through a bank sanctioned by the UK Russia sanctions regime, provided that both the sender and the recipient are not themselves subject to UK sanctions (the “GL”). The updates to the GL include: (i) an extension to the expiry of the GL to 7 November 2027 (The GL was first introduced in 2022 and was amended in 2023), (ii) the definition of Designated Credit or Financial Institution has been amended; and (iii) the reporting conditions have been amended. Within 14 days of the end of each calendar month, a Relevant Institution must report to HM Treasury any Relevant Payments processed under General Licence INT/2024/5394840 during that calendar month with details and supporting evidence of the amount(s) processed; the name of the Original Sender and the Original Intended Recipient; the name on the account at the final institution in the chain of payments to which the funds were processed; the payment route used; and the date on which the funds were processed. Any persons intending to use the GL should consult the copy of the GL for full details of the permissions and usage requirements.
UK Updates DPRK Trade Sanctions Guidance
The UK has updated its guidance under the Democratic People’s Republic of Korea (Sanctions) (EU Exit) Regulations 2019 (the “DPRK Regulations”) to clarify the treatment of export licences for media-related equipment. The amendment allows independent media organisations to export certain luxury goods to the DPRK strictly for legitimate news-gathering purposes, provided those items are removed once the assignment ends. This clarification ensures journalistic freedom while preserving the integrity of trade sanctions on the export of these items. The change relates to regulations 45–47 of the DPRK Regulations, which prohibit the export of specified goods but now include this limited exemption for press activity. Businesses involved in media, logistics, or technology should verify whether proposed exports qualify and ensure that licensing conditions are met in full, including re-export obligations.
UK Parliament Publishes Research Briefings on Russia Sanctions
The UK House of Commons Library has published two new research briefings: Sanctions Against Russia: What Has Changed in 2025? and Sanctions Against Russia: Targeting Third Countries. The papers assess developments in UK, EU, and US sanctions coordination and the challenges of addressing circumvention through non-aligned states. They note that Russia remains the most heavily sanctioned country in the world, with ongoing efforts to tighten enforcement and address the role of intermediaries. For UK businesses, the reports serve as a reminder of the increasing importance of end-use and end-user checks, particularly when dealing with counterparties in jurisdictions with weak export control regimes. The briefings also explore the UK’s growing emphasis on enforcement and intelligence-sharing with international partners, reflecting a shift from sanctions policy development to practical enforcement outcomes.
New Designations Made Under Domestic Counter-Terrorism Sanctions Regime
The UK Government has designated one individual and one entity, Kieren James Gallagher and New Irish Republican Army, for their alleged involvement in terrorist activities under the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 (see OFSI notice here). According to a UK Government press release, both are being targeted for being responsible for, or involved in, terrorist activity, and/or providing financial services, or making available funds or economic resources, for the purposes of terrorism. The newly designated targets are now subject to an asset freeze, and, in the case of the individual, a UK travel ban and director disqualification. This action is the second use of the Treasury-led domestic counter-terrorism regime to target Northern Ireland-related terrorism and signals that the UK is working proactively to take action against those who try to exploit the UK’s financial system for this activity.
UK Government Publishes Case Study on Russia Sanctions Compound Settlement
The UK’s HMRC has published a case study on the £1.1 million compound settlement that it reached earlier this year with a UK company for breaching financial sanctions under The Russia (Sanctions) (EU Exit) Regulations 2019. The breach related to the supply of goods to Russia in contravention of export restrictions. The settlement, one of the largest imposed for a Russia-related sanctions offence, was agreed in lieu of criminal prosecution. HMRC emphasised that compound settlements are used where a company cooperates fully and there is no evidence of deliberate evasion. This case underlines the UK government’s continued enforcement focus on Russia export controls and serves as a reminder for exporters to ensure robust compliance systems and to seek appropriate licences where required.
UK Government Announces New Export Control Regulations
The Export Control Joint Unit (ECJU) has announced plans to introduce The Export Control (Amendment) (No.2) Regulations 2025 in December. The forthcoming legislation will align the UK’s export control regime with international standards and introduce new controls over emerging technologies, dual-use goods, and items linked to capital punishment or torture. The updates also reflect policy shifts such as the lifting of the arms embargo on Armenia and Azerbaijan, and are expected to harmonise licensing processes across Northern Ireland. In pertinent part, and further to the adoption by the EU of similar controls which apply in Northern Ireland, the amendments effectively move controls on these goods and technology from Schedule 3 of The Export Control Order 2008 (S.I. 2008/3231) to Annex I of the assimilated Dual Use Regulation Council Regulation (EC) No 428/2009, and update the list of those controlled items. Businesses operating in defence, technology, or logistics should review their export classifications once the regulations are published, as changes may require new or amended export licences. The ECJU has encouraged early engagement with its helpline and SPIRE system to ensure uninterrupted trade compliance.
UK Delists President of Syria
The UK Government has delisted two individuals designated under the UN ISIL (Da’esh) and Al-Qaida sanctions regime, reflecting UN Security Council Resolution 2799 (2025). The two individuals that have been delisted include Syrian President, Ahmad al-Sharaa, and Syria's interior minister, Anas Khattab. The decision of the UK Government follows that of the United Nations Security Council, which did the same this week, and comes after the UK lifted some sanctions on Syria earlier this year in April; however, restrictions related to arms and security remain in place. This move by the UK Government highlights its commitment to supporting a peaceful and Syrian-led transition to help build a more stable future for the state of Syria.
EU Developments
EU Council Updates Individual Listing under ISIL (Da’esh) and Al-Qaeda Sanctions Framework
The EU Council has amended an individual listing under the autonomous restrictive measures regime targeting ISIL (Da’esh) and Al-Qaeda, following a series of updates at the UN level. Specifically, changes to Council Regulation (EC) No 881/2002 reflect the UN Security Council Sanctions Committee’s decision to revise the listing of Abd El Kader Mahmoud Mohamed El Sayed. The updated entry now includes a confirmed prison sentence in Italy and revised status information.
This update follows the recent renewal of the EU’s sanctions regime against ISIL (Da’esh) and Al-Qaeda, as noted in our November 3 Sanctions Update.
EU Tightens Visa Rules for Russian Nationals
The European Commission has recently adopted stricter rules for issuing visas to Russian nationals, in light of growing security concerns linked to Russia’s war of aggression against Ukraine. The decision is based on a joint assessment by EU Member States under local Schengen cooperation and builds on earlier EU actions, such as the full suspension of the Visa Facilitation Agreement with Russia and the Commission’s 2022 guidelines on visa procedures and border controls for Russian citizens at the EU’s external borders.
Under the newly adopted Implementing Decision, Russian nationals applying from within Russia will no longer be eligible for multiple-entry visas. Instead, they must apply for a new visa each time they wish to travel to the European Union, allowing Member States to conduct closer and more frequent checks.
Only specific groups, such as close relatives of EU residents or Russian citizens legally residing in the EU and transportation workers, may still qualify for limited multiple-entry visas, provided they meet strict conditions.
Exceptions remain for independent journalists, human rights defenders, representatives of civil society organizations or other vulnerable categories.
Asia-Pacific Developments
Australia Sanctions North Korean Cyber Criminals and Issues Advisory Notes
On November 6, 2025, Australia imposed targeted financial sanctions and travel bans on four entities and one individual associated with North Korea’s cyber operations. The designations include Park Jin Hyok, Kimsuky, Lazarus Group, Andariel, and Chosun Expo, all of whom are alleged to have engaged in cyber-enabled activities such as cryptocurrency theft, fraudulent IT services, and espionage. These operations are believed to have generated revenue used to support North Korea’s weapons of mass destruction and ballistic missile programs. The sanctions, enacted under the Autonomous Sanctions Regulations 2011, freeze any assets held in Australia and prohibit entry into the country for the listed parties.
On the same day, the Australian Sanctions Office released eight new advisory notes to assist the regulated community in identifying and managing sanctions risks. One of these notes specifically addresses the cyber risks posed by information technology workers from the DPRK. It warns that DPRK nationals have been securing remote employment with foreign companies, including Australian businesses, by concealing their identities and locations through virtual private networks and remote monitoring tools. These individuals, often operating from DPRK, China, Russia, or Southeast Asia, may use their access to sensitive systems to conduct cyber espionage, steal intellectual property, or generate revenue for the North Korean regime. The advisory urges Australian businesses to strengthen employment screening processes and monitor for indicators of sanctions risk when engaging remote IT professionals.
Japan Reaffirms Sakhalin-1’s Strategic Role Amid Sanctions on Russian Shareholders
In November 2025, Japan’s Ministry of Economy, Trade and Industry (METI) reaffirmed the strategic importance of the Sakhalin-1 oil and gas project in light of new US sanctions targeting Russian shareholders, including Rosneft. METI stated that Japan’s energy security depends on foreign projects such as Sakhalin-1 and confirmed its intention to take necessary measures to ensure a stable supply. This position was reiterated despite Japan sourcing over 90 percent of its crude oil imports from the Middle East, underscoring the government’s recognition of Sakhalin-1’s role in diversifying energy sources. The project, formerly operated by ExxonMobil, now includes Rosneft, ONGC Videsh, and the Japanese consortium SODECO among its stakeholders.
China Adjusts Measures on US Entities Listed Under Export Control and Unreliable Entity Lists
On November 10, 2025, China’s Ministry of Commerce implemented adjustments to previously imposed non-tariff measures targeting US entities, in accordance with the consensus reached during China-US economic and trade consultations in Kuala Lumpur. Under the Export Control List, China lifted restrictions on 15 US entities listed in the March 4 announcement and extended the suspension of restrictions for another year on 16 entities listed in the April 4 announcement. These entities had been subject to prohibitions on the export of dual-use items. Separately, under the Unreliable Entity List, China terminated measures against entities listed in the March 4 announcement and extended the suspension of measures for one year on those named in the April 4 announcement. Chinese companies seeking to export dual-use items or conduct transactions with the affected entities must apply for approval, which will be reviewed in accordance with applicable regulations.
