Overview
The Sanctions Update, compiled by attorneys from Steptoe’s award-winning International Regulatory Compliance team and the Stepwise: Risk Outlook editorial team, publishes every Monday. Guided by the knowledge of Steptoe’s industry-leading International Trade and Regulatory Compliance team, the Sanctions Update compiles and contextualizes weekly developments in international regulatory enforcement and compliance, as well as offers insights on geopolitical context, business impacts, and forthcoming risks.
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The Lede
US Sanctions Cartel de los Soles as Tensions with Venezuela Rise
On November 24th, the US Department of State designated Venezuela’s Cartel de los Soles as a Foreign Terrorist Organization (FTO), pursuant to Section 219 of the Immigration and Nationality Act. The cartel, a popular name for an informal grouping of corrupt high-level politicians and officials, was previously designated by the Department of the Treasury pursuant to EO 13224 in July of this year. The designation builds upon the US’ conception of Venezuelan President Nicolas Maduro as a drug kingpin, reinforcing the Trump administration’s legal and strategic basis for escalating operations against the drug trade and Maduro’s regime in Venezuela.
The target of last week’s sanctions, the Cartel de los Soles, is an amorphous one: the name emerged in the popular lexicon in the 1990s as a way to refer to high-ranking military officers who had grown rich from drug running, but has expanded to comprise police and other government officials perceived to be benefiting from other types of corruption, like illegal mining or fuel trafficking. As such, the designation of the group as a “cartel” is somewhat dubious—the name is mostly used by the public to malign politicians, and individuals are unlikely to self-identify as a member—as is the assertion that Maduro leads the organization. Experts consider the group a disorganized “noncartel entity” at best, and nonexistent at worst. Therefore, secondary sanctions risk could feasibly encapsulate broad swaths of Maduro’s government and Venezuelan public officials.
While the Venezuelan government is reportedly involved in organized crime and drug trafficking activities, experts disagree on the extent to which Maduro actively directs and personally benefits from the flow of drugs. Many assess that Maduro has set up a system that encourages corruption —without directly managing it—as a way to secure military loyalty. Thus, the Cartel de los Soles’ designation is likely a primarily symbolic move, given the group’s unclear membership and the fact that the Maduro government is already heavily sanctioned. However, this depends in significant part on whether and how the Trump administration seeks to enforce the designation, including any enforcement actions they might seek to bring.
In recent months, the US has built its capability, as well as a strategic and legal basis, to conduct strikes on Venezuela and the Maduro regime. Since the summer, the White House has massed military assets in the Caribbean region (including its largest aircraft carrier), stepped up airstrikes on alleged drug trafficking vessels, authorized covert operations within Venezuela’s borders, and reportedly entertained discussions around ousting President Maduro.
The temperature has risen considerably in recent weeks. On Saturday, President Trump posted to social media that “Airlines, Pilots, Drug Dealers, and Human Traffickers” should consider Venezuelan airspace closed, following Thanksgiving remarks in which Trump said land strikes were “easier” and “going to start very soon.” The comments came after leaks to news outlets at the beginning of the week indicating that US operations against Maduro’s regime would enter a “new phase” in the coming days—reportedly to first include covert actions within Venezuela, likely followed by strikes on Venezuelan territory.
Despite the lack of consensus on the Cartel de los Soles as a cohesive entity, its recent FTO designation further solidifies the strategic underpinnings of the Trump administration’s military policy against Venezuela, which sees drug trafficking, organized crime and cartel violence, and Venezuela’s regime as under the broad umbrella of “narco-terrorism.” The White House has built upon its conception of Maduro as a drug kingpin in the last year, tying historical enmity with the regime in Caracas to efforts to stem the flow of drugs into the US, a central issue for Trump’s second term. Venezuela does not produce significant quantities of fentanyl and is not a part of the primary cocaine trafficking pipeline to the US, which goes through Colombia and the Pacific Ocean (although it is a launchpad for drug trafficking toward Europe through West Africa). Nonetheless, there is a high probability of escalation in the coming weeks, likely to result in heightened operational obstacles in the Caribbean and even more dire operational, reputational and legal challenges for the few American companies still doing business with the Maduro regime.
US Developments
Trump Administration Considering Sanctions on China for Purchases of Russian LNG
In a letter from Senior Bureau Official and Deputy Assistant Secretary for Senate Affairs, Paul Guaglianone, on November 21, the State Department said it would give “careful consideration” to imposing sanctions on Chinese buyers of Russian liquefied natural gas (LNG) from the sanctioned Arctic LNG 2 project.
The letter, which came in response to a September 19 request from Senate Democrats to Secretary of State Marco Rubio for information on the Trump administration’s plans to enforce sanctions on the Arctic LNG 2 project, was released by the Senate Banking Committee alongside a statement from Ranking Member Elizabeth Warren (D-MA) calling for Congressional review of any “unwinding” of Russia-related sanctions.
The letter did not commit the Trump administration to any course of action.
OFAC Imposes $4.6M Penalty for Russia Violations
On November 24, OFAC announced that it had imposed a $4,677,552 penalty on a real estate investor for alleged violations of OFAC sanctions on Russia and failure to comply with an OFAC subpoena.
Specifically, OFAC alleged that, from around April 2023 to March 2024, the real estate investor, acting through and on behalf of an Atlanta, Georgia-based company, King Holdings LLC, willfully dealt in US residential property owned by a family member of a Russian oligarch who was sanctioned in March 2022, including by mortgaging, renovating, and selling the property, despite an OFAC cease-and-desist letter.
OFAC alleges that the investor concealed the real estate sale from OFAC. OFAC determined that the alleged violations were not voluntarily disclosed and were egregious. OFAC imposed the statutory maximum penalty for this case.
Senate Banking Chair Expresses Support for Russia Sanctions
On November 22, the Chairman of the Senate Committee on Banking, Housing, and Urban Affairs, Sen. Tim Scott (R-SC), issued a statement expressing support for “tough, targeted” sanctions on Russia. Specifically, Chairman Scott committed to working with Sens. Lindsey Graham (R-SC) and Richard Blumenthal (D-CT), as well as Congressional leadership, to bring the Sanctioning Russia Act of 2025 to President Trump’s desk.
As reported previously, the Sanctioning Russia Act of 2025, a sweeping sanctions and tariff-related bill, has been the subject of renewed interest in Congress after President Trump indicated he would support the legislation. However, the bill still faces notable obstacles.
House Speaker Mike Johnson (R-LA) and Senate Majority Leader John Thune (R-SD) have expressed different views, for instance, on which Chamber should move on the legislation first. Meanwhile, the Trump administration continues to negotiate a peace plan with Russia and Ukraine, the outcome of which could impact whether President Trump maintains his support for greater sanctions on Russia or rescinds it.
UK Developments
OFSI Publishes New General Licence Authorizing Continuation of Business with Certain Lukoil International Entities
OFSI has published General Licence INT/2025/8031092 for the Continuation of Business of Lukoil International Entities, which authorises individuals and entities required to comply with UK sanctions to continue transacting with Lukoil International GmbH and its subsidiaries (“Lukoil International Entities”) (the “GL”). Subject to certain conditions, the GL authorises the continuation of business operations involving Lukoil International Entities, provided that funds related to the transactions are paid into a frozen account. The GL also allows UK financial institutions to process payments related to these continued business operations. Additionally, OFSI has published new FAQ 174 under its FAQ Guidance, which explains the new GL and its issuance in the context of ongoing negotiations for the sale of Lukoil International GmbH’s assets.
UK’s National Crime Agency Exposes Russian Money Laundering Network Operating in the UK
The UK’s National Crime Agency (NCA) has disclosed the results of “Operation Destabilise”, a major multi-agency investigation that uncovered a multi-billion-dollar money-laundering network operating inside the UK to support the Russian state and organised crime groups. The network allegedly purchased a Kyrgyz bank to facilitate sanctions evasion and used UK infrastructure to move illicit funds, with UK-based criminals converting cash from drug trafficking, firearms and immigration crime into cryptocurrency for onward transfer. Coordinated enforcement across 28 UK towns and cities resulted in 45 arrests and more than £5.1 million in seized cash, alongside the disruption of courier routes and associated UK companies linked to Russia-connected networks. The case highlights growing law enforcement attention focused on crypto-enabled money laundering and informal value-transfer systems. The NCA has stressed that businesses should remain alert to transactions involving high-risk jurisdictions, complex structures or large volumes of cash, and ensure strong internal controls and suspicious activity reporting processes are in place.
OFSI Amends Agricultural Commodities General Licence
OFSI has amended General Licence INT/2022/2349952, which pertains to transactions related to agricultural commodities, including the provision of insurance and other services (the “Agricultural Commodities GL”). The Agricultural Commodities GL was initially granted under regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). Subject to certain conditions, the Agricultural Commodities GL permits certain exporters, producers, sellers or transporters of agricultural commodities (including food, fertiliser, seed, feed, and reproductive materials) to receive or transfer funds and economic resources from any person, including from UK designated persons, in connection with the export, sale, production and transport of agricultural commodities. The GL was amended to reflect changes to Schedule 3E, Part 2A of the Russia Regulations and expands the definition of “fertiliser” to include fertilisers classified under commodity code 2814 and its subheadings. Any persons intending to use the Agricultural Commodities GL should consult the copy of the licence for full details of the permissions and usage requirements.
UK Government Updates Russia Sanctions Guidance with Trade Licences Guide
The UK Government has updated its Russia sanctions statutory guidance to incorporate a link to a new guidance page on trade licence considerations under the Russia sanctions regime. Under Section 3.4 of the Russia sanctions guidance, “Licensing for trade sanctions”, there is now a link to the new guidance page: “Look up considerations for trade licences under the Russia sanctions”. This new guidance page is a navigable and scannable guide listing all considerations for trade licences for certain prohibitions, and links to general licences available that form a part of the Russia sanctions guidance. The new guidance page recommends that businesses use the new guidance if they think that a proposed activity would fall within one of the listed licensing considerations and should explain why they believe the particular licensing consideration is satisfied in any licence application. The new guidance also reminds businesses that they should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until a licence has been granted.
EU Developments
European Commission Updates FAQs Following 19th Sanctions Package Against Russia
The European Commission published an update to its FAQs on sanctions against Russia and Belarus to reflect the changes introduced by the 19th sanctions package against Russia. The revised FAQs include guidance on the prohibition of the purchase, import, or transfer of Russian liquefied natural gas (LNG) under Article 3ra of Council Regulation 833/2014, with phased implementation depending on contract type. The Commission clarifies that the transfer of Russian LNG by EU operators is prohibited under Article 3ra, regardless of its final destination, including to third countries.
The Commission guidance also addresses the infrastructure transaction ban and restrictions to transactions with state-owned enterprises under Article 5aa of Council Regulation 833/2014. On the latter, the Commission clarifies that EU insurers may underwrite voyages calling at ports owned by listed state-owned enterprises without breaching Article 5aa, as the provision of insurance to the vessel does not constitute a direct or indirect transaction with the listed entity. However, if insured damage occurs, an EU insurer may only pay a valid claim to the state-owned enterprise if the vessel’s entry was for a purpose covered by an exemption under Article 5aa. The guidance further notes that exemptions for Rosneft and Gazprom Neft’s oil and gas imports into the EU were removed under the 19th sanctions package against Russia.
EU Council Renews Sanctions Regimes Targeting Türkiye and Mali
Following a recent review, the EU Council has renewed two sanctions regimes.
On November 24, the EU Council extended the sanctions regime against Türkiye under Council Decision 2019/1894 for one year, until November 30, 2026. The sanctions regime targets individuals and entities involved in unauthorized drilling activities related to hydrocarbon exploration and production within the territorial sea, exclusive economic zone, or continental shelf of the Republic of Cyprus, as well as those providing financial, technical, or material support for these operations. The restrictive measures include a travel ban, asset freezes, and a prohibition on making funds or economic resources available to listed persons or entities. Following the recent update, the sanctions list has been amended by the EU Council and currently contains no entries.
On December 1, the EU Council amended Council Decision 2017/1775 to renew restrictive measures in view of the situation in Mali until December 14, 2026 and update the sanctions listing in the respective Annex. The sanctions framework targets individuals and entities linked to actions or policies that threaten the peace, security, or stability of Mali, or obstruct or undermine the successful completion of Mali’s political transition. The current list includes identified leaders and instigators of the 18 August 2020 coup, an individual who played a central role in the overthrow of President Ibrahim Boubacar Keïta, and the former head of the Wagner Group in Mali.
Asia-Pacific Developments
Singapore Imposes Sanctions on Four Israelis Over West Bank Violence
On November 21, 2025, Singapore announced the imposition of financial sanctions on four Israeli nationals for involvement in acts of extremist violence against Palestinians in the West Bank. The individuals are now subject to asset freezes and restrictions under Singapore’s autonomous sanctions framework. The Ministry of Foreign Affairs stated that these measures reflect Singapore’s position that such actions are unlawful and undermine prospects for a two-State solution.
Malaysia Regulator Fines Moneywave for Breach of Sanctions Screening Rules
Bank Negara Malaysia announced on November 26, 2025, that it had imposed an Administrative Monetary Penalty of RM14,000 on Moneywave Sdn. Bhd. for failing to comply with targeted financial sanctions screening requirements under section 74(3) of the Money Services Business Act 2011. The enforcement action followed an on-site examination that revealed Moneywave did not maintain a sanctions database based on the United Nations Security Council Resolutions List and the Domestic List. Moneywave has since implemented remedial measures by subscribing to a commercial sanctions database service integrated into its currency exchange system.
South Korea Unveils Largest Sanctions Package Against Online Crime Network
On November 27, 2025, South Korea imposed sanctions on 15 individuals and 132 entities linked to a Southeast Asia-based network accused of orchestrating online crimes targeting South Korean nationals. This represents Seoul’s first use of sanctions against transnational criminal activity in the region and constitutes its largest single sanctions package to date. The decision follows a series of joint crackdowns and heightened cooperation with regional partners, including a recent memorandum of understanding with China aimed at combating voice phishing and online fraud.
Sanctions Compliance Pressures Drive India’s Shift to Alternative Oil Sources
India’s imports of Russian crude are expected to decline sharply in December 2025 as Western sanctions tighten and banks increase scrutiny of transactions. According to refining sources, volumes are expected to drop to about 600,000–650,000 barrels per day, marking the lowest level in at least three years. The decline follows US sanctions targeting major Russian producers Rosneft and Lukoil and an EU deadline in January restricting fuel from refineries processing Russian crude. Most Indian refiners have halted purchases from sanctioned entities and shifted to alternative sources to ensure compliance.
