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
What’s Next for US Sanctions in Venezuela Post-Maduro
Last week, the US sanctions and military pressure campaign against Nicolas Maduro’s regime in Venezuela culminated in a shock strike on Caracas and the extraction of Maduro and his wife to the US, where they will stand trial for conspiracy to import cocaine and related charges. The escalation follows months of heightened sanctions and growing military confrontation, ushering in a new era of US engagement with the country. The US has not yet commented on a new sanctions strategy for Venezuela beyond promising to enforce existing restrictions.
A few days before Maduro’s extraction, the US issued sanctions on four companies and associated oil tankers it said were tied to Venezuela, a further move to deny the Maduro regime profits from its already heavily sanctioned oil trade. The sanctions followed the Trump administration’s imposition of a blockade on all sanctioned oil tankers entering or departing Venezuela, and the seizure of sanctioned vessels amid heightened US military presence in the region. The narco-related sanctions regime has also increased in intensity: late last year, the US sanctioned entities, including the Cartel de los Soles (a group allegedly comprising Venezuela’s top brass, all accused of participating in drug trafficking), as well as high-ranking individuals within the regime accused of facilitating the cocaine trade.
Secretary of State Marco Rubio has stated that the US will enforce existing sanctions and an “oil quarantine” on the country rather than playing a day-to-day role in governing the country or seeking new concessions from Caracas, such as oil access. This strategy officially represents a continuation of existing US policy in Venezuela—using sanctions pressure to compel policy changes, albeit now with much more leverage. It also diverges from President Trump’s statements that the US is “in charge” and will “run” Venezuela post-Maduro’s ouster, and will seek goals including a more US-friendly government, and reclamation of what Trump has described as “stolen” US oil.
The US’ path to open up Venezuela’s oil sector is obstructed: the interim leader, Maduro’s vice president Delcy Rodriguez, is a regime insider who has condemned the US intervention (although she has since softened her stance, potentially in response to US pressure). Nonetheless, the Trump administration is betting on her to cut a deal in the short term, calling Rodriguez a “partner” and avoiding voicing support for opposition leader María Corina Machado, currently in exile since accepting the Nobel Peace Prize in Oslo late last year, but who has publicly floated returning to Venezuela and running for office again. Trump suggested that Machado would not have the support from key power brokers, like the military, to run the country, and signaled that the US intends to work with Rodriguez until a managed political transition can take place.
Despite Acting President Rodriguez’s reluctance, the US’ current plan appears to be applying pressure—via the threat of sanctions and military action—against the current interim government to make desired policy changes in Caracas. The plan largely focuses on opening the country’s oil sector to American investment, forming a transitional government, and shifting the country’s economy to an open market.
The recovery of the Venezuelan economy and, particularly, its hobbled oil sector will be heavily tied to the US’ plans for easing sanctions. The US has reportedly called on oil majors to “get ready,” telling them that compensation for oil assets expropriated by Venezuela will depend on rapid investment to revive the country’s oil industry. The US will also need to lift some sanctions or issue waivers/licenses in order to ease fears of regulatory risks and reputation reprisals, including those on state-owned oil company Petróleos de Venezuela, S.A. (PDVSA), with which some oil majors are considering forming public-private partnerships to expedite oil exploitation. With a path to sanctions relief far from clear, sliding oil prices in 2025, and cooperation in Caracas highly uncertain, the way forward for significant levels of foreign investment in Venezuela’s extraction infrastructure is not guaranteed. As such, analysts estimate that little Venezuelan oil will be added to the market in the next two years.
The upheaval in Venezuela—and the ensuing flight of sanctioned oil tankers from the Caribbean—could also have implications on other heavily-sanctioned oil-producing countries, like Russia and Iran. Countries involved in the trade of sanctioned oil use many of the same tankers in the global “shadow fleet.” Supply concerns have eased as many of the vessels pinned by the US blockade have fled the region, with near-term disruptions less likely. However, longer-term implications of the US oil blockade, seizure of sanctioned vessels, and heightened appetite for military intervention carry implications beyond Caracas.
US Developments
US Repeals Caesar Act
On December 18, 2025, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2026 (the “FY26 NDAA”) (S. 1071). Among other measures, the FY26 NDAA included a full repeal of the Caesar Syria Civilian Protection Act of 2019 (the “Caesar Act”), removing the threat of mandatory Caesar Act sanctions for foreign persons providing support to the Government of Syria and engaging in certain transactions involving Syrian industry, including the infrastructure and energy sectors.
Shortly after the bill was signed, the Departments of the Treasury, Commerce, and State updated their Tri-Seal Advisory, clarifying the sanctions and export controls relief provided to Syria in the aftermath of the Bashar al-Assad regime. While most sanctions, with the exception of those on members of the al-Assad regime as well as other human rights abusers, Captagon traffickers, and other destabilizing actors, have been lifted, the Department of State is still evaluating Syria’s status as a State Sponsor of Terrorism (SST).
OFAC Targets Iran’s Oil Exports and Weapons Programs
OFAC has continued to take action against Iran’s oil exports and weapons programs in line with President Trump’s National Security Presidential Memorandum-2 (NSPM-2).
- On December 18, 2025, OFAC designated 29 “shadow fleet” vessels and their respective management firms for transporting “hundreds of millions of dollars’ worth” of Iranian petroleum products. OFAC also designated Hatem Elsaid Farid Ibrahim Sakr, an Egyptian businessman whose companies are allegedly associated with seven of the 29 vessels.
- On December 30, 2025, OFAC designated ten individuals and entities for their alleged involvement in procuring weapons, or chemical precursors to weapons, in support of the Iranian regime, including its unmanned aerial vehicle (UAV) program.
OFAC Sanctions Mexican Cartel
On December 17, 2025, OFAC sanctioned the Cartel de Santa Rosa de Lima (CSRL), a cartel that OFAC says derives the majority of its illicit revenue from fuel and oil theft in Guanajuato, as well as its leader, Jose Antonio Yepez Ortiz.
In an accompanying statement, Secretary of the Treasury Scott Bessent claimed that “[n]o matter where or how the cartels are making and laundering money, we will find it and we will stop it.” The sanctions against CSRL follow similar actions taken against Mexican cartels from November 13 and October 30, 2025, and are part of President Trump’s policy calling for the “total elimination” of cartels and TCOs.
US Sanctions ICC Judges
On December 18, 2025, the State Department designated two International Criminal Court (ICC) judges, Gocha Lordkipanidze of Georgia and Erdenebalsuran Damdin of Mongolia, for engaging in efforts to investigate, arrest, detain, or prosecute Israeli nationals. The State Department pointed specifically to these judges’ votes in favor of the ICC’s ruling against Israel’s appeal on December 15, 2025, which sought to block an investigation into its actions in Gaza.
The State Department has previously sanctioned individuals and entities affiliated with the ICC on September 4, August 20, July 9, and June 5, 2025.
El Salvador Sanctions Bill Introduced in the House
On December 18, 2025, Representative Jim McGovern (D-MA) introduced H.R. 6878, which is companion legislation to the El Salvador Accountability Act of 2025 (S. 2058) in the Senate. In general, the bill would impose blocking sanctions and visa restrictions, among other restrictions, on Salvadoran President Nayib Bukele, members of his cabinet, and other foreign persons working on behalf of the Salvadoran government who have engaged in violations of human rights or engaged in a scheme to deprive US residents of their Constitutional rights. If enacted, the sanctions under the Act could not be terminated until at least four years after enactment and only after the President certifies that the government of El Salvador is no longer engaged in human rights violations or a scheme to deprive US residents of their Constitutional rights.
The sponsors of the Act, Senators Tim Kaine (D-VA), Chris Van Hollen (D-MD), and Alex Padilla (D-CA), assert that the Salvadoran government has engaged in gross human rights abuses and “collusion” with the Trump administration to imprison people from the United States without due process. Currently, neither the Senate nor House bills have bipartisan support, and it appears unlikely that either legislation will move forward.
UK Developments
Upcoming Changes to UK Sanctions Lists
On January 28, 2026, the OFSI Consolidated List of Asset Freeze Targets will close and be replaced as the only source of UK sanctions designations by the UK Sanctions List maintained by the Foreign, Commonwealth, and Development Office. OFSI has published a webinar outlining the upcoming changes, as well as a format guide for the UK Sanctions List that includes mappings to the fields on the OFSI Consolidated List. Businesses should use the period prior to the changeover date to prepare any systems for this change.
OTSI Publishes Blog Post on Best Practices for Breach Reporting
OTSI has published a blog post outlining the role of breach reporting in trade sanctions enforcement. The blog post provides guidance and best practice tips as to what should and should not be included in a breach report to OTSI.
UK Expands General Licence Relating to Travel in Russia
OFSI has amended General Licence INT/2022/1839676 to broaden the list of Russian transport providers with which UK persons may purchase rail and air tickets for journeys originating in or within Russia. Subject to certain conditions, the licence continues to provide authorisation for otherwise prohibited ticket purchases. According to the notice, JSC Siberian Airlines has been added to the permitted providers list, alongside Aeroflot, Rossiya Airlines, Ural Airlines, and Russian Railways (and its subsidiary, South Caucasus Railway). The amended licence will remain in force until May 22, 2028. Businesses and individuals relying on the licence should ensure transactions fall squarely within its scope and that appropriate records are maintained.
OFSI Issues General Licence for Myanmar Humanitarian Activity
OFSI has issued General Licence INT/2025/8257372 pertaining to humanitarian activity in Myanmar. This licence is granted under regulation 44 of The Myanmar (Sanctions) Regulations 2021 (the “Myanmar Regulations”) and under regulation 20 of The Global Human Rights (Sanctions) Regulations 2020. Subject to certain conditions, the activities of specified persons that otherwise would be prohibited under the asset freeze and making available sanctions will be authorised where those activities are necessary to provide humanitarian assistance, support basic human needs, and facilitate the timely provision of those activities in Myanmar. Any persons intending to use General Licence INT/2025/8257372 should consult the copy of the licence for full details of the definition, permissions, and usage requirements. Additionally, FAQ 176 was added to UK government guidance on financial sanctions to address the notification requirements for users of general licence INT/2025/8257372.
UK Targets Perpetrators of Violence Against Civilians in Latest Round of Syria Designations
The UK Government has designated three entities and six individuals under the Syria sanctions regime (notice). According to the UK Government press release, these designations target individuals and organisations linked to violence against civilians throughout Syria, including those involved in the coastal violence in March 2025, as well as historic violence committed during the Syrian Civil War. These designated persons are now subject to an asset freeze, and, in the case of individuals, a UK travel ban. These measures form part of the UK Government’s ongoing commitment to seek accountability for abuses against Syrian civilians, both by the former Assad regime and other actors.
UK Targets Russian Oil Industry in Latest Round of Designations
The UK Government has designated 19 entities and five individuals under the Russia sanctions regime (notice). According to a UK Government press release, these designations target Russian energy and military supply chain targets, including Russia’s largest remaining unsanctioned oil companies (i.e., PJSC Tatneft, PJSC Russneft, LCC NNK-Oil, and LLC Rusneftegaz Group), billionaire oil tycoon, Murtaza Ali Lakhani, and his companies that have become some of the largest traders of Russian oil since 2022, as well as the Central Asian supply chains of cotton pulp, a vital component in the production of ammunition, explosives and missile fuel, which has been exported to Russia at scale. These designated persons are now subject to an asset freeze, and, in the case of individuals, a UK travel ban.
Additionally, OFSI has published General Licence INT/2025/8202932 (Russian Oil Companies Wind Down General Licence). This licence is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 and, subject to certain conditions, allows for certain persons to wind down from any transactions to which they are a party involving any of PJSC Tatneft, PJSC Russneft, LCC NNK-Oil, and LLC Rusneftegaz Group, and their subsidiaries. The authorisation granted includes the closing out of any such positions, and allows banks, financial institutions, clearing houses, and others as specified in the licence to carry out any activity reasonably necessary to effect this. Any persons intending to use the licence should consult the copy of the licence for full details of the definition, permissions, and usage requirements. These measures demonstrate the UK’s continued efforts to increase pressure on strategically important sectors of the Russian economy to encourage an end to the war in Ukraine.
UK Expands General Trade Licence Relating to Russian Fertilisers
The ECJU has updated the General trade licence Russia sanctions – financial services and funds related to fertilisers to expand the scope of the activity it permits. The amended licence now includes anhydrous ammonia among the specified fertiliser goods covered by the licence. Subject to certain conditions, the licence allows the provision of financial services and the making available of funds to persons connected with Russia for the supply or delivery of specified fertiliser products from Russia to a third country, as well as the making available of those fertiliser goods to persons in third countries. The licence applies only when the fertilisers are intended for agricultural use. A full list of the specified fertiliser goods is available within the general trade licence document. Businesses relying on the licence should review the updated document carefully to confirm that the relevant goods fall within the specified list and that all conditions are met.
OFSI Amends Russian Oil Exempt Projects General Licence
OFSI has amended General Licence INT/2025/5635700 relating to Russian Oil Exempt Projects. The amendment adds the Zohr project to the list of Exempt Projects and expands the scope of permitted activity under the licence. The updated licence now allows persons to continue business operations and exercise shareholder rights in respect of an Exempt Project when the project’s share registrar is a UK-designated person. This includes making payments for administration fees connected with share registrar services and receiving dividend payments that have been processed by, or by reference to, a UK-designated share registrar. Businesses seeking to rely on the licence should review the amended terms carefully to ensure compliance with all conditions and reporting requirements.
EU Developments
European Commission Publishes Updates to its FAQs on Sanctions Against Russia and Belarus
The European Commission published a series of updates to its FAQs on sanctions against Russia and Belarus. The revised FAQs include guidance on restrictions on diamonds under Article 3p of Council Regulation (EU) 833/2014, as well as on the movements of Russian diplomats under Article 5v and 5w of the same Regulation. The Commission also updated Annex I to the FAQs, which contains the Correlation Table of goods and technology listed in Annex VII of Council Regulation (EU) 833/2014.
The Commission further published additional clarifications regarding the scope of the prohibitions for EU operators under Article 5ah of Council Regulation (EU) 833/2014, in relation to Russian special economic, innovation or preferential zones that play a key role in supporting Russia’s military industrial base.
EU Council Lists 41 Shadow Fleet Vessels Under Sanctions Against Russia
The EU Council listed 41 additional vessels belonging to Russia’s shadow fleet of oil tankers in Annex XVI of Decision 2014/512/CFSP and Annex XLII of Council Regulation (EU) 833/2014. The listed vessels, used to transport Russian oil, contribute to Russia’s energy revenues and are subject to an EU port access ban as well as a prohibition on the provision of a broad range of maritime transport services.
This update brings the total number of shadow fleet vessels listed under EU sanctions against Russia to almost 600.
EU Council Renews Sectoral Sanctions Targeting Russia
The EU Council recently renewed the sectoral sanctions targeting Russia under Decision 2014/512/CFSP for a further six months, until July 31, 2026.
Initially imposed in July 2014, the economic sanctions under Decision 2014/512/CFSP consist of a broad range of sectoral restrictions covering trade, finance, energy, transport, and dual-use goods and technology.
EU Council Adds Two Individuals to Russia Human Rights Sanctions List
The EU Council has amended Decision (CFSP) 2024/1484 to add two individuals to the sanctions list for their responsibility in serious violations of human rights, the repression of civil society and democratic opposition, and the undermining of democracy and the rule of law in Russia.
The newly listed individuals are a Moscow City Court judge who has repeatedly issued politically motivated rulings against opposition figures and human rights defenders, and a prosecutor involved in high-profile cases marked by serious human rights violations and the repression of people critical of Russian authorities or supportive of Ukraine.
The restrictive measures include a travel ban, asset freezes, and a prohibition on making funds or economic resources available to the designated individuals.
