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
EU Sanctions Pro-Russian Actors for Destabilizing Moldova
Last week, the European Council imposed sanctions on seven politicians and three entities for their roles in activities undermining Moldova’s democratic stability ahead of its pivotal parliamentary elections this September. Russian-backed destabilization efforts loom large ahead of the polls, which will decide whether the country continues its integration with the EU or edges closer to renewing ties with Moscow.
Moldova: Between Russia and the EU
Although Moldova aspires to align with the West (the country applied for EU candidacy in 2022 and aims to join the bloc by 2030), Moscow has worked to undermine these efforts. Russian influence in the breakaway region of Transnistria and the autonomous region of Gagauzia, where Russian is widely spoken, is significant. Transnistria hosts 1,500 Russian troops, offering Moscow leverage to pressure both Moldova and the EU, and raising concerns about a potential new front against Ukraine since the war began. Both regions have signaled allegiance to Moscow through referendums, such as Gagauzia’s 2014 vote to integrate into the Eurasian Economic Union. While Chisinau declared the referendum illegitimate, Moscow endorsed it.
Pro-Russian politicians, like Ilan Shor (sometimes called the “Hand of Moscow”), have sought to stoke nostalgia for Soviet times and oppose EU integration, portraying it as harmful to Moldova’s interests. Shor has proved himself instrumental to Moscow, particularly through installing pro-Russian politicians, including supporting the election of Gagauzia’s governor, Evghenia Gutul, through vote-buying. Shor led the Șor Party, a pro-Russian political party that was outlawed by Moldova’s Constitutional Court in 2023.
Leading up to the 2024 presidential election and the nationwide referendum on EU accession, Russia launched a disinformation campaign to destabilize Moldova and weaken pro-European sentiment. Tactics included deepfake videos of President Maia Sandu, hacking sensitive information, and orchestrating fake bomb threats to incite fear. In the months before the election, Shor (who now resides in Russia) was accused of funneling $39 million to sway voters against Sandu and an EU membership referendum. Despite these efforts, Sandu won re-election with 55% of the votes and narrowly secured 50.38% of the votes in favor of EU accession. But Russia’s meddling continues to skew public perception of Moscow’s influence, inflating its perceived importance relative to its actual economic ties.
Targeted Sanctions and Russia’s Influence Network
The EU’s newly imposed sanctions targeted seven politicians linked to Ilan Shor, along with three entities involved in Russian meddling in Moldova. Four of the sanctioned individuals—Alexandru Beșchieru, Vadim Grozavu, Alexei Lungu, and Natalia Parasca—lead political parties that succeeded the now-outlawed Șor Party. These groups were united by Shor under the Victory/Pobeda Political Bloc, which was also sanctioned for its role in disseminating disinformation and orchestrating election fraud. Another sanctioned politician, Victoria Furtună, received substantial backing from Shor during the 2024 presidential election, during which Shor’s network allegedly coerced voters into supporting her. Irina Lozovan of the Renaștere party was sanctioned for allegedly bribing voters during the 2024 election and the referendum for Moldova’s EU accession. Meanwhile, Alexandr Nesterovschi reportedly orchestrated schemes to create a fake pro-European movement controlled by Shor to manipulate political discourse.
The sanctions also targeted the cryptocurrency company A7, which facilitated cross-border payments to help Russia evade Western sanctions. Pegged to the Russian ruble and backed by deposits at Promsvyazbank—a Russian institution sanctioned for links to Moscow’s defense sector—the A7A5 cryptocurrency has raised $9.3 billion since February 2025. The third sanctioned entity, the Cultural Educational Centre of Moldova, played a key role in electoral interference and propaganda. Its tactics included providing free vouchers to voters, organizing transportation to polling stations in Moscow, and promoting Russia’s “Card of the Citizen of the Republic of Moldova in the Russian Federation” program. These efforts aimed to boost pro-Russian sentiment among Moldovans and served as vital propaganda tools for Shor’s Victory/Pobeda Bloc.
Last week’s sanctions are part of the EU’s efforts to enhance Moldova’s resiliency and stability in the face of Russian interference. Such effort began at the behest of the Moldovan government in April 2023, which has adamantly tried to uproot persons responsible for undermining the country’s sovereignty. This latest round of sanctions now totals 23 individuals and 5 entities being held responsible for destabilizing Moldova.
September Elections and Future Russian Destabilization Efforts
With Moldova’s parliamentary elections approaching in September, the stakes are high. These elections will determine whether Moldova continues its path toward EU accession. As the country faces mounting economic and social challenges, EU policy—including sanctions aimed at countering Russian influence—will play a critical role in shaping the outcomes. Emerging coalitions seeking to challenge Sandu’s position, coupled with recent reductions in US foreign aid to Moldova, have created fertile ground for heightened Russian interference in the upcoming elections. Meanwhile, widening economic inequality and deepening social tensions further destabilize Moldova’s political landscape, leaving the country vulnerable to exploitation by external actors. EU sanctions are an effort to quash these threats and disrupt Russian influence in Moldova’s political and economic systems.
Russia’s overt actions in the lead-up to Moldova’s 2024 presidential election and referendum strongly suggest that Moscow may escalate its destabilization efforts ahead of the September elections. While Sandu and PAS continue to push forward with their EU integration strategy, concerns remain that ongoing economic and social instability may leave voters more susceptible to bribery and manipulation, potentially allowing pro-Russian politicians to gain influence. The EU’s sanctions imposed last week disrupted significant footholds Russia previously maintained in Moldova, potentially hampering Moscow’s capacity for future interference. However, long-standing divisions in Transnistria and Gagauzia present additional vulnerabilities that remain opportunities for external manipulation.
US Developments
Trump Threatens Secondary Tariffs on Russia While Thune Pauses Sanctions Package
During a meeting with Mark Rutte, the Secretary General of the North Atlantic Treaty Organization (NATO), President Trump announced that he will be imposing “secondary” tariffs on Russia at or around 100 percent if he cannot reach a deal with the Kremlin regarding its war effort in Ukraine within 50 days. Trump also announced that the US will be selling weapons and other military equipment to European allies, who will then transfer those weapons and military equipment to Ukraine.
Trump did not specify which sectors or products would be subject to secondary tariffs, or if certain exceptions or licenses would be available. The announcement, coupled with the arms deal, signals a significant shift in the Trump administration’s approach toward Russia and its war in Ukraine. The administration has previously been hesitant to expand sanctions on Russia on the basis that new sanctions would jeopardize ongoing negotiations. However, with frustrations mounting, Trump’s apparent stance toward Russia, especially in recent weeks, has shifted.
Notably, Senate Majority Leader John Thune (R-SD) stated that he would pause ongoing efforts in Congress to bring the Sanctioning Russia Act of 2025 (S. 1241/H.R. 2548) to a vote. As we previously reported, the legislation, which would impose a variety of tariffs and secondary sanctions on supporters of the Russian economy or war effort, was gaining momentum in both chambers of Congress in recent weeks. There is substantial speculation that Trump would support the bill if it were amended to grant him more discretion to calibrate the sanctions. Now, it appears that the soonest the legislation will reach the floor will be after the 50-day window for negotiations expires.
“Snapback” Sanctions on Iran Loom as Tehran Refuses to Negotiate
Secretary of State Marco Rubio and the foreign ministers of France, Germany, and the United Kingdom reportedly agreed in a phone call to set the end of August as a deadline for reaching a nuclear deal with Iran. After that point, if no deal is reached, the three European countries will initiate a “snapback” mechanism to reimpose the United Nations Security Council sanctions that were originally suspended as a result of the Obama-era Joint Comprehensive Plan of Action, commonly known as the Iran Nuclear Deal.
In a related development, a group of Republican US Senators sent a letter to officials from France, Germany, and the United Kingdom, urging them to initiate the “snapback” mechanism. In their letter, the Senators said the decision to initiate the process “is only the beginning,” and that, once sanctions are back in place, those imposing them “must commit to their enforcement,” including by cracking down on alleged Chinese purchasers and private smugglers of Iranian oil and related products.
For its part, Iran has stated that it will respond to any reimposition of UN sanctions over its nuclear program. According to Reuters, Foreign Ministry spokesperson Esmaeil Baghaei told reporters that the response will be “appropriate and proportionate” but did not specify what that may entail. Over the weekend, state-affiliated Iranian media reported that Tehran would discuss its nuclear program with E3 “next week,” following statements from the Iranian parliament that it will not resume negotiations with the US over its nuclear program until certain conditions are met. Iranian officials have not publicly announced these conditions, but Iranian Foreign Minister Abbas Araqchi previously suggested that they may include guarantees against further strikes against Tehran.
Treasury Sanctions Tren de Aragua Leaders
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned Hector Rusthenford Guerrero Flores (“Niño Guerrero”)—the alleged head of Tren de Aragua (TdA), a Foreign Terrorist Organization, Transnational Criminal Organization, and Specially Designated Global Terrorist—as well as five other alleged TdA leaders and affiliates.
Concurrently, the Department of State’s Bureau of International Narcotics and Law Enforcement Affairs announced through its Transnational Organized Crime Rewards Program that it is offering a reward of up to $5 million for information leading to the arrest or conviction of Niño Guerrero. INL also announced that it is offering a reward of up to $4 million for information leading to the arrest or conviction of Yohan Jose Romero, allegedly one of the co-founders of TdA, who was sanctioned alongside Niño Guerrero.
OFAC’s designations follow a related action from June 24, 2025, wherein Giovanni Vincente Mosquera Serrano, a TdA leader allegedly involved in the organization’s drug trafficking and financial operations, was also sanctioned.
Brokerage Firm Settles with OFAC
Interactive Brokers LLC (“IB”), a Connecticut-based brokerage firm, has agreed to pay OFAC $11,832,136 to settle its potential civil liability for 12,367 apparent violations of multiple OFAC sanctions programs. According to the Enforcement Release, from on or around July 15, 2016, to on or around January 31, 2024, IB provided brokerage and investment services to persons in Iran, Cuba, Syria, and the Crimea region of Ukraine. During the same time period, IB also processed trades in securities subject to the Chinese Military-Industrial Complex program, conducted transactions involving blocked persons under OFAC’s Russia, Global Magnitsky, Venezuela, and Syria, and engaged in new investments in the Russian Federation.
The penalty amount reflects OFAC’s determination that the apparent violations were non-egregious and voluntarily self-disclosed. It also reflects the remedial measures IB implemented upon discovery of the apparent violations and IB’s cooperation with OFAC’s multi-year investigation. Notably, this settlement agreement is the fourth such agreement that OFAC has announced since the beginning of June, following those entered into with Harman International Industries, Inc, Key Holding, LLC, and Unicat Catalyst Technologies.
UK Developments
UK Lowers Oil Price Cap on Seaborne Russian Crude Oil
The UK Government, working in collaboration with the EU, has announced its intention to reduce the oil price cap on seaborne Russian crude oil from $60 to $47.60 per barrel. The change is intended to reduce Russia’s income from the sale of crude oil and ability to fund its war in Ukraine. The new, lower crude oil price cap will come into effect at 23:01 (BST) on September 2, 2025. In addition to impacting the maritime transportation of Russian crude oil, the reduced price cap will also apply to the provision of services (e.g., financial and brokering services) caught under the price cap regime. For any Russian crude oil trades with an effective date of contract the lower oil price cap comes into effect, and which are compliant with the existing price cap of $60 per barrel, there will be a wind-down period of 45 days to give businesses time to adjust and ensure consistent implementation of the new oil price cap by all operators. After expiry of that wind-down period at 23:01 (BST) on October 17, 2025, the lower price cap of $47.60 per barrel takes effect.
UK Imposes New Sanctions Under the Cyber and Russia Sanctions Regimes
The UK Government has taken action against Russian spies and hackers targeting the UK and others by designating 18 individuals and one entity under the Cyber Sanctions Regime and designating three individuals and one entity under the Russia Sanctions Regime. These measures target three units of the Russian military intelligence agency (GRU) and 18 military intelligence officers who are responsible for conducting a sustained campaign of malicious cyber activity over many years, including their involvement in the bombing of the Mariupol Theatre, the targeting of Yulia Skripal, and cyber operations in support of Putin’s illegal war in Ukraine. All individuals and entities are now subject to asset freezes and trust services restrictions. In announcing these actions, the UK Government is taking steps to implement the commitment to countering hybrid threats at home and protect the UK’s national security outlined by Foreign Secretary Lammy in his recent Mansion House speech.
OFSI Issues New Brokerage Accounts General Licence
OFSI has issued a new General Licence, INT/2025/6641960, under both the Russia and the Belarus Regulations, which allows non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker (the “GL”). The GL only applies where the only designated party involved is the designated broker. Any persons intending to use the GL should consult the copy of the licence for full details of the definition, permissions, and usage requirements. The GL took effect on July 18, 2025, and will expire on July 16, 2026.
EU Developments
EU Adopts 18th Sanctions Package Against Russia
On Friday, July 18, the European Union adopted its 18th sanctions package against Russia, targeting its banking, energy, and military-industrial sectors. Following weeks of negotiations and resistance from several EU member states, the package was finalized after Slovakia’s decision to lift its veto on Thursday. Reports indicate Slovakia’s approval came after securing guarantees from the European Commission to mitigate the potential impact of the EU’s plan to phase out Russian gas and oil imports by the end of 2027.
The new sanctions package introduces a set of restrictive measures across Russia’s key economic sectors. For the first time, the EU lowered the oil price cap from $60 to $47.60 per barrel and introduced an automatic adjustment mechanism to maintain effectiveness. Additional measures target Russia’s shadow fleet involved in circumventing sanctions, banning 105 additional vessels from port access and sanctioning operators managing these tankers. Restrictions also include a ban on imports of refined petroleum products derived from Russian crude oil (excluding the US, UK, Canada, and Switzerland) and a complete transaction ban on Nord Stream 1 and 2 pipelines to prevent future maintenance or operation. Exemptions allowing the Czech Republic to import oil were also revoked.
Financial sanctions were further strengthened by imposing transaction bans on 22 additional Russian banks. The new package reduces the threshold for sanctioning third-country financial and credit institutions, and crypto-asset service providers aiding Russia’s war efforts or undermining EU sanctions, including entities linked to Russia’s alternative financial messaging system (SPFS). Transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and associated companies are fully prohibited, with mechanisms to extend bans to RDIF-backed entities. Other restrictive measures were introduced to block the sale, supply, and export of software systems used in banking.
The 18th sanctions package also targets suppliers to Russia’s military industrial complex and limits access to critical technologies and resources. Entities aiding Russia’s defense sector, including three Chinese companies selling battlefield use goods and eight Belarusian firms, face full-fledged sanctions. Export controls were expanded for 26 entities involved in dual-use goods and technologies crucial to Russia’s defense, including 11 third-country entities in China, Hong Kong, and Türkiye that previously bypassed bans. These include suppliers of unmanned aerial vehicles (UAVs). Lastly, the EU has introduced export bans on key items like computer numerical control (CNC) machines and chemicals used in military propellants. Expanding the existing transit ban through Russian territory, movement of goods critical to construction and transport was further restricted to disrupt supply chains supporting Russia’s war efforts.
EU Council Revises Sanctions Regimes Targeting Moldova, Iran, and Haiti
The EU Council has updated several pieces of sanctions legislation, further tightening restrictive measures against entities and individuals in various countries.
In relation to the Republic of Moldova, Council Decision 2023/891 and Regulation (EU) 2023/888 were amended by adding seven individuals and three entities to the sanctions listings, subjecting them to travel bans, asset freezes, and prohibitions on financial transactions. These measures target activities aimed at destabilizing Moldova, including actions that undermine its democratic institutions, sovereignty, and security.
In addition, the EU Global Human Rights Sanctions Regime was amended to add the entries of eight persons and one entity to Annex I to Regulation (EU) 2020/1998 for their involvement in serious human rights violations and transnational repression linked to Iranian state bodies. Those added to the sanctions list are now subject to asset freezes, travel bans, and prohibitions on the provision of funds or economic resources.
Lastly, the EU Council has taken further steps to address the ongoing crisis in Haiti by amending Council Decision 2022/2319 and Regulation (EU) 2022/2309, which established restrictive measures in light of the situation in the country and aligned with the UNSC resolution 2653 (2022). Specifically, the EU Council extended the EU framework for restrictive measures until July 29, 2026, targeting individuals and entities responsible for actions that threaten Haiti’s peace, stability, and security. Furthermore, three individuals involved in gang-related violence and criminal activities in Haiti were added to Annex II of Council Decision 2022/2319 and Annex Ia of Regulation (EU) 2022/2309, making them subject to travel restrictions, a targeted arms embargo, asset freezes, and a prohibition of funds or economic resources.
EU Council Adopts 4th Sanctions Package Against Human Rights Violations and Security Threats in Sudan
The EU Council has adopted its fourth sanctions package aimed at addressing serious human rights violations and threats to peace, stability, and security in Sudan. The restrictive measures target entities and individuals linked to the ongoing conflict between the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF). Two entities, Alkhaleej Bank and Red Rock Mining Company, have been added to the sanctions list for their roles in financing the conflict. Additionally, two individuals, SAF Commander Abu Aqla Mohamed Kaikal and RSF Field Commander Hussein Barsham, have been added to the list of sanctioned individuals and entities for their involvement in ethnic violence, forced displacement, and targeted attacks on civilians in Darfur and other conflict-affected areas of Sudan.
With this sanctions package, the total number of sanctioned individuals increases to ten, while the number of sanctioned entities rises to eight. Those listed are subject to restrictive measures, including asset freezes, travel bans, and a prohibition on providing funds or economic resources.
EU Council Updates Sanctions Listings Targeting Russia Over Human Rights Violations and Hybrid Threats
On July 15, the EU Council announced new listings regarding two EU sanctions frameworks against Russia. First, the framework for restrictive measures against those responsible for serious human rights violations in Russia (Council Decision 2024/1484 and Regulation (EU) 2024/1485) was amended to include five individuals involved in human rights abuses and the repression of civil society and democratic opposition. These individuals, including members of the judiciary, were sanctioned for their roles in the politically motivated persecution of activist Alexei Gorinov, who was prosecuted for opposing Russia’s war in Ukraine. The sanctions entail asset freezes, travel bans, and a prohibition for EU entities and citizens from providing financial resources to the designated individuals.
Second, the framework for restrictive measures in response to Russia’s destabilizing actions (Council Decision 2024/2643 and Regulation (EU) 2024/2642) was amended to include nine individuals and six entities involved in hybrid threats such as disinformation, electronic warfare, and interference in occupied Ukrainian territories. These targets include the Russian Television and Radio Broadcasting Network (RTRS), key figures in electronic warfare linked to GNSS signal disruptions in Europe, and organizations such as the BRICS Journalists Association and the Foundation to Battle Injustice, which have been implicated in disinformation campaigns.
Asia-Pacific Developments
China’s Criticism of US Sanctions on Cuba
On July 15, 2025, China’s Ministry of Foreign Affairs (MOFA) strongly criticized the recent US sanctions on Cuban President Miguel Díaz-Canel, Defense Minister Álvaro López Miera, and Interior Minister Lázaro Álvarez Casas over alleged human rights violations. According to MOFA, the US is using human rights as a pretext to impose unilateral sanctions and interfere in Cuba’s internal affairs. MOFA argued that the decades-long US blockade and sanctions have “devastated the lives of the Cuban people” and should be “lifted at once, not redoubled.” Additionally, MOFA called on the US to remove Cuba from its “state sponsors of terrorism” list and focus on addressing its own human rights violations, including those at Guantanamo Bay.
China and India Push Back Against NATO’s Sanctions Warnings
China and India have firmly pushed back against NATO Secretary General Mark Rutte’s warnings of severe secondary sanctions if they continue trading with Russia. On July 16, 2025, MOFA reiterated China’s stance against “unilateral sanctions” and “long-arm jurisdiction,” advocating dialogue and negotiation as the only viable solution to the Ukraine crisis. A day later, India’s Ministry of External Affairs (MOEA) criticized the West for what it described as “double standards.” India stressed its strategic autonomy, stating it would make energy decisions based on market realities, and emphasized that “securing energy needs of our people is understandably an overriding priority for us.” India also expressed openness to reviving trilateral talks with China and Russia to address broader global issues.
These responses followed Rutte’s reported call for China, India, and Brazil to pressure Russian President Vladimir Putin into peace talks, warning of “massive” repercussions if they did not act.
