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
The White House Leans in on Lifting Sanctions on Syria
In advance of Syrian President Ahmed al-Sharaa’s Washington visit, the White House is pressing hard for the removal of remaining US sanctions against the country. President Trump will hold his third meeting with al-Sharaa today and is expected to announce plans to remove Syria from the list of state sponsors of terrorism. Separately, the White House is urging Congress to permanently repeal the Caesar Syria Civilian Protection Act of 2019.
Syria has been designated as a state sponsor of terrorism (SST) since 1979, when the country was ruled by Hafiz al-Assad. The initial reason for the designation was Syrian support for militant Palestinian groups opposed to Israel’s existence. Over the years, the Assad regime’s support for terrorism expanded to include Hizballah, the Iranian Revolutionary Guard and various Islamist extremist groups. However, the 2024 revolution, after 14 years of civil war in Syria, brought al-Sharaa to power and initiated significant shifts in policy, including a rejection of terrorism and a desire to end the country’s political and economic isolation.
President Trump has been an early advocate for sanctions relief in order to support the new government in Damascus and its political reorientation. In May, the State Department issued a 180-day waiver of sanctions under the Caesar Act, and the Treasury Department issued a general license authorizing transactions involving the interim Syrian government, its central bank, and state-owned enterprises. These were temporary measures to give the US time to monitor Syrian performance against its pledges.
Five months later, after Syria has made the necessary progress toward or met its initial counterterrorism commitments, the White House is ready to take the next steps. The Trump administration has a choice on how to remove Syria from the SST list. First, the president could certify to Congress that Syria has not supported terrorism over the previous six months, requesting and obtaining assurances from Damascus that it will not resume support in the future. Syria would then be delisted 45 days after notification. Alternatively, President Trump could opt for immediate delisting by certifying that there has been a fundamental change in government in Damascus, that the government no longer supports terrorist groups and provides assurances that it will not in the future.
Repealing the Caesar Act, on the other hand, is not in the cards as a deliverable for the White House meeting, caught up as it is in the legislative process and slowed by the government shutdown. The White House and State Department have been urging Congress to permanently repeal the legislation through the National Defense Authorization Act (NDAA). The Senate version of the NDAA, passed on October 10, includes an amendment to repeal the Caesar Act, alongside an amendment introduced by Senator Lindsey Graham (R-SC) that imposes six binding conditions on the Syria government, including that Syria must officially join the Global Coalition to Defeat ISIS, protect the rights of religious and ethnic groups, maintain peaceful relations with Israel and remove foreign fighters from state and security institutions. The House version of the NDAA does not include language on the Caesar Act. Legislators will need to work out a compromise version in a conference committee, the most likely outcome being that the Act is repealed with a period of reporting requirements. This will mandate oversight, but would not include a snapback sanctions provision. The shutdown has extended the timeline for reconciliation and the potential lifting of sanctions, with lawmakers initially targeting a December passage prior to the shutdown.
The White House’s preferred outcome is a prompt repeal/delisting to boost investor confidence to jumpstart much-needed reconstruction in Syria and provide policy support to advance other White House efforts, such as a non-aggression pact between Israel and Syria. Nearly a year since the fall of Bashar al-Assad, a fully developed and operational economic reconstruction plan for Syria remains elusive. Repealing US sanctions would open the door for investment to flood in and support construction in critical sectors, notably infrastructure and logistics. Moreover, it offers the chance for Syrian businesses to reconnect with international markets after decades of isolation. According to media reports, the US is preparing to establish a military presence in Damascus to monitor a potential agreement. The US is also finalizing an agreement for Syria to join the anti-ISIS coalition. These initiatives require delisting of Syria as an SST and would be easier programmatically if Syria were no longer under the Caesar Act sanctions.
The US joins other international stakeholders in the desire to create a pathway for the new Damascus government’s reintegration into the international community. On November 6, the UN Security Council voted to remove President al-Sharaa and Interior Minister Anas Khattab from UN sanctions measures targeting members and supporters of terrorist groups ISIL and al-Qa’ida, on the basis of no active ties between Hayat Tahrir al-Sham (HTS) and al-Qa’ida. Sharaa is the former leader of HTS. China abstained from the vote, citing doubts that the Syrian government will continue to take positive steps on counterterrorism. Beijing is concerned about the future of ethnic Uyghur foreign fighters who fought with HTS and who remain in Syria. How those fighters will be treated in the new Syria remains an open question—some may be demobilized, but others are likely to be integrated into the new Syrian army. Beijing, conversely, wants them to be deported to China. Following the UN vote, the US and UK lifted sanctions on al-Sharaa and Khattab. An EU spokesperson said on Friday the UN decision would be reflected in EU measures.
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.
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.
