Overview
The Sanctions Update, compiled by attorneys from Steptoe’s award-winning International Trade and Regulatory Compliance team and the Stepwise: Risk Outlook editorial team, publishes every Monday. Guided by the expertise of Steptoe’s industry-leading IRC 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.
For more detailed analysis on related issues, see Steptoe’s International Compliance Blog. For information on industry-specific monitoring or bespoke services, please contact the team here.
Lede
US Sets Sights on Scams with “Scam Center Strike Force”
Last week, the US Attorney for the District of Columbia, the Department of Justice, the FBI, and the US Secret Service announced a new intragovernmental task force focused on investigating and punishing scams and fraud targeting Americans from Southeast Asian scam compounds run by Chinese transnational crime organizations (TCOs). The four agencies involved in the announcement, in partnership with the State Department, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the Department of Commerce, will use sanctions, seizures and criminal prosecutions to disrupt the scams, as well as providing education and some form of restitution to the victims. The announcement coincided with a fresh raft of sanctions against Chinese TCO-linked armed groups and companies in Myanmar and Thailand that have developed and operated scam centers.
Online investment scams have exploded in recent years. In October, the Treasury Department estimated that Americans had cumulatively lost over $16.6 billion to Southeast Asia-based scam operations, with $10 billion of those losses occurring just in 2024. Blockchain intelligence platform TRM Labs has tracked over $53 billion in global scam losses since 2023 – a number that is almost certainly a significant undercount, as research suggests that only 15 to 20% of victims ever report their losses due to stigma. The typical method is called “pig butchering,” in which scammers slowly build trust with victims to convince them to invest increasingly large sums of money in fake cryptocurrency platforms, even showing fabricated profits, and eventually vanishing with the funds. Fraudsters also use romance scams, building a relationship to persuade victims into sending money over a period of weeks or months, or request money or bank access by posing as employers, government representatives, or employers.
The proliferation of these scams has been enabled by the explosion of scam centers, large-scale, professionalized operations that rely on forced labor and ultimately enrich organized crime or armed groups. Many Southeast Asian scam centers are concentrated in areas of weak governance, such as Cambodia, Laos, and Myanmar, located close to Thailand’s borders to take advantage of the country’s reliable electricity and telecommunications networks. Many utilize special economic zones (SEZs) created to attract investment to capitalize on reduced regulatory oversight and cheaper startup costs. The centers are staffed by trafficked individuals from throughout the region and the world, usually lured to the compounds by the promise of legal employment. The profits from these centers flow to organized crime syndicates, many of which with Chinese leadership.
The US’ new Scam Center Strike Force comes as governments around the globe are taking heightened steps to disrupt these networks. In September, the US and UK jointly took their largest-ever action targeting Southeast Asian cybercriminal networks with 146 sanctions on the Prince Group network, a Cambodia-based network operating online investment scams. In late October, Myanmar’s military captured and shut down the notorious KK Park scam center as it recaptured territory along its Thai border as part of an ongoing civil war, freeing upwards of 2,000 detained laborers. China has increasingly leveraged its diplomatic clout with Myanmar’s military junta to encourage rooting out these centers, especially as coverage of the trafficking of Chinese citizens to work in scam centers has increased. Beijing reported last month that Chinese and Myanmar officials have arrested 57,000 Chinese nationals suspected of operating these scam operations.
Effectively disrupting scam centers is an uphill battle. Rooting out individual centers is a game of whack-a-mole, and oversight regimes in Southeast Asian SEZs are currently ill-suited to prevent new centers from quickly popping up to replace ones that are shut down. Profits, typically laundered through luxury properties and encrypted Bitcoin wallets, are hard to track. Organized crime groups typically find footholds, for financial bases or trafficking recruitment, in areas of Africa and Southeast Asia where weak governance makes tracking difficult and diplomatic pressure on host governments ineffective. The US’ new interagency Scam Center Strike Force is a step towards a new, more interconnected method of fighting scams, and could be followed with international cooperation hubs – like a Chinese and Thai joint venture floated by Beijing in February.
US Developments
OFAC Sanctions Iranian Procurement Network
On November 12, OFAC designated 32 individuals and entities based in Iran, the United Arab Emirates (UAE), Türkiye, China, Hong Kong, India, Germany, and Ukraine for their alleged roles in operating procurement networks that support Iran’s ballistic missile and unmanned aerial vehicle (UAV) programs, including on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), a Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT).
This is Treasury’s second round of nonproliferation sanctions targeting Iran following the reimposition of United Nations Security Council’s (UNSC) sanctions that were originally suspended as part of the Joint Comprehensive Plan of Action (JCPOA) in 2015. Treasury issued its first round of sanctions measures on October 1. Those sanctions targeted 21 entities and 17 individuals across multiple jurisdictions who allegedly facilitated the acquisition of sensitive goods and technology for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), a SDGT and key component of Iran’s defense apparatus.
OFAC Partners with Government of Mexico to Target TCO
On November 13, OFAC and FinCEN partnered with the Government of Mexico to target the Hysa Organized Crime Group (HOCG) and multiple other Mexico-based gambling establishments allegedly involved in cartel-related activity, such as money laundering.
In particular:
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OFAC sanctioned 27 individuals and entities for their alleged support of the HOCG, which OFAC says uses its influence through its investments in, or control over, various Mexico-based businesses to launder proceeds of narcotics trafficking.
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FinCEN issued a Notice of Proposed Rulemaking (NPRM) identifying transactions involving ten Mexico-based gambling establishments as a class of transactions to be of primary money laundering concern, with the intent of severing these establishments’ access to the US financial system.
The Treasury Department announced that these joint efforts between the US and Mexico were the result of commitments secured by Treasury Under Secretary for Terrorism and Financial Intelligence John Hurley during his recent trip to Mexico. The US continues to target Mexico-based, cartel-related activity, in line with President Trump’s Executive Order (EO) calling for the “total elimination” of cartels and other transnational criminal organizations’ (TCO) presence in the US and their ability to threaten the United States.
Trump Eases Sanctions on Syria Following Meeting with al-Sharaa
On November 10, following a highly anticipated meeting between President Trump and Syrian President Ahmed al-Sharaa, the Department of State issued a suspension of mandatory sanctions imposed pursuant to the Caesar Syria Civilian Protection Act of 2019 (the “Caesar Act”). The Department of State’s decision follows OFAC’s removal of the SDGT designations of al-Sharaa and Syrian Interior Minister Anas Khattab on November 7, and the UNSC’s vote to remove sanctions on the same two individuals on November 6. It also comes as the Wall Street Journal (WSJ) reports that the Trump administration may push Congress for a full repeal of the Caesar Act, the language for which is already present in the Senate’s version of the National Defense Authorization Act (NDAA) (S. 2296), but not in the House’s version.
At the same time as the suspension of mandatory sanctions under the Caesar Act, the Department of State, alongside the Departments of the Treasury and Commerce, issued a Tri-Seal Advisory outlining the sanctions and export controls relief provided by the US to Syria as a result of the toppling of the Bashar al-Assad regime to date, as well as the permissible and non-permissible activities for public and private actors with respect to Syria as a result.
OFAC Issues New General Licenses Related to Rosneft and Lukoil Sanctions
On November 14, OFAC issued or amended four Russia-related general licenses (GLs):
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“Authorizing Petroleum Services and Other Transactions Related to the Caspian Pipeline Consortium, Tengizchevroil, and Karachaganak Projects (GL 124B);
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“Authorizing Certain Transactions Involving Lukoil Retail Service Stations Located Outside of Russia” (GL 128A);
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“Authorizing Transactions Involving Certain Lukoil Entities in Bulgaria” (GL 130);
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“Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities” (GL 131).
These GLs provide relief for certain categories of transactions following the designation of Russia’s two largest oil companies, Open Joint Stock Company Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil), along with dozens of their subsidiaries and affiliates, on October 22. They build on a number of other GLs issued by OFAC on October 22 and October 29.
UK Developments
UK Updates Iran Nuclear Sanctions Guidance
The UK Government has published an updated version of the Iran Nuclear Sanctions statutory guidance. The changes to the guidance reflect the Iran (Sanctions) (Nuclear) (EU Exit) (Amendment) Regulations 2025, which implement the reintroduction of UN sanctions on Iran’s nuclear regime in the UK following the E3’s triggering of the “snapback procedure” on August 28, 2025. The revised guidance clarifies how the reinstated UN measures interact with the UK’s autonomous Iran sanctions regime, including expanded designation bases and renewed restrictions on nuclear-related goods, technology and financial services. For UK businesses operating in sectors such as energy, finance, shipping and dual-use goods, the update signals a materially tighter compliance environment and a need to reassess risk exposure, screening settings and the continued suitability of existing licences.
UK Releases Q2 Statistics for Strategic Export Control Licensing
The UK’s Export Control Joint Unit (ECJU) has published its quarterly report on export control licensing statistics for April to June 2025. The report highlights that 2,612 Standard Individual Export Licences (“SIELs”) were issued in Q2, below the long-term quarterly average of 3,089. In addition, the report details processing performance across the outgoing SPIRE system and the new LITE platform, with 53% of applications decided within 20 working days in SPIRE (69% within 60 days), and 50% decided within 20 days in LITE (92% within 60 days). The value of SIELs issued fell to £2.7 billion in Q2 from £4.8 billion in Q1, bringing the total for 2025 to £7.5 billion across 5,335 licences, with an approval rate of 96%. Businesses should note these figures as indicators of current licensing timelines and operational pressures within ECJU when planning export-controlled transactions.
London Art Gallery Charged with Luxury Goods Export Offence Under UK Russia Sanctions
The UK’s HMRC has charged international gallery, Hauser & Wirth, alongside London art shipper, Artay Rauchwerger Solomons, with breaching UK Russia sanctions for allegedly making an artwork available to a Russian businessman, Alexander Popov. The alleged offence took place between April and December 2022, after the UK introduced its ban on exporting luxury goods to persons connected with Russia. The case concerns a George Condo artwork, which was valued above the £250 threshold captured by the Russia (Sanctions) (EU Exit) Regulations 2019. Alexander Popov is not a UK designated person and there is no suggestion of wrongdoing by him. A plea and trial preparation hearing is scheduled for December 16, 2025. This is the first criminal action under the UK’s Russia luxury goods export restrictions, signalling increased scrutiny of high-value art transactions.
OFSI Issues New General Licence Authorizing Continuation of Business with Certain Lukoil Bulgaria Entities
OFSI has issued General Licence INT/2025/7895596 (Continuation of Business of Lukoil Bulgaria Entities), which allows for the continuation of business operations with certain Lukoil Bulgaria Entities (the “GL”). The GL has been issued under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019. Subject to certain conditions, the GL allows a person to continue business operations involving certain specified Lukoil Bulgaria entities (i.e., Lukoil Bulgaria EOOD and Lukoil Neftochim Burgas AD) and their subsidiaries including, but not limited to: (i) payments to or from the Lukoil Bulgaria entities under any existing or new obligations or contracts, (ii) payments to or from any other person under any obligations or contracts; and (iii) provision of, and receipt of, economic resources from the Lukoil Bulgaria entities. Any persons intending to use the GL should consult the copy of the licence for full details of the definition, permissions, and usage requirements. In addition, OFSI has added new FAQ 173 to its FAQs guidance to address whether business operations with Lukoil Bulgaria EOOD and Lukoil Neftochim Burgas AD can continue to operate as normal with respect to UK financial sanctions.
UK Announces Intention to Impose a Maritime Services Ban on Russian LNG
The UK Foreign Secretary, Yvette Cooper, announced the UK’s intention to introduce a maritime services ban on Russian LNG during a G7 foreign ministers meeting in Canada on November 11, 2025. The UK banned the import of Russian Liquefied Natural Gas (LNG) in January 2023 and now intends to go further by banning the maritime transport of Russian LNG and provision of related services such as insurance for Russian LNG exports to third countries. While the precise scope of the new measures remains to be confirmed because the legislation required to implement the ban has not yet been published, it is understood that the ban will be phased in during 2026 as part of coordinated action with the European Union. Businesses involved in the shipping and insurance sectors with exposure to Russian LNG should monitor developments closely and take appropriate steps to ensure compliance with the ban prior to its coming into effect next year.
EU Developments
EU Publishes Update to Dual-Use Export Control List
On November 14, the European Union published an update to the Regulation establishing the common list of dual-use items subject to export controls in the Official Journal. The revision reflects changes adopted in 2024 by the international non-proliferation regimes and export control arrangements, including the Australia Group, the Missile Technology Control Regime (MTCR), the Nuclear Suppliers Group (NSG), the Wassenaar Arrangement, and the Chemical Weapons Convention (CWC).
The updated Annex I to Regulation 2021/821 introduces controls on emerging technologies such as AI processors, quantum-safe cryptography, CMOS integrated circuits, cryogenic cooling systems and components, and semiconductor manufacturing deposition equipment. Many of these items were previously subject to national-level controls and are now formally integrated into the EU dual-use export control list. The Regulation entered into force on November 15.
Asia Pacific Developments
China Halts Sanctions on Hanwha Ocean Units Following US Trade Measure Suspension
On November 10, 2025, China’s Ministry of Commerce (MOFCOM) announced it will suspend for one year the countermeasures imposed under China’s Anti-Foreign Sanctions Law on five US-related subsidiaries of South Korea’s Hanwha Ocean Co., Ltd. The suspension, effective immediately, temporarily halts the sanctions set out in Ministry of Commerce Order No. 6 of 2025. The decision follows the US announcement on November 9, 2025, that it will pause for one year its Section 301 investigation measures targeting China’s maritime, logistics, and shipbuilding sectors. MOFCOM said the suspension “reflects both sides’ efforts to implement the consensus reached during recent China‑US trade talks in Kuala Lumpur.” China reaffirmed “its willingness to continue dialogue with Washington” to promote “fair competition in global shipping and shipbuilding,” while enhancing “certainty and stability” in bilateral trade.
Russia Imposes Indefinite Entry Bans on 30 Japanese Nationals in Retaliation for Tokyo’s Sanctions
On November 11, 2025, in retaliation for Tokyo’s sanctions over the war in Ukraine, Russia reportedly announced indefinite entry bans on 30 Japanese nationals, including Foreign Ministry press official Toshihiro Kitamura. In September, Japan imposed sanctions on Russian companies, individuals, and other entities, and lowered its price cap on Russian seaborne crude in line with measures taken by Western countries. Moscow said the travel restrictions were a direct response. Chief Cabinet Secretary Minoru Kihara called the move “regrettable,” accused Moscow of shifting blame for its invasion, but stressed the importance of maintaining people‑to‑people exchanges.
Australia Eases Certain Sanctions on Syria’s Energy and Banking Sectors
On November 14, 2025, the Australian Minister for Foreign Affairs announced “amendments to the Syria sanctions framework,” suspending sanctioned commercial activity related to Syria’s petrochemical and oil and gas industries, the Syrian government, Syrian-based individuals and entities, and Syrian financial institutions. The changes remove equipment, materials, software, and technology linked to crude oil, natural gas, petrochemicals, and power plant construction from the list of export sanctioned goods, and repeal the import ban on crude oil, petroleum, and petrochemical products. Additionally, two financial institutions — the Commercial Bank of Syria and the Syrian Lebanese Commercial Bank — have been de‑listed from targeted financial sanctions and removed from Australia’s Consolidated List. These measures mark a significant easing of restrictions on Syria’s energy and banking sectors.
