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 Deputy Commander of the Sudanese Rapid Support Forces
On Thursday, the EU imposed sanctions on Abdelrahim Hamdan Dagalo, the deputy commander of Sudan’s paramilitary Rapid Support Forces (RSF), in response to the militia’s ongoing violence in El Fasher amid the RSF’s ongoing civil war with the Sudanese Armed Forces (SAF). Abdelrahim Dagalo, brother of RSF leader Mohamed Hamdan Dagalo (known as Hemedti), is accused of serious human rights abuses. As stability in Sudan continues to deteriorate, global leaders have increased attention on the country and indicated their commitment to addressing the crisis, including by imposing further restrictive measures aimed at securing a permanent ceasefire and transitioning Sudan to civilian rule.
Abdelrahim Hamdan Dagalo has also been sanctioned by the US (since September 2023) and Canada (since April 2024). The EU’s listing accuses him of playing a central role in the RSF’s campaign in Darfur by personally overseeing military operations in the region since October 2023. The EU further asserts that during the RSF’s takeover of El Fasher last month, Dagalo directed actions against civilians, including killings and executions. It holds him responsible for committing acts that constitute serious human rights violations and breaches of international humanitarian law, as well as for threatening the peace, stability, and security of Sudan. The latest sanctions place Dagalo under a visa ban and an asset freeze.
Sudan’s civil war broke out in 2023 amid a power struggle between the government-backed SAF and the paramilitary RSF. The SAF and RSF, which evolved out of former dictator Omar al-Bashir’s Arab-majority Janjaweed militia, joined forces to orchestrate the April 2019 coup that removed Bashir and led to the formation of a transitional government tasked with drafting a new constitution. A growing power struggle over the government transition and planned elections erupted into violence in April 2023, spreading since to a national civil war. The RSF’s capture of El Fasher on October 26—SAF’s last stronghold in Darfur—has left the country effectively partitioned, with RSF controlling the west and southwest, while SAF controls the east and most of Khartoum. Both parties have been accused of committing atrocities and driving what the UN describes as the world’s largest humanitarian crisis, with 12 million displaced and likely more than 150,000 killed.
The international response to the crisis has combined humanitarian aid, diplomatic efforts, and punitive measures, including targeted sanctions. In October 2023, the EU adopted a sanctions regime against those responsible for undermining stability and democracy in Sudan. The regime now covers 11 individuals and eight entities, subjecting them to an EU-wide travel ban, asset freezes, and restrictions on access to funds. Last year, the EU added Abdelrahim Hamdan Dagalo’s holding company, Al Junaid Multi Activities Co. Ltd., to this list. Dagalo and his two sons own the company, which is accused of acquiring military equipment for the RSF. In September, the European Council extended these restrictive measures for an additional year.
The EU’s statement on Thursday signaled the bloc’s readiness to launch additional measures on “all actors” responsible for the ongoing destabilization of Sudan. As of now, the EU has refrained from imposing restrictions on SAF leader Gen. Abdel Fattah al-Burhan or RSF leader Mohamed Hamdan Dagalo, instead focusing on targeting close associates. As the war progresses, further EU sanctions on the leaders would align its approach with the US, which sanctioned both earlier this year in January, and respond to mounting calls for a more coordinated global response. The EU’s hesitation to sanction either leader could be attributed to a desire to maintain a channel for dialogue or hesitancy to back either side.
International attention on ending the conflict has gained momentum elsewhere in recent weeks, with British Foreign Secretary Yvette Cooper stating last week that London intends to introduce additional sanctions relating to human rights violations and abuses in Sudan. At present, most of the UK’s sanctions targeting the crisis have been entity-based, rather than aimed at named individuals. During his visit to Washington last week, Saudi Crown Prince Mohammed bin Salman pressed the US to take a more active role in negotiating a ceasefire. President Trump has signaled the US is prepared to collaborate with regional partners—including Saudi Arabia, the UAE, and Qatar—to broker a peace agreement in Sudan, consistent with his earlier foreign policy focus on peace negotiations and diplomatic mediation. Trump’s Africa envoy, Massad Boulos, has already convinced the interventionist powers, in principle, to accept a ceasefire to surge humanitarian aid and transition Sudan to civilian governance (barring the Muslim Brotherhood) on September 13. The RSF tactically agreed to the ceasefire after capturing El Fasher in late October. The SAF has declined the ceasefire, believing it will help the RSF reconstitute its strength.
Looking ahead, there is growing pressure in Washington to designate RSF as a Foreign Terrorist Organization (FTO) or Specially Designated Global Terrorist organization (SDGT). Either designation would significantly increase the risk of secondary sanctions for businesses and individuals exposed to RSF. Moreover, Sudan’s long history of political instability and weak governance underscores significant downside risks for businesses in post-war recovery. The country remains vulnerable to renewed violence, operational disruptions, and slow implementation of reconstruction plans, meaning investor confidence and economic recovery could remain fragile in the long term.
US Developments
Sanctions on Russia Loom as Trump Sends Peace Plan to Ukraine
Congress has once again taken up the Sanctioning Russia Act of 2025 (the “Act”), a sweeping sanctions and tariff-related bill first introduced in April by Senators Lindsey Graham (R-SC) and Richard Blumenthal (D-CT). However, the renewed push in Congress, which came after President Trump indicated he would support the legislation provided he retains ultimate decision-making flexibility, could face a number of hurdles in the coming days and weeks.
On November 19, Senate Majority Leader John Thune (R-SD) told reporters that he believed the House would need to make the first move on the bill. It is largely expected that the House can pass the Act with broad support; the bill (H.R. 2548) currently has 119 cosponsors across partisan lines. Yet, according to Representative Brian Fitzpatrick (R-PA), who “huddled” with House Speaker Mike Johnson (R-LA) on the House floor on November 19, Johnson “doesn’t necessarily” agree with Thune’s assessment, foreshadowing what may be a stalemate across Chambers.
The disagreement may be rendered moot if the threat of a discharge petition, which would force a vote even if Johnson does not schedule one, is made a reality. Nevertheless, even if such a measure is introduced and the House votes to pass the Act, the Senate, as Thune indicated in his remarks, faces a packed docket in the next month. Appropriations, defense policy, healthcare, and nominations are likely to take precedence over the Act unless President Trump throws his full weight behind it.
Across the Atlantic, the Act, which depends largely on President Trump’s support, faces another potential hurdle. Just days after President Trump indicated he would support the Act, the Secretary of the Army, Dan Driscoll, traveled to Ukraine to deliver the Administration’s most recent peace plan (the “Plan”) to Ukrainian President Volodymyr Zelenskyy.
Laid out in 28 points, the Plan notably calls for Ukraine to make territorial concessions, permanently reduce the size of its armed forces, and hold elections within 100 days of the war’s end. It also contains language barring Ukraine from entering the North Atlantic Treaty Organization (NATO). Such terms would be predicated on US security guarantees for Ukraine and a commitment from Russia not to invade Ukraine or other neighboring countries.
President Trump said that he expects President Zelenskyy’s response by November 27, but that he may extend that deadline “if things are working well.” Depending on the reaction to the Plan and any terms that may need to be negotiated further, the Act may continue to remain pending in Congress.
US Continues to Target Iranian Petroleum Networks
On November 20, the Office of Foreign Assets Control (OFAC) and the Department of State sanctioned multiple individuals, entities, and vessels alleged to be facilitating the sale of Iranian-origin petroleum and petroleum products for the benefit of the Iranian regime and its terrorist proxies.
- OFAC designated 41 individuals, entities, and vessels across multiple jurisdictions, including the United Arab Emirates (UAE), India, and Germany, for their alleged roles in facilitating the sale of Iranian-origin petroleum and petroleum products.
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- OFAC said these actions build on similarly targeted sanctions against alleged Iranian petroleum networks from February 6 and May 13.
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- The Department of State sanctioned 17 individuals, entities, and vessels across multiple jurisdictions, including the UAE, India, Singapore, and Vietnam, for their alleged roles in facilitating the sale of Iranian-origin petroleum and petroleum products.
These actions build on President Trump’s National Security Presidential Memorandum 2 (NSPM-2), which called for, among other things, “maximum pressure” on the Iranian regime. They also came as Iran announced that it was withdrawing from an agreement to allow for international inspections of its nuclear sites.
OFAC Sanctions Russian BPH Service Provider
On November 19, OFAC sanctioned Media Land, an alleged Russia-based bulletproof hosting (BPH) service provider, as well as three of its leadership team members, three of its sister companies, and entities and individuals affiliated with a separate, previously designated BPH service provider, Aeza Group. Under Secretary of the Treasury for Terrorism and Financial Intelligence John K. Hurley said in an accompanying statement that BPH service providers “provide cybercriminals essential services to aid them in attacking businesses in the United States and in allied countries,” and that OFAC’s recent designations “demonstrate[] [a] commitment to combating cybercrime and protecting our citizens.”
OFAC’s actions were taken in collaboration with Australia’s Department of Foreign Affairs and Trade (DFAT) and the United Kingdom’s Foreign Commonwealth and Development Office (FCDO). This is the second time during the Trump administration that the three countries have come together to sanction BPH service providers, following designations made on February 11.
OFAC Designates Former Olympian and Narcotrafficker
On November 19, OFAC designated Ryan James Wedding (“Wedding”), a former Olympic snowboarder for Team Canada, who is currently one of the Federal Bureau of Investigation’s (FBI) Ten Most Wanted Fugitives, as well as nine individuals and nine entities said to be closely associated with him, for multiple alleged crimes, including narcotrafficking and money laundering.
The sanctions were accompanied by an announcement from the Department of Justice that ten defendants had been arrested pursuant to a nine-count federal grand jury indictment against Wedding and others in connection with a January 31 murder in Colombia of a federal witness.
UK Developments
UK Publishes New Amber Alert on Sanctions Evasion Networks and Shadow Fleets
The UK National Crime Agency (NCA) published an amber alert (the “Alert”) that seeks to assist maritime and financial institutions to identify and prevent sanctions evasion involving commodities by sanctions evasion networks and shadow fleets that support regimes subject to sanctions, such as the Democratic People’s Republic of Korea, Iran, and Russia. The Alert builds on the July 2025 NCA red alert on Russian shadow fleet sanctions evasion and avoidance networks and outlines various sanctions evasion typologies and warning flags that affected businesses should be alert to and incorporate into their sanctions risk assessments and compliance controls. Businesses and financial institutions active in the maritime sector should carefully review the amber alert and assess whether any updates are required to their sanctions risk assessments and compliance controls.
UK Updates Definition of “Divest Investor” in Financial Sanctions Guidance
The UK Government has updated its general financial sanctions guidance to clarify when OFSI may license transactions involving “divest investors” under the Russia sanctions regime. The updated definition now expressly includes three categories: (i) designated persons under UK Russia sanctions; (ii) the Russian Government itself; and (iii) anyone facilitating another party’s divestment from these investors. OFSI may authorize UK entities to acquire an interest from a divest investor when the only consideration is a payment to the UK-designated person or the Russian Government, and the funds are either placed into a frozen UK account or paid into an account in a jurisdiction with equivalent sanctions controls. The revised wording is significant for UK companies with Russian-linked shareholdings, as it confirms that the acquisition of interests held by UK designated persons or the Russian Government in the acquiring UK entity can be licensed, resolving previous ambiguity around what constituted permissible “divestment.”
UK Amends Export Control Framework
The UK’s Export Control Joint Unit (ECJU) has published a notice outlining a number of amendments to the UK export control framework that will be introduced from December 16, 2025, by The Export Control (Amendment) (No. 2) Regulations 2025 (the “Amendment Regulations”). The changes update three key instruments—the Export Control Order 2008, the assimilated EU Dual-Use Regulation, and the assimilated Torture Regulation—to ensure continued alignment with the UK’s international commitments and recent updates to EU control lists. In pertinent part, the amendments replace the UK-specific controls on sensitive emerging technologies (PL9013, PL9014 and PL9015) with new “500-series” dual-use entries, mirroring the structure already in use in Northern Ireland where EU controls still apply directly. Businesses handling dual-use goods or items usable for capital punishment or torture should review the revised control list entries carefully to understand whether their classification obligations have changed and ensure that licensing assessments reflect the updated regime.
UK Targets Facilitators of Cyber Criminals in Latest Round of Designations
OFSI has designated one entity under the Russia sanctions regime (notice) and designated two entities and four individuals under the Cyber sanctions regime (notice). According to the UK Government press release, this was part of a coordinated effort with the US and Australia to target Media Land LLC, a Russian cybercrime group providing hosting services that facilitate and allow cyber criminals to engage in illegal activity. In addition to Media Land LLC, OFSI has made the following designations under its Cyber sanctions regime: (i) ML Cloud LLC (which is said to be a sister company of Media Land LLC); and (ii) Andrei Kozlov, Yulia Pankova, Alexander Volosovik, and Kirill Zatolokin (who are each said to be employed by, or associated with, Media Land LLC). OFSI has also added Azea Group LLC to its Russia sanctions list, which is another hosting service that is said to have engaged in actions threatening Ukraine’s national security. This coordinated action with Australia and the US demonstrates the UK’s ongoing commitment to tackling malicious Russian cyber activity globally.
UK Government Publishes Parliamentary Briefing on UK’s Response to Israel and Palestine Conflict
The UK House of Commons parliamentary library has published a briefing on the UK’s response to the conflict in Israel and Palestine from March-October 2025. The briefing includes information on UK sanctions in response to the situation in Israel and the Occupied Palestinian Territories (OPTs) from March to November 2025. In the pertinent part, in May, the UK Government announced a round of sanctions against organisations and individuals involved in settler violence in the West Bank and also announced an asset freeze and travel ban against Israeli ministers Ben-Gvir and Smotrich. These actions follow a joint statement issued by the governments of France, Canada and the UK on May 19, which said that they were prepared to take “further concrete action” in response to a “wholly disproportionate” Israeli military action and the lack of aid entering Gaza since March 2025. In September, the UK Government also stated that it was planning new sanctions against Hamas. Taken together, these measures demonstrate a sustained willingness by the UK to use autonomous sanctions to deter violence, respond to humanitarian concerns, and align pressure with international partners.
OFSI Amends General Licence Authorizing Continuation of Business with Certain Lukoil Bulgaria Entities
OFSI has amended the General Licence INT/2025/7895596 for the Continuation of Business with certain Lukoil Bulgaria Entities to extend the subsidiaries covered under the licence (the “GL”). Subject to certain conditions, the GL allows a person to continue business operations involving certain specified Lukoil Bulgaria entities. Prior to the amendments, the GL only applied to Lukoil Bulgaria EOOD and Lukoil Neftochim Burgas AD, and their subsidiaries. Following the amendments to the GL, the licence now also applies to Lukoil Aviation Bulgaria EOOD and Lukoil Bunker Bulgaria EOOD, and their subsidiaries. Any persons intending to use the GL should consult the copy of the licence for full details of the definition, permissions, and usage requirements. Additionally, OFSI has updated FAQ 173 of its FAQ guidance to reflect the update to the GL.
EU Developments
European Commission Updates FAQs on EU sanctions concerning Syria
The European Commission published updated FAQs on EU sanctions against Syria to guide operators through the current framework, following the EU’s decision on May 28, 2025, to lift almost all sectoral economic sanctions. The FAQs outline the scope of the sanctions lifting, the restrictions that remain, and the impact on financial and trade activities between the EU and Syria.
The Commission confirmed the delisting of 29 entities, including the Central Bank of Syria and companies in oil, cotton, telecommunications, and media, while maintaining listings of persons linked to the Al-Assad regime. It also clarified that the humanitarian exemption adopted by the EU Council following the February 2023 earthquake remains in force without expiry. This exemption allows certain humanitarian operators to provide funds or economic resources to listed persons and entities without prior authorization from National Competent Authorities (NCAs).
Lastly, the updated FAQs include guidance on contracts between EU and Syrian operators whose performance became prohibited when sanctions against Syria came into force in 2012 and thereafter. According to the Commission, EU operators were shielded from legal consequences for non-performance of contracts affected by sanctions under Article 27 of Council Regulation 36/2012. However, the imposition of sanctions did not automatically terminate such contracts; they were effectively suspended and may now be resumed if permitted under the applicable law. The Commission further clarifies that a designated Syrian person or entity (whether currently or previously listed) is not entitled to claim damages after May 28, 2025, from an EU operator for non-performance of an action restricted before that date, even if the claim is brought after May 28, 2025.
EU Council Amends Sanctions Listing Targeting Russia
On November 20, the EU Council amended Decision (CFSP) 2024/1484 concerning restrictive measures in view of the situation in Russia. The update adds ten individuals to the sanctions list set out in the Annex to Decision 2024/1484. Those listed include senior officials of the Russian Federal Penitentiary Service, judges, prosecutors, and an investigator involved in serious human rights violations, politically motivated prosecutions, and the repression of civil society. The restrictive measures imposed include a travel ban, the freezing of assets, and a prohibition on making funds or economic resources available to designated individuals.
Asia-Pacific Developments
Russian Oil Prices Plunge as India and China Slash Imports Before US Sanctions Hit
Russian oil prices have plunged as India and China sharply reduced purchases ahead of a looming US sanctions deadline targeting Rosneft and Lukoil. Major Indian buyers and Chinese firms have suspended direct imports, impacting roughly 45% of Russian oil exports to China. This demand collapse has left about one-third of Russia’s seaborne shipments—around 1.4 million barrels per day—stranded in floating storage.
Novatek Slashes LNG Prices to Secure Chinese Buyers Amid Sanctions
Sanctions imposed by the US and Europe have forced Russian LNG producer Novatek to slash prices by 30–40% since August to attract Chinese buyers for gas from its Arctic LNG 2 project, a $21 billion venture previously stalled by some of the toughest restrictions on Moscow’s energy sector. These steep discounts have revived sales that were in limbo for months, as Washington intensifies efforts to curb Russia’s oil and gas revenues and warns countries against purchasing sanctioned fuel. Despite this pressure, China—Russia’s key strategic partner—continues to import LNG, with the Beihai terminal serving as a primary entry point for these shipments. The situation highlights how Moscow is relying on aggressive price cuts to sustain energy exports amid tightening sanctions and escalating geopolitical tensions.
China’s Digital Currency Plan in Myanmar Aims to Bypass US Sanctions
China is assisting Myanmar’s military regime in developing a digital payment system based on the digital yuan, aiming to bypass US sanctions and reduce reliance on the SWIFT network. The initiative includes creating a digital kyat issued by Myanmar’s central bank and converting it into digital yuan through ICBC, with transactions routed via China’s Cross-Border Interbank Payment System (CIPS) instead of dollar-based channels. This layered structure could obscure ownership and allow sanctioned entities to access dollar clearing through Chinese intermediaries, exploiting ICBC’s correspondent ties with major US banks.
S7 Airlines Begins Flying Over North Korea Amid Safety and Sanctions Concerns
Russia’s largest private carrier, S7 Airlines, has started routing flights between Vladivostok and Shanghai through North Korean airspace, a route long avoided by other airlines due to safety and sanctions concerns. Flight-tracking data shows the change began on November 12. The move may reflect growing economic ties between Russia and North Korea and could offer cost benefits for S7, such as shorter distances or favorable winds. However, the practice raises questions about compliance with UN sanctions, as fee transfers might breach restrictions, and poses risks linked to North Korea’s missile tests and limited emergency landing infrastructure.
