Monthly Sanctions Update (December 2025)

KEY DEVELOPMENTS

• Major US, UK and EU designations: US designation of Clan del Golfo as an FTO and SDGT; EU asset-freeze measures linked to gang violence in Haiti; UK Russia-regime designations of the GRU and associated foreign information manipulation networks following the Dawn Sturgess Inquiry; UK cyber-sanctions designations of China-based technology companies; US and UK sanctions targeting Rapid Support Forces leadership; PRC sanctions against selected US defence companies and executives following approval of a Taiwan arms sale.

• Sanctions litigation and judicial developments: UK Commercial Court judgment in Beneathco DMCC v R.J. O’Brien Ltd dismissing an Iran-related payment claim and confirming application of the Ralli Bros principle; UK Commercial Court refusal in FH Holding Moscow Ltd v AO UniCredit (Russia) and UniCredit SpA to grant an anti-suit injunction in Russia-related foreclosure proceedings; PJSC VTB Bank v HM Treasury confirms OFSI’s statutory discretion to amend general licences under the UK Russia sanctions regime.

• Cyber-related sanctions expansions: UK designations under the Cyber (Sanctions) (EU Exit) Regulations 2020 targeting China-based entities alleged to have supported malicious cyber activity against UK public- and private-sector systems; UK Russia-regime sanctions targeting coordinated foreign information manipulation and interference involving fake news websites, social media accounts and automated bot networks.

• Significant Russia-related developments: EU Council renewal of sectoral sanctions against Russia through 31 July 2026 by Council Decision (CFSP) 2025/2648; OFAC imposition of an approximately US $7.1 million civil penalty against Gracetown, Inc. for dealings involving blocked property owned by Oleg Deripaska and related reporting failures; US Treasury extension of the deadline for permitted negotiations relating to PJSC Lukoil’s foreign assets; EU agreement on a €90 billion loan package for Ukraine.

• Geopolitical adjustments to sanctions regimes: US lifting of sanctions on Belarusian potash exports; US delisting of Brazilian Supreme Court Justice Alexandre de Moraes and related parties; UK delisting of Munir Al Qubaysi under the Iraq regime; UK de-listings and new designations under the Syria sanctions regime.

• Regulatory and licensing updates:  OFSI amendment to the Legal Services General Licence (INT/2025/7323088); amendments to Russian travel and oil-related General Licences; issuance of a Russian oil wind-down licence; introduction of a Myanmar humanitarian General Licence.

GLOBAL SANCTIONS

BELARUS

• On 13 December 2025, the United States lifted sanctions on Belarusian potash exports, a key source of revenue for Belarus and a critical input in global fertiliser supply chains. The decision followed the release by Belarusian authorities of 123 detainees, including political prisoners and individuals associated with opposition activity against the government of President Alexander Lukashenko.

BRAZIL

• On 12 December 2025, the United States removed Brazilian Supreme Court Justice Alexandre de Moraes, his wife, and the Lex Institute from its Specially Designated Nationals (SDN) List, reversing sanctions imposed earlier in the year under the Global Magnitsky Human Rights Accountability Act. The original designation had frozen any US-based property and prohibited dealings with US persons and was linked to Moraes’s role in overseeing criminal proceedings against former President Jair Bolsonaro. The delisting followed diplomatic engagement between US and Brazilian officials.

CHINA

• On 4 and 9 December 2025, the UK Government designated Integrity Technology Group Incorporated and Sichuan Anxun Information Technology Co., Ltd. under the Cyber (Sanctions) (EU Exit) Regulations 2020. The entities are alleged to have supported malicious cyber activity affecting UK public-sector and private-sector IT systems, including through botnet operations and the provision of cyber-intrusion services. The designations impose asset freeze measures and prohibit UK persons from making funds or economic resources available to the listed entities.

COLOMBIA

• On 16 December 2025, the US Department of State designated the Colombia-based Clan del Golfo as both a Foreign Terrorist Organization (FTO) and a Specially Designated Global Terrorist (SDGT) entity under US law. According to the State Department, Clan del Golfo is responsible for widespread violence, drug trafficking, extortion and other criminal activity that undermines civilian security and regional stability. The designation blocks Clan del Golfo’s property and interests in the United States and generally prohibits US persons from engaging in transactions with the group or its members.

HAITI

• On 15 December 2025, the EU adopted new asset-freeze measures against three individuals and one entity connected to serious human rights abuses and gang-related violence in Haiti. The designations target persons assessed to be responsible for, or complicit in, activities contributing to widespread insecurity, including violence carried out by organised criminal groups.

IRAN

• On 24 November 2025, the UK Commercial Court delivered its judgment in Beneathco DMCC v R.J. O’Brien Ltd. The case concerned a UAE-based entity that held approximately USD 16.5 million in a derivatives trading account with an FCA-regulated broker at the time it was designated under the US Iran sanctions regime. The claimant later sought to recover the funds by issuing amended payment instructions directing payment to an account held by a third party. The Court dismissed the claim, concluding that no valid payment demand had been made because the contractual terms required payment in US dollars, and the request for payment in a different currency was ineffective. The Court further held that the broker was entitled to rely on the Ralli Bros principle, as making payment in US dollars would have involved an act within the US and would have resulted in a breach of US sanctions.

• On 30 December 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 10 individuals and entities in Iran and Venezuela for their roles in the Iran-Venezuela weapons trade, including a Venezuelan company and its chairman that acquired Iranian-designed unmanned aerial vehicles (UAVs) and assisted in their sale and assembly in Venezuela. The action, taken under Executive Orders targeting weapons proliferation, also included Iran-based persons involved in procuring chemicals used in ballistic missile programs and thereby supporting Iran’s UAV and missile development. According to OFAC, the designations build on previous nonproliferation measures and U.N. sanctions reimposed in September 2025 and reflect US efforts to disrupt the flow of Iranian conventional weapons to Caracas, which are assessed to threaten US and allied personnel and destabilize regional security.

IRAQ

• On 10 December 2025, the UK Government removed Munir Al Qubaysi from the UK’s Iraq sanctions regime, following his delisting from the UN sanctions list. Mr Al Qubaysi had originally been designated in 2004 in connection with his role as director of Al-Bashair Trading Company, which was reported to have operated as a major front company involved in Iraq’s arms procurement activities.

RUSSIA

• On 24 November 2025, the UK court declined to grant anti-suit injunction in Russia-related proceedings. The UK Commercial Court has refused an application for an anti-suit injunction in FH Holding Moscow Ltd v AO UniCredit (Russia) and UniCredit SpA. The dispute arose out of a financing arrangement entered into in 2018 under which a Russian operating company borrowed funds from an Italian bank pursuant to an English law–governed facility agreement providing for arbitration in Vienna. Separate security arrangements over Russian property were governed by Russian law and subject to the jurisdiction of the Russian courts. Following the commencement of foreclosure proceedings in Moscow in March 2025, the borrower sought to restrain those proceedings on the basis that the Russian courts might require conduct that would place it in breach of EU Russia sanctions. The Court rejected the application, finding that the risk of any sanctions breach was speculative and insufficiently concrete to justify intervention. It also held that the UK’s public policy interest in supporting EU sanctions, without additional factors connecting the dispute to the English courts, did not provide a sufficient basis for granting anti-suit relief.

• On 4 December 2025, the UK Government designated multiple individuals and entities under the Russia and Cyber sanctions regimes, including Russia’s military intelligence agency (the GRU) and associated officers. The designations followed the publication of the final report of the Dawn Sturgess Inquiry into the Salisbury poisonings, which concluded that GRU agents were responsible for the attack. The measures target those involved in cyber-attacks, disinformation, sabotage and political interference undermining UK security.

• On 4 December 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed an approximately $7.1M civil penalty on New York–based property management company Gracetown, Inc. for violations of the Ukraine-/Russia-Related Sanctions Regulations and related reporting obligations. OFAC found that, between April 2018 and May 2020, Gracetown knowingly received 24 payments on behalf of a British Virgin Islands–based entity ultimately owned by designated Russian oligarch Oleg Deripaska, despite having received explicit notice from OFAC that all dealings involving Deripaska and his property were prohibited. OFAC further determined that Gracetown failed to timely report blocked property for more than 45 months, including an accumulated debt owed to a Deripaska-owned entity, and classified the conduct as egregious and not voluntarily self-disclosed, underscoring enforcement risks for US service providers that continue dealings or fail to meet blocking and reporting requirements following designation.

• On 9 December 2025, the UK Government designated seven individuals and entities under the Russia sanctions regime in connection with foreign information manipulation and interference (FIMI) activities. Those designated include Rybar LLC and its director Mikhail Zvinchuk, the Centre for Geopolitical Expertise and its founder Aleksandr Dugin, and several organisations linked to PRAVFOND, a Russian state-backed body. The designated parties are alleged to have been involved in coordinated efforts to undermine democratic processes through the creation of fake news websites and the use of social media and automated bot accounts to disseminate misleading narratives supportive of Russia’s war in Ukraine.

• On 12 December 2025, the US Treasury extended the deadline for permitted negotiations relating to Lukoil’s foreign assets to 17 January 2026, postponing the previous cut-off of 13 December 2025. According to Reuters, Saudi Arabia’s Midad Energy has emerged as a leading contender in the potential acquisition process and has proposed a transaction structure involving an upfront cash payment alongside escrow arrangements, under which sale proceeds would be held in a designated escrow account pending the lifting of sanctions on Lukoil.

• On 16 December 2025, the EU Council renewed its sectoral sanctions against Russia for a further six months, until 31 July 2026, by adopting Council Decision (CFSP) 2025/2648. The sectoral measures include restrictions on Russia’s financial, energy, defence and dual-use goods sectors, and form part of one of the EU’s six Russia-related sanctions regimes. The renewal maintains the existing framework of economic restrictions introduced in response to Russia’s actions undermining Ukraine’s territorial integrity and reflects the EU’s continued policy of sustained sanctions pressure.

• On 19 December 2025, the Administrative Court rejected a claim brought by PJSC VTB Bank (VTB) challenging a decision of OFSI to amend a general licence. In PJSC VTB Bank v HM Treasury, VTB argued that OFSI’s amendment of the licence was unlawful. The Court dismissed the claim, confirming that OFSI was entitled to amend the general licence in the exercise of its statutory powers. The judgment underscores the broad discretion afforded to HM Treasury and OFSI in the administration and modification of sanctions licensing arrangements under the UK’s Russia sanctions framework.

SUDAN

• On 9 December 2025, the US Department of the Treasury’s OFAC imposed sanctions on four individuals and four entities linked to a transnational network that recruited and trained former Colombian military personnel to fight for the Sudanese paramilitary group known as the Rapid Support Forces (RSF). OFAC stated that the network provided training and support, including to child soldiers, in furtherance of RSF operations contributing to Sudan’s ongoing conflict. Subsequently, on 12 December 2025, the UK sanctioned four senior RSF commanders, including RSF Deputy Leader Abdul Rahim Hamdan Dagalo, for their alleged responsibility for mass killings, sexual violence and attacks on civilians, imposing asset freezes and travel bans. The UK simultaneously announced an additional £21 million in humanitarian assistance, underscoring a parallel strategy of targeted sanctions and humanitarian support in response to the crisis.

• On 27 December 2025, President Volodymyr Zelenskyy signed two decrees enacting decisions of Ukraine’s National Security and Defence Council to align parts of Ukraine’s sanctions regime with those of the UK and to implement restrictions consistent with United Nations Security Council resolutions. Under the first decree, Ukraine imposed sanctions on eight individuals and 40 legal entities, including persons and companies linked to forced child deportations, supply of dual-use electronics and components used in Russian missile and drone production, and entities facilitating circumvention of sanctions and energy-sector support. The second decree implements sanctions in line with UN Security Council mandates concerning South Sudan, targeting eight members of the country’s military leadership for their role in prolonging conflict and committing serious abuses. These coordinated actions form part of Ukraine’s broader effort to align its sanctions measures with key international partners.

SYRIA

• On 19 December 2025, the UK added nine new designations, consisting of 6 individuals and 3 entities, all subject to an asset freeze. This followed four de-listings under the Syria regime on 17 December 2025. All de-listings remain subject to sanctions in other jurisdictions, namely the Iran regime, the Iran (Nuclear) regime, and the Chemical Weapons regime.

TAIWAN

• On 26 December 2025, China’s Ministry of Foreign Affairs announced sanctions on 20 US defence-related companies and 10 senior executives following Washington’s approval of a roughly US $11.1 billion arms sale to Taiwan, one of the largest packages in recent history. The sanctions freeze any assets the targeted firms and individuals hold within China and bar Chinese entities and citizens from entering into business with them. The list includes major defence contractors such as Northrop Grumman Systems Corporation, L3Harris Maritime Services and Boeing’s St. Louis defence unit, as well as executives including the founder of Anduril Industries. China’s foreign ministry described the measures as a necessary response to what it called provocations that “cross the line” on the Taiwan issue, reiterating that Taiwan is a core national interest and rejecting external arms transfers to the island.

UKRAINE

• On 19 December 2025, EU leaders agreed to provide Ukraine with a €90 billion loan package intended to cover Kyiv’s budgetary and defence needs over the next two years. The loan will be financed through joint EU borrowing backed by the EU budget, rather than by using Russian sovereign assets frozen in the EU, despite earlier proposals to do so. Member States failed to reach consensus on making immobilised Russian assets part of the financing mechanism, primarily due to legal and financial risk concerns. Ukrainian President Volodymyr Zelenskyy welcomed the agreement, noting its significance for Ukraine’s resilience, and emphasised that Russian assets will remain immobilised.

VENEZUELA

• On 11 December 2025, the US Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on a group of individuals and entities connected to the Maduro government in Venezuela, including three members of President Nicolás Maduro’s family, a Panamanian businessman, six shipping companies and a number of vessels. OFAC stated that two of the family members were designated under US counter-narcotics authorities, on the basis of alleged involvement in drug trafficking activities in Venezuela. The remaining family member, together with the Panamanian businessman, the shipping companies and the vessels, were designated for their alleged role in facilitating the illicit transport of Venezuelan oil, including activities linked to the Government of Venezuela and state-owned entities such as Petróleos de Venezuela, S.A. (PdVSA).

• On 31 December 2025, OFAC imposed sanctions on four Venezuelan oil-sector companies and identified four associated oil tankers—Nord Star, Rosalind (also known as Lunar Tide), Della, and Valiant—as blocked property for operating in Venezuela’s oil economy and facilitating revenue flows to the Maduro government. OFAC noted that these actions form part of an intensifying campaign against Venezuela’s illicit oil trade and its “shadow fleet” of vessels used to evade sanctions and generate funds for regime activities. The designations block any US property or interests of the companies and tankers and prohibit US persons from engaging in transactions with them.

GLOBAL REGULATIONS/TOOLS UPDATE: OFSI

General Licenses 

Legal Services General Licence (INT/2025/7323088), amended 17 December 2025

OFSI’s Legal Services General Licence INT/2025/7323088 took effect on 29 October 2025, replacing the previous legal services licence and permitting UK law firms, counsel and related service providers to receive payment for legal services provided to designated persons under most UK autonomous sanctions regimes, subject to specified conditions. On 17 December 2025, the licence was amended to clarify that the definition of “legal services” expressly includes legal advice and representation in dispute resolution proceedings, correcting an omission in the original October version. The licence continues to impose financial caps, detailed reporting obligations within 14 days of payment, and six-year record-keeping requirements, and does not permit payments involving persons designated solely to comply with UN obligations.

Russia

Russian Travel General Licence (INT/2022/1839676), amended 12 December 2025

This licence permits UK persons to purchase passenger rail and air travel tickets from specified Russian transport providers, including Aeroflot, Russian Railways and their subsidiaries, for journeys originating in or within Russia, as well as certain rail routes between Armenia and Georgia. It also authorises UK financial institutions and intermediaries to process payments necessary to effect such ticket purchases. The licence remains subject to strict conditions and does not permit funds to be made available beyond what is expressly authorised, and is currently valid until 22 May 2028.

Russian Oil Exempt Projects General Licence (INT/2025/5635700), amended 17 December 2025 This licence permits continued business operations involving specified Russian oil companies and their subsidiaries, including PJSC Lukoil, Rosneft and Gazpromneft-Sakhalin, where activities relate solely to listed “Exempt Projects” such as Sakhalin-2, the Caspian Pipeline Consortium, TengizChevroil, Shah Deniz and Zohr. It authorises payments, contractual performance and certain shareholder activities connected to these projects for defined periods, subject to project-specific expiry dates set out in Schedule 1. The licence reflects the UK’s approach of preserving critical international energy projects while maintaining broader Russia sanctions restrictions, and includes six-year record-keeping obligations for all parties relying on its permissions

Russian Oil Companies Wind-Down General Licence (INT/2025/8202932), effective 18 December 2025

This licence authorises non-designated persons and relevant UK institutions to wind down transactions involving specified Russian oil companies, including PJSC Russneft and PJSC Tatneft, and their subsidiaries. Permitted activity includes closing out positions and taking steps reasonably necessary to effect an orderly wind-down. The licence is time-limited, expiring on 31 January 2026, and imposes record-keeping obligations requiring parties to retain transaction records for at least six years

Myanmar

Myanmar Humanitarian Activity General Licence (INT/2025/8257372), effective 19 December 2025

This General Licence permits specified humanitarian actors to carry out activities necessary to provide humanitarian assistance and support basic human needs in Myanmar, notwithstanding otherwise applicable prohibitions under the Myanmar and Global Human Rights sanctions regimes. The licence applies to UN bodies, UK-funded organisations, participating NGOs, international organisations and their partners, and allows the provision and processing of funds, goods and services required for humanitarian operations. Funds used must not be owned or controlled by a designated person, and any relevant organisation relying on the licence must notify HM Treasury within 30 days of commencing activities in Myanmar. The licence reflects the UK’s continued use of broad humanitarian carve-outs to facilitate aid delivery while maintaining sanctions pressure on designated actors.

CONCLUSION

December’s developments highlight the continued influence of US and UK sanctions authorities in shaping the global sanctions landscape through new designations, enforcement action, judicial clarification and targeted licensing updates. Alongside EU measures and selective sanctions relief linked to diplomatic and humanitarian objectives, these actions reflect an increasingly complex and enforcement-driven compliance environment for businesses and financial institutions operating across jurisdictions. MR’s monthly sanctions update will continue to monitor these developments, providing timely insight into international sanctions measures, regulatory reforms and key enforcement trends shaping the global sanctions landscape.