Monthly Sanctions Update (November 2025)

KEY DEVELOPMENTS

• Major U.S. and U.N. designations: New U.S. sanctions on Colombia’s president and senior officials; joint U.S.–U.N. designations targeting Haitian gang leaders; U.S. designation of Venezuela’s “Cartel de los Soles” as an FTO; Nigeria designated a “country of particular concern.”
• High-value sanctions litigation: Mikhail Fridman initiated US$16bn investment treaty arbitration against Luxembourg challenging EU sanctions-related asset freezes.
• Cyber-related sanctions expansions: Coordinated U.S.–UK–Australia designations against Russian “bulletproof hosting” providers (including Media Land, ML.Cloud, Aeza Group); U.S. designations targeting North Korean crypto-laundering and DPRK IT worker networks.
• Significant Russia-related developments: UK action against a billion-dollar Russian money-laundering network; U.S. measures prompting Lukoil’s accelerated sale of international assets.
• Geopolitical adjustments to various sanctions regimes: U.S. one-year sanctions waiver for Hungary’s Russian energy imports; U.N. vote lifting sanctions on Syria’s interim leadership; U.S. removal of 2022 sanctions on Milorad Dodik.
• Regulatory and licensing updates: OFSI and OFAC issued multiple Russia-related General Licences, including those covering Lukoil entities, CPC-related operations, correspondent-banking payments, and divestment mechanisms.
• U.S. and UK enforcement activity: OFAC imposed a record US$4.7m penalty for dealings in blocked Russian property; HMRC published a £1.1m compound settlement for Russia-linked export breaches.

GLOBAL SANCTIONS

COLOMBIA

• On 29 October 2025, the U.S. imposed sweeping sanctions on Colombian President Gustavo Petro, his wife Veronica Alcocer, his son Nicolás Petro, and Interior Minister Armando Benedetti. Treasury alleges the administration has “allowed drug cartels to flourish” and obstructed counter-narcotics efforts. The designations freeze U.S.-linked assets and bar U.S. persons from dealings with the listed individuals. This marks the first time the U.S. has sanctioned a sitting Colombian president and comes as the Administration expands its regional counterdrug campaign, including increased maritime interdictions and the deployment of an aircraft carrier to the eastern Pacific.

HAITI

• On 17 October 2025, the U.S. and U.N. jointly sanctioned Dimitri Herard (former head of presidential security) and Kempes Sanon (leader of the Bel Air gang) for supporting the Viv Ansanm coalition, now considered Haiti’s most powerful gang alliance. Herard allegedly provided training and weapons to gang leaders after escaping custody in 2024, while Sanon is accused of extortion, kidnappings, and maintaining networks inside Haitian government institutions enabling him to evade arrest. The U.N. resolution imposes a global asset freeze, travel ban, and an arms embargo, marking one of the most comprehensive multilateral actions targeting Haiti’s gang networks to date.

HUNGARY

• Following a meeting in Washington, the U.S. granted Hungary a one-year exemption from sanctions targeting Russian energy imports. The waiver allows continued deliveries through the TurkStream gas pipeline and the Druzhba oil pipeline, both of which remain central to Hungary’s energy security. As part of the agreement, Hungary committed to purchasing approximately $600 million in U.S. LNG, expanding cooperation on nuclear energy, and increasing procurement of U.S.-made nuclear fuel for the Paks nuclear power plant. The move underscores occasional U.S. flexibility in applying Russia-related sanctions where allies face acute energy vulnerabilities.

LUXEMBOURG

• Senior Advocate Gourab Banerji has been appointed as the claimant-nominated arbitrator in a US$16 billion UNCITRAL investment treaty arbitration brought by Russian businessman Mikhail Fridman against the Grand Duchy of Luxembourg. The claim is brought under the 1989 Russia–Belgium/Luxembourg Bilateral Investment Treaty and challenges Luxembourg’s freezing of Fridman’s assets following his designation under the EU sanctions regime. The tribunal is now fully constituted, chaired by Professor Joongi Kim (Yonsei Law School). Luxembourg has appointed Klaus Sachs (CMS Munich) as its arbitrator. Fridman alleges that the sanctions resulted in the unlawful expropriation of his beneficial interests in ABH Holdings, part of the Alfa Group, and argues that the EU’s assertions regarding his links to the Russian government lack evidentiary basis. The arbitration follows an April 2024 EU General Court ruling that annulled earlier sanctions imposed on Fridman (Feb 2022–Mar 2023) as unjustified, though later EU listings remain in force, continuing to affect his assets.

NIGERIA

• In early November 2025, the Administration designated Nigeria a “country of particular concern” under the International Religious Freedom Act, citing the alleged persecution of Christians and threats from radical armed groups. While this designation does not itself impose sanctions, it authorizes the U.S. to enact penalties such as the suspension of non-humanitarian aid, visa restrictions, and trade measures. Nigeria strongly rejected the allegations, noting that extremist violence in the north affects multiple communities and that the U.S. assessment does not reflect current security dynamics.

NORTH KOREA

• On 4 November 2025, the U.S. sanctioned eight individuals and two firms implicated in laundering cryptocurrency stolen by North Korean state-sponsored hackers. According to Treasury, DPRK cyber operations have diverted over $3 billion in digital assets over the past three years, funneling proceeds into the regime’s nuclear weapons program. The designations target overseas banking representatives operating in China, Russia, and elsewhere, as well as entities managing millions in crypto for sanctioned institutions such as First Credit Bank. The action follows earlier U.S. warnings about North Korean IT workers posing as remote contractors to gain access to U.S. financial systems.

• On 19 November 2025, the listing of Chosun Expo, a North Korean front company associated with the Reconnaissance General Bureau (RGB), was amended under the Russia (Sanctions) (EU Exit) Regulations 2019. The entity is linked to malicious cyber activity including data interference and unauthorised access to information systems.

RUSSIA

• On 19 November 2025, the UK updated its sanctions list under the Cyber (Sanctions) (EU Exit) Regulations 2020, adding Media Land LLC, ML.Cloud LLC, and individuals Alexander Alexandrovich Volosovik, Kirill Andreevich Zatolokin, Yulia Vladimirovna Pankova, and Andrei Valerevich Kozlov. The listings impose asset freezes and director disqualifications on the entities, and travel bans on the individuals. The UK government stated that Media Land has acted as a “bulletproof hosting” provider, supplying resilient server infrastructure that allegedly enabled ransomware operations, phishing, DDoS attacks, and other malicious cyber activities targeting organisations in the UK and allied countries.

• In a coordinated action the same day, the U.S. and Australia also imposed sanctions targeting the same cybercrime infrastructure. OFAC designated Media Land for supporting ransomware operations, along with three members of its leadership, three affiliated companies (including ML.Cloud), and Hypercore Ltd., described as a front company for Aeza Group LLC, another bulletproof hosting provider sanctioned earlier in the year. John K. Hurley, U.S. Under Secretary of the Treasury for Terrorism and Financial Intelligence, said the joint action underscores a “collective commitment to combatting cybercrime and protecting our citizens.”

• On 19 November 2025, the UK Government added Aeza Group LLC to the UK Sanctions List under the Russia (Sanctions) (EU Exit) Regulations 2019. According to the Government, Aeza Group has provided “bulletproof hosting” infrastructure used to support the operations of the Social Design Agency, a Russian state-linked disinformation organisation already designated by the UK in 2024 for activities aimed at destabilising Ukraine and undermining democratic institutions globally.

• On 21 November 2025, the National Crime Agency uncovered a billion-dollar Russian money-laundering network operating across at least 28 UK towns and cities, in an investigation dubbed “Operation Destabilise”. The network converted criminal proceeds and cash into cryptocurrency to facilitate sanctions evasion and Russian military financing. Key actors from the SMART and TGR networks were sanctioned by OFAC in December 2024 after being linked to the acquisition of Kyrgyzstan’s Keremet Bank, which was used to facilitate payments to Russia’s state-owned Promsvyazbank. Russian-Moldovan oligarch Ilan Shor and his sanctioned platform A7 were also tied to the scheme. Operation Destabilise has resulted in 128 arrests and the seizure of over £25 million in the UK, plus $24 million and €2.6 million internationally, significantly restricting Russian-linked laundering networks’ access to Western financial systems.

• On 21 November 2025, following the full implementation of new U.S. sanctions, Lukoil accelerated plans to divest its US$22 billion international portfolio, centred on its 75% stake in Iraq’s West Qurna-2 oilfield. A proposed sale to Gunvor had already collapsed after a 6 November U.S. Treasury statement that the company would “never get a licence” while the conflict continues. The U.S. has now authorised Lukoil to engage alternative bidders until 13 December 2025, with Chevron, ExxonMobil, ADNOC and private-equity firms reportedly evaluating offers. On the same day, Lukoil dissolved the supervisory board of Lukoil International GmbH, leaving managing director Alexander Matytsyn as sole executive. Its trading arm has reduced staff and wound down activity, and Iraq has frozen Lukoil’s revenue share from West Qurna-2.

SERBIA

• On 29 October 2025, the U.S. lifted sanctions previously imposed (in 2022) on Milorad Dodik, the former president of Republika Srpska, along with related designations on his family members and a media outlet. The original measures had alleged corruption and efforts to destabilise Bosnia’s post-Dayton political structure. Treasury did not specify its rationale for the reversal, while Dodik publicly called the decision a “moral vindication.”

SYRIA

• On 6 November 2025, the U.S. secured near-unanimous support at the U.N. Security Council to lift sanctions on Syria’s interim president Ahmad al-Sharaa and Interior Minister Anas Hasan Khattab. The timing aligned with al-Sharaa’s 10 November visit to Washington, the first by a Syrian president since 1946. The U.S. framed the vote as recognizing Syria’s “new era” following the fall of Bashar al-Assad in December 2024. Importantly, U.S. domestic sanctions under the Caesar Syria Civilian Protection Act (2019) remain fully in effect and require congressional action for repeal.

VENEZUELA

• On 24 November 2025, the U.S. designated the Venezuelan network known as the Cartel de los Soles as a Foreign Terrorist Organization, characterising the loosely structured group of senior military, intelligence and political figures as engaged in terrorism and narcotrafficking activities that threaten U.S. national security. The designation triggers an asset freeze over any U.S.-linked property, prohibits entry into the United States, bars U.S. persons from dealings with the group, and exposes any actor providing “material support” to potential criminal liability. The move follows long-standing U.S. allegations that Nicolás Maduro and senior officials have used narcotics trafficking to consolidate power and destabilise the region, while Venezuela rejects the network’s existence and calls the designation politically motivated

GLOBAL REGULATIONS/TOOLS UPDATE: OFSI

OFSI UPDATES GUIDANCE ON DIVESTMENT LICENCES INVOLVING RUSSIAN INVESTORS

• On 18 November 2025, OFSI updated its general financial sanctions guidance to clarify the circumstances under which it may issue a divestment licence where a Russian divest investor is involved. Under the updated framework, a UK applicant may acquire an interest in a UK entity that is currently held by a designated person or by the Russian Government provided that the full consideration for the transaction consists solely of a transfer of funds to the designated person or the Russian Government, and additional conditions specified by OFSI are satisfied (e.g., transparency, valuation, reporting). Further guidance can be found here.

CORRESPONDENT BANKING – 2022 BLOCKED PAYMENTS

• On 5 November 2025, OFSI amended and extended the Correspondent Banking – 2022 Blocked Payments General Licence INT/2024/5394840, which permits UK financial institutions to process certain payments originally blocked in 2022 due to the involvement of Russian-designated banks in the payment chain. The update extends the licence’s validity to 7 November 2027 and introduces strengthened reporting obligations, requiring institutions to submit monthly returns to HM Treasury detailing any payments processed under the licence, including amounts, counterparties, payment routes and dates. The amendment also refines the definition of “Designated Credit or Financial Institution,” reinforcing the need for careful screening and documentation when assessing eligibility. For institutions with exposure to Russia-linked correspondent flows, the revised licence provides a continued legal mechanism to resolve legacy blocked payments, but raises the compliance bar through enhanced monitoring and reporting requirements. Further guidance can be found here.

CONTINUATION OF BUSINESS LUKOIL BULGARIA ENTITIES

• On 14 November 2025, OFSI issued a new Russia-related General Licence INT/2025/7895596, permitting the continued operation of specified Lukoil Bulgaria entities, framed as a transitional measure to safeguard regional energy stability. While narrow in scope, this GL is operationally important: it reflects the UK’s continued use of targeted flexibility within the Russia regime, ensuring that sanctions do not unintentionally disrupt European energy markets. It also has practical compliance implications for UK businesses more broadly, particularly banks, insurers, logistics providers and legal advisors, whose screening tools may flag Lukoil Bulgaria as a Russia-linked counterparty. The licence applies to acts otherwise prohibited by the Russia Regulations. This general licence is set to expire on 14 February 2026. Further guidance can be found here.

CONTINUATION OF BUSINESS LUKOIL INTERNATIONAL ENTITIES

• On 27 November 2025, OFSI published General Licence INT/2025/8031092 under the Russia (Sanctions) (EU Exit) Regulations 2019. The licence authorises the continuation of business operations with Lukoil International GmbH (the Vienna-based international arm of Lukoil) and its subsidiaries, activity that would otherwise be prohibited under the Russia sanctions regime.  Alongside the licence, OFSI published FAQ 174, confirming that it is aware of ongoing negotiations relating to the potential sale of PJSC Lukoil’s international assets. The General Licence is valid until 26 February 2026, after which OFSI will consider renewal in light of the progress of those negotiations. Further guidance can be found here.

DESIGNATION OF NEW IRISH REPUBLICAN ARMY (NEW IRA) AND SUSPECTED TERROR FACILITATOR

• On 6 November 2025, OFSI issued an asset freeze against the New Irish Republican Army and an asset freeze and director disqualification against Kieran Gallagher under the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019. This matches the UK’s dedication to stop terrorist financing. Lucy Rigby MP KC, Economic Secretary to the Treasury said this in relation to the sanctions:

• “These designations reflect this government’s continued commitment to protecting the peaceful consensus of the people of Northern Ireland, and to upholding the principles of the Good Friday Agreement in support of the UK’s wider efforts to protect national security for all citizens.”

GLOBAL REGULATIONS/TOOLS UPDATE: OFAC

OFAC PUBLISHES NEW RUSSIA-RELATED GENERAL LICENSES FOR CPC OPERATIONS, LUKOIL ENTITIES, AND DIVESTMENT ACTIVITIES

• On 14 November 2025, OFAC issued a package of Russia-related general licenses providing narrowly scoped authorisations for otherwise prohibited activities. General License 124B renews and expands authorisations for certain petroleum-related services connected to the Caspian Pipeline Consortium (CPC), Tengizchevroil, and Karachaganak Petroleum Operating projects, ensuring continued operational and safety-critical activities. General License 128A authorises limited transactions involving Lukoil-branded retail service stations located outside the Russian Federation, including routine operations and maintenance. General License 130 permits specific transactions involving designated Lukoil Bulgaria entities to support continuity of fuel supply and essential operations. General License 131 authorises transactions necessary to negotiate and enter into contingent contracts for the divestment of Lukoil International GmbH, as well as activities required for the maintenance and orderly wind-down of the company and its subsidiaries. These measures, published at [here], form part of OFAC’s targeted approach to preserving energy market stability while maintaining core Russia sanctions restriction. Further guidance can be found here

U.S. TREASURY IMPOSES $4.7 MILLION PENALTY AGAINST REAL ESTATE INVESTOR FOR DEALINGS IN BLOCKED RUSSIAN PROPERTY

• On 24 November 2025, OFAC announced a $4.7 million civil penalty against a U.S. real-estate investor who, through an Atlanta-based investment company, willfully mortgaged, renovated, and sold a residential property owned by a Russia-designated individual. OFAC found that the investor proceeded despite clear notice that the property was blocked, including a cease-and-desist letter and a subpoena, resulting in what OFAC characterised as an egregious violation of U.S. sanctions. Treasury highlighted that this is the largest sanctions penalty imposed on an individual to date, underscoring that U.S. persons, including real-estate professionals and private investors, must ensure strict compliance when dealing with property potentially linked to sanctioned parties. Further guidance can be found here.

RECENT CASE STUDY BY HMRC

• On 3 November 2025, HMRC published a case study detailing a £1.1 million compound settlement paid by a UK exporter for making goods available to Russia in breach of the Russia (Sanctions) (EU Exit) Regulations 2019. The case underscores the risks of exporting to third countries where goods may ultimately reach Russia and highlights the importance of understanding when an activity is considered “connected with Russia.” HMRC also clarified the scope of the “making available” prohibitions, reminding firms that sanctions liability can arise even without direct exports to Russia if goods are supplied to Russian-owned or Russia-linked counterparties. Further guidance can be found here.

IN CLOSING

MR’s monthly sanctions update will continue to monitor these developments, providing timely insight into new designations, regulatory reforms, and key enforcement trends shaping the global compliance landscape.