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Last week's major developments in sanctions - February 10th, 2025, to February 14th, 2025

Monday, February 10

  • There were no major developments on this day.


Tuesday, February 11
Wednesday, February 12

  • OFSI issued General Licence INT/2025/5810196 under its Syria sanctions regime authorizing the facilitation of payments related to specified humanitarian assistance activities. (Here) Keep in mind that this license has a notification to OFSI requirement.


Thursday, February 13

  • The United Kingdom's Minister of State sent a statement to the House of Commons on adapting the UK's Syria sanctions regime following the fall of Assad’s regime. Accordingly, the UK Government will introduce measures to amend the Syria sanctions regime, including easing restrictions in the energy, transport, and finance sectors to support humanitarian efforts and Syria’s reconstruction while maintaining asset freezes and travel bans on Assad and his associates. (Here)

  • After seven days from the issuance of the Executive Order that imposed sanctions on one of the International Criminal Court's prosecutors, OFAC updated its SDN list. (Here)

  • OFSI published its first Financial Services Threat Assessment. The assessment discusses threats and vulnerabilities relating to UK financial sanctions. The assessment

    • Listed the following six findings:

      • It is likely that some UK financial services firms, including non-bank payment

        service providers (NBPSPs), have not self-disclosed all suspected breaches to OFSI.

        The timely identification and reporting of suspected breaches varies across the

        sector and across different UK sanctions regimes.

      • It is highly likely that most non-compliance by UK financial services firms has

        occurred due to several common issues, including the improper maintenance of

        frozen assets and licence conditions breaches. These issues are relevant to

        compliance with all UK sanctions regimes.

      • It is almost certain that Russian designated persons (DPs) have turned to new

        professional and non-professional enablers in their attempts to breach UK

        financial sanctions prohibitions. OFSI has observed significantly increased enabler

        activity since 2023.

      • It is highly likely that enablers have made payments through NBPSPs relating

        to the maintenance of Russian DPs’ lifestyles and assets, including superyachts and

        UK residential properties.

      • It is likely a small number of enablers have attempted to front for Russian DPs

        and claim ownership of frozen assets.

      • Enablers have almost certainly used alternative payment methods, in particular

        crypto assets, to breach UK financial sanctions prohibitions on Russia.

    • Provides some case studies on how Russian designated persons attempted to evade the UK sanctions; and

    • Discusses the risk associated with intermediary countries in sanctions evasion. Specifically, the assessment mentions that "since February 2022, just over 25% of suspected breach reports received by OFSI from UK financial services firms have made reference to intermediary jurisdictions. The following jurisdictions feature most often: British Virgin Islands (BVI); the Republic of Cyprus; Switzerland; United Arab Emirates (UAE); Guernsey; Luxembourg; Austria; and Türkiye."

  • The United States' Department of Justice charged Flighttime Enterprises Inc., an American subsidiary of a Russian aircraft parts supplier, along with three of its current and former employees, with crimes related to a scheme to illegally export aircraft parts and components from the United States to Russia and Russian airline companies without the required licenses from the Department of Commerce. (Here)


Friday, February 14

  • OFSI imposed asset freezing sanctions against four individuals and two entities under its Russia sanctions regime. (Here, and press release)

 

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