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Last Week's Major Developments in Sanctions - February 24th, 2025, to February 28th, 2025

Monday, February 24
  • On the third anniversary of the Russia's second invasion of Ukraine, the European Union and the United Kingdom imposed additional sanctions against Russia.

    • The European Union unveiled its 16th sanctions package that consists of five Council's Decisions: (press release)

      • Council Decision (CFSP) 2025/388 of 24 February 2025 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (here)

        • Imposing asset-freezing sanctions against 48 persons and 35 entities, including one entity in China and one in Türkiye;

        • Introducing two further designation grounds.

      • Council Decision (CFSP) 2025/391 of 24 February 2025 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (here)

        • Expanding the designation grounds to allow for the designations of natural or legal persons supporting, materially or financially, or benefiting from, the military and industrial complex of Belarus;

        • Expanding the export restrictions on certain listed entities;

        • Expanding the list of items that may be exported to Belarus;

        • Adding new categories of services that may not be provided to Belarusian persons including construction, architectural and engineering services, legal advisory services and IT consultancy services; and

        • Introducing or expanding many restrictions against Belarus.

      • Council Decision (CFSP) 2025/394 of 24 February 2025 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (here)

        • Imposing additional bans against Russian media operations in the EU;

        • Expanded export controls by adding new items to the list of items that are subject to restrictions, and identifying 53 entities that are subject to additional restrictions; and

        • Adding or revising other restrictions.

      • Council Decision (CFSP) 2025/396 of 24 February 2025 amending Decision (CFSP) 2022/266 concerning restrictive measures in response to the illegal recognition, occupation or annexation by the Russian Federation of certain non-government controlled areas of Ukraine (here):

        • Expanding the restrictions related to Donetsk, Kherson, Luhansk and Zaporizhzhia regions.

      • Council Decision (CFSP) 2025/397 of 24 February 2025 amending Decision 2014/386/CFSP concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol (here):

        • Expanding the restrictions related to Crimea and Sevastopol.

    • The United Kingdom imposed asset-freezing sanctions against 34 individuals and 33 entities and added 40 new ship specifications under the Russia sanctions regime. Perhaps the most notable designation was the designation of Keramat Bank in Kyrgyzstan. (Here, and press release)

    • Other countries including Canada and Australia also introduced new sanctions on the third anniversary. The United States did not impose any sanctions for the third anniversary.

  • The EU Council adopted the first round of Syria sanctions relaxations. (Decision, and press release) Among other things, the Decision included delisting of Agricultural Cooperative Bank, Industrial Bank, Popular Credit Bank, Saving Bank, and Syrian Arab Airlines.

  • The Department of State and OFAC imposed blocking sanctions against five individuals and 17 entities and identified 13 vessels as blocked property, across multiple jurisdictions, for their involvement in Iran’s oil industry. (Here, the Department of the Treasury's press release, the Department of State's press release, and the Department of State's fact sheet)


Tuesday, February 25
  • The United Kingdom updated its "countering Russian sanctions evasion - guidance for exporters." (Here)

  • A U.S. person was sentenced to five years in prison for violating the U.S. sanctions against Iran. The convict conspired with two Iranian companies located in Tehran, Iran, to illegally export U.S.-manufactured industrial equipment for use in Iran’s oil, gas, and petrochemical industries. (Here)


Wednesday, February 26

Thursday, February 27
  • DBT and OTSI published an updated guidance on how to apply for a license to provide sanctioned trade services. (Here)


Friday, February 28
  • There was no major development on this day.


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