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Last week's major developments in sanctions - January 6th, 2024, to January 10th, 2025

Monday, January 6

  • OFAC issued General License 24 under its Syria sanctions program to allow certain transactions that involve (i) governing institutions, (ii) certain energy-related transactions, and (iii) Central Bank of Syria provided transactions are personal remittances. (Here, and the Department of Treasury's press release) OFAC also published eight new FAQs in relation to General License 24.


Tuesday, January 7
Wednesday, January 8

  • OFSI imposed asset-freezing sanctions against an entity, Blood and Honour, under the country's autonomous counter terrorism sanctions program. (Here, and press release)

  • The President of the United State issued a new Executive Order (E.O.) amending E.O. 14033 with respect to the situation in the Western Balkans to add three new grounds for designations. (Here)


Thursday, January 9

  • There was no major development on this day.


Friday, January 10

  • OFSI imposed asset-freezing sanctions against sanctioned 15 new individuals associated with Nicolás Maduro’s regime. (Here, and press release)

  • OFSI also imposed asset-freezing sanctions against Gazprom Neft and PJSC Surgutneftegas, 2 Russian oil giants. (Here, and press release) Simultaneously, OFSI issued General Licence INT/2025/5635700 (authorizing certain transactions with Gazpromneft-Sakhalin LLC) and General Licence INT/2025/5635701 (authorizing winding

    down of positions involving the Gazprom Neft and PJSC Surgutneftegas or any entity owned or controlled by them).

  • The EU Council decided to prolong the restrictive measures in view of the situation in Venezuela for a further year, until 10 January 2026. Additionally, the Council has decided to impose asset-freezing sanctions against 15 additional individuals, which include members of the National Electoral Council of Venezuela, the judiciary, and the security forces. (Here)

  • OFAC imposed blocking sanctions against eight Venezuelan officials who lead key economic and security agencies in Venezuela. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • In concert with the UK, OFAC and the State Department unveiled a large sanctions package that imposed blocking sanctions on more than 200 entities and individuals involved in Russia’s energy sector and identified more than 180 vessels as blocked property. Furthermore, the Secretary of the Treasury issued two determinations to increase the pressure on the Russia's energy sector. First, a determination pursuant to E.O. 14024 that authorizes the imposition of sanctions on any person determined to operate or have operated in the energy sector of the Russian Federation economy. Second, a new determination pursuant to E.O. 14071 prohibiting the provision of U.S. petroleum services to persons located in the Russian Federation, cutting off Russia’s access to U.S. services related to the extraction and production of crude oil and other petroleum products. The prohibition takes effect beginning at 12:01 a.m. eastern standard time on February 27, 2025. Simultaneously, OFAC issued several licenses to mitigate the unintended effects of the new sanctions or to authorize wind down-related transactions. OFAC also published or updated several FAQs about this day's action.  (Here, the Department of the Treasury's press release, the Department of State's Fact Sheet, and the Department of State's press release) It is interesting that most of the designations as part of this action were also designated under EO13662, which under CAATSA, ties their delistings to the will of Congress.


Recommendation for the week
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