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Last Week's Major Developments in Sanctions - March 10th, 2025, to March 14th, 2025

Monday, March 10

  • There was no major development on this day.


Tuesday, March 11

  • The United Kingdom's the Export Control Joint Unit (ECJU) published a notice informing the public of the upcoming updates to the UK strategic export control list. (Here)

  • In line with the new U.S. administration's policy to combat international cartels, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) that requires all money services businesses (MSBs) located in 30 ZIP codes across California and Texas near the southwest border to file Currency Transaction Reports (CTRs) with FinCEN at a $200 threshold, in connection with cash transactions. (Here)


Wednesday, March 12

  • OFAC imposed blocking sanctions against one individual and a Sweden-based organization with alleged ties to Iran's government under its transnational criminal organizations sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFSI updated its guidance for High Value Dealers & Art Market Participants by adding a factsheet to the guidance and amending section 2.1 of the guidance for clarification. (Here)

  • OFSI published 13 new FAQs about relevant firms bringing the total number of OFSI's FAQs to 144. (Here) The new FAQs shed light on reporting obligations of certain relevant firms.


Thursday, March 13

Friday, March 14

  • OFSI issued General licence INT/2025/5886860, Petrol station payments for United Kingdom nationals in Kyrgyzstan and Tajikistan. (Here) It authorizes UK nationals to purchase petrol from a sanctioned person at any petrol station in Kyrgyzstan and Tajikistan that is either owned by such person or sells the sanctioned person's petrol, provided that the petrol is for that UK national’s personal vehicle.

  • The EU Council adopted a position that will impose tariffs on the remaining agricultural products from Russia and Belarus, as well as certain nitrogen-based fertilizers. (Here) This is an interesting use of a new tool of economic statecraft by the EU against Russia and Belarus.

  • OFSI published a disclosure about violations of UK sanctions by three charities that failed to respond to requests for information from OFSI. (Here) There was no monetary penalty assessed against those three charities.

  • EU Council extended Council Decision 2014/512/CFSP, which is one of the main decisions that imposes asset freeze sanctions against Russia, until 15 September 2025. (Press release)


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