In today’s fast-paced global market, staying current on sanctions updates is critical for businesses engaged in cross-border payments. Recent developments from U.S. and U.K. authorities—as well as actions by the European Union—underscore the dynamic nature of the regulatory landscape. Below we break down the key updates announced in January 2025 and what they mean for your business operations.
U.S. Treasury expands authorizations for activities and transactions in Syria
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 24, expanding authorizations for activities and transactions in Syria, effective December 8, 2024. This action underscores the United States’ commitment to ensuring that U.S. sanctions do not impede activities to meet basic human needs or humanitarian assistance.
This authorization is in effect for six months, as the U.S. government continues to monitor the situation. GL 24 helps ensure that sanctions do not impede essential services and continuity of governance functions across Syria, including the provision of electricity, energy, water, and sanitation. Get all the details in the official announcement.
UK sanctions guidance: Countering evasion and no-Russia clause
The Office of Trade Sanctions Implementation (OTSI) has published two documents to aid compliance with UK sanctions against Russia. “Countering Russian Sanctions Evasion” guides exporters and manufacturers in identifying circumvention tactics, recognizing high-risk goods, spotting red flags, and enhancing due diligence to aid businesses in managing their risk and meeting their compliance obligations.
The UK government has also issued a “No-Russia Clause” which assists exporters in tailoring contracts to include provisions that prevent re-export to Russia. Prohibitions in the UK’s Russia sanctions regime also typically prohibit export ‘for use in’ Russia. Even if the immediate destination of the relevant goods is not Russia, the prohibition may still apply. UK’s trade sanctions on Russia seek to deny Russia access to the goods, technologies, services, and revenue necessary to pursue its illegal war.
Direct trade between the UK and Russia has fallen heavily since sanctions were introduced. However, Russia has been seeking to procure goods and services via indirect routes and complex supply chains. This heightens the risk of circumvention of trade sanctions, and diversion of goods to Russia.
US Treasury sanctions Russia’s energy sector
The U.S. Department of the Treasury (OFAC) and the UK’s Office of Financial Sanctions Implementation (OFSI) have announced sweeping sanctions targeting Russia’s energy sector to diminish revenue for its war against Ukraine. The sanctions, fulfilling a G7 commitment, impact major oil producers Gazprom Neft and Surgutneftegas, over 180 vessels (including those in the “shadow fleet”), oil traders, service providers, and energy officials.
A new determination authorizes sanctions on anyone operating in Russia’s energy sector, increasing risks for those involved in the Russian oil trade. The UK is joining the US in sanctioning major Russian oil producers. Treasury also issued amended General License 8L, which authorizes certain wind-down transactions related to energy through March 12, 2025.
Strengthening collaboration on economic sanctions
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury and the Office of Financial Sanctions Implementation (OFSI) of the UK have established a Memorandum of Understanding to enhance their collaborative relationship. This arrangement aims to advance their shared goal of enforcing and promoting compliance with economic and trade sanctions.
The Memorandum facilitates the sharing of relevant information, coordination of investigations, personnel training, and discussions on regulatory expectations. It outlines terms and conditions for cooperation, ensuring compliance with applicable laws and regulations. Information sharing will adhere to strict controls and safeguards, with mechanisms for handling unauthorized disclosures. The agreement also establishes contact points for efficient communication and designates coordinators to oversee its implementation.
While not legally binding, the Memorandum signifies a commitment to cooperation, allowing for amendments, suspension, or termination by either participant.
Family International Realty LLC fined for sanctions evasion
OFAC has announced that Family International Realty LLC and its owner have agreed to pay $1,076,923 to settle potential civil liability for violating Ukraine-/Russia-related sanctions. Between 2018 and 2023, they executed a scheme to evade sanctions by transferring ownership of luxury condominiums owned by sanctioned Russian oligarchs Valeri Abramov and Viktor Perevalov to family members and shell companies. This was done to obscure the oligarchs’ interests and facilitate rentals and sales, generating approximately $182,442 in commissions and reimbursements for the company. The settlement reflects that the violations were egregious and not self-disclosed, also considering the owner’s resolution of related criminal charges.
Haas Automation settles with OFAC for sanctions violations
Haas Automation, Inc. has agreed to pay $1,044,781 to settle potential civil liability for 21 apparent violations of Ukraine-/Russia-related sanctions. Between December 2019 and March 2022, Haas indirectly supplied a computer numerical control (CNC) machine, spare parts, and authorization codes to blocked Russian entities through its Russian distributor, Abamet Management Limited.
The U.S. Office of Foreign Assets Control (OFAC) determined that Haas did not voluntarily disclose the violations and that eight of them were egregious. OFAC considered Haas’s remedial efforts and cooperation as mitigating factors. Haas is also settling with the Bureau of Industry and Security (BIS) for $1,500,000. Further details are available in the enforcement release.
Executive Order 14148: Rescinding prior actions
On January 24, President Trump signed a new Executive Order (E.O.), “Initial Rescissions Of Harmful Executive Orders And Actions,” which, among other actions, revoked E.O. 14115, “Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank.” To implement the President’s revocation of E.O. 14115, OFAC removed the West Bank-Related Sanctions program from its website and removed all persons designated under E.O. 14115 from the Specially Designated Nationals and Blocked Persons List (SDN List). All property and interests in property blocked under E.O. 14115 are now unblocked.
EU prolongs economic sanctions against Russia
The Council of the European Union has extended its economic sanctions targeting specific sectors of the Russian economy for another six months, lasting until July 31, 2025. These measures, initially introduced in 2014 in response to Russia’s actions in Ukraine, were significantly expanded following Russia’s full-scale invasion in February 2022. The sanctions aim to weaken Russia’s ability to finance the war and apply pressure to change its policies. They encompass restrictions on trade, finance, technology, and dual-use goods. The EU remains steadfast in its condemnation of Russia’s aggression and unwavering support for Ukraine’s sovereignty and territorial integrity. Read the full announcement for more detail.
Navigating the latest sanctions updates in cross-border payments
Staying ahead of sanctions updates isn’t just about avoiding penalties, it’s about safeguarding your business reputation and ensuring seamless international operations. As regulatory landscapes evolve, proactive compliance becomes an essential element of strategic growth.
In an era of rapid regulatory change, your ability to adapt and stay informed is key to maintaining a competitive edge and protecting your bottom line. For companies navigating cross-border payments, these updates serve as a crucial reminder to:
- Enhance compliance frameworks:
Regularly update your internal policies and due diligence processes considering new sanctions guidance and enforcement actions. - Invest in training:
Ensure that your teams are well-versed in the latest regulatory changes. Training can help identify red flags and prevent inadvertent sanctions breaches. - Leverage technology:
Utilize advanced compliance tools to monitor transactions, screen counterparties, and flag any activities that may fall under evolving sanctions regimes. - Maintain open channels:
Engage with legal and regulatory experts to continuously assess your exposure and adapt to the shifting sanctions landscape.
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