With the geopolitical landscape becoming increasingly volatile, cross-border payments and compliance teams must stay alert to evolving sanctions regimes and international enforcement measures. The recent issuance of National Security Presidential Memorandum NSPM-2 by U.S. President Donald Trump marks a renewed phase of strategic pressure on Iran. This directive, along with a wave of sanctions from OFAC, the EU, and the UK targeting Iran, Russia, and other global actors, signals heightened complexity and risk for businesses engaged in international transactions.
From expanded oil-related sanctions to new compliance tools, we explore recent sanctions announcements and their potential impact on businesses engaged in global commerce.
U.S. intensifies pressure on Iran with new national security directive
On February 4, 2025, President Donald Trump issued National Security Presidential Memorandum NSPM-2, directing a comprehensive strategy to exert maximum pressure on Iran. This directive aims to prevent Iran from acquiring nuclear weapons and intercontinental ballistic missiles, while neutralizing its terrorist networks, and countering its aggressive missile development and regional destabilization efforts. The memorandum instructs the Secretary of the Treasury to enforce stringent economic sanctions, targeting individuals and entities violating existing Iran-related sanctions. Additionally, the Secretary of State is tasked with modifying or rescinding sanctions waivers and leading diplomatic initiatives to isolate Iran internationally. The Attorney General is directed to pursue legal actions against Iran-sponsored networks and operatives within the United States.
OFAC takes aim at oil network generating funds for Iran
Following the NSP memo, The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned an international network facilitating the shipment of millions of barrels of Iranian crude oil, valued at hundreds of millions of dollars to China. This network operated on behalf of Iran’s Armed Forces General Staff (AFGS) and its front company, Sepehr Energy Jahan Nama Pars. The sanctions target entities and individuals across multiple jurisdictions, including China, India, and the United Arab Emirates, along with several vessels. Iran reportedly uses revenue from these oil sales to fund regional activities and support terrorist groups such as Hamas, the Houthis, and Hizballah. OFAC’s action aims to disrupt these financial channels and curb Iran’s destabilizing activities.
New File Finder tool on OFAC website simplifies sanctions search
OFAC has unveiled a new File Finder tool designed to make sanctions compliance more efficient by allowing users to search and explore the agency’s entire library of content quickly and easily. Users can filter results by document title, type, and contents, giving businesses faster access to critical regulatory materials. Searchable content includes general licenses, executive orders, federal register notices, legal guidance, and sanctions advisories, among others.
For businesses that operate across borders or handle cross-border payments, this tool is a valuable resource, empowering legal and compliance teams to quickly locate the latest updates, assess potential exposure, and make informed decisions with confidence.
EU implements 16th sanctions package against Russia amid ongoing war in Ukraine
Marking three years since Russia’s full-scale invasion of Ukraine, the European Union introduced its 16th package of sanctions aimed at debilitating Russia’s capacity to continue its aggression. This comprehensive set of measures targets critical sectors of the Russian economy, including a ban on imports of Russian aluminum, restrictions on approximately 70 vessels associated with circumventing oil and gas transport limitations, and sanctions against 13 Russian banks and three financial institutions.
Additionally, the EU imposed trade bans on specific chemicals and suspended broadcasting licenses for eight Russian media outlets. The package also includes further restrictive measures on Belarus mirroring the trade-related sanctions agreed against the Russian Federation, as well as other measures such as restrictions concerning the sale or provision of services and software, deposits and crypto-asset wallets, and transports. These actions underscore the EU’s unwavering commitment to supporting Ukraine’s sovereignty and applying sustained pressure on the Kremlin to cease its unlawful military operations.
This latest package increases compliance complexity and heightens operational risk for international businesses engaged in cross-border payments, particularly in sectors exposed to Russian supply chains or financial systems.
UK announces sweeping sanctions on Russia
Also marking the third anniversary of Russia’s invasion of Ukraine, the UK announced its largest sanctions package since 2022. The move targets over 100 individuals and entities fueling Russia’s war efforts, with a focus on disrupting military supply chains and cutting off revenue streams. Sanctions extend beyond Russia’s borders to firms in China, India, Turkey, and Central Asia supplying dual-use goods and electronics.
The UK also sanctioned North Korean defence officials for deploying forces to aid Russia, and 13 Russian entities involved in technology smuggling. For the first time, new powers were used to target foreign financial institutions, including Kyrgyzstan’s Keremet Bank. The action underscores the UK’s commitment to economic pressure as a tool to weaken Russia’s military capabilities and push toward peace. Businesses involved in cross-border payments should remain alert to evolving sanctions and compliance risks in this shifting geopolitical landscape.
EU eases sanctions on Syria to support economic recovery and humanitarian trade
The European Union (EU) has suspended several restrictive measures against Syria to support its political transition and economic recovery. The Council’s decision lifts sanctions in the energy (oil, gas, electricity) and transport sectors and removes five entities, including the Industrial Bank and Syrian Arab Airlines, from the EU’s asset freeze list. Additionally, certain banking restrictions have been eased to facilitate financial transactions related to these sectors and humanitarian efforts. The EU has also indefinitely extended the existing humanitarian exemption and introduced an exemption for personal use exports of luxury goods to Syria.
While these measures aim to foster engagement with Syria’s populace and businesses, the EU maintains sanctions related to the former Al-Assad regime, chemical weapons, and illicit drug trade, as well as restrictions on arms trade and dual-use goods.
Stay on top of evolving sanctions announcements
When it comes to economic sanctions, businesses engaged in cross-border payments must prioritize vigilance, agility, and informed compliance. From renewed U.S. pressure on Iran to sweeping EU and UK sanctions on Russia, and selective easing in Syria, the geopolitical landscape is in flux. With enforcement extending across borders and sectors, the cost of non-compliance is rising, and the need for clarity has never been greater. Talk Convera today about how we can support your compliance journey in an increasingly regulated world.
Want more insights on the topics shaping the future of cross-border payments? Tune in to Converge, with new episodes every Wednesday.
Plus, register for the Daily Market Update to get the latest currency news and FX analysis from our experts directly to your inbox.
