Weekly Sanctions Update: August 25, 2025

The Sanctions Update is compiled by Steptoe's International Trade and Regulatory Compliance team and Steptoe's Strategic Risk team. You can subscribe to receive the Sanctions Update every week through Steptoe's International Compliance Blog and Stepwise Risk Outlook publication home pages.

For more information or advice on any of the developments discussed below, please contact a member of our sanctions team here.

US Developments

Trump Meets with Zelensky and European Leaders Following Summit with Putin

On August 18, President Trump met with Ukrainian President Volodymyr Zelensky and multiple European leaders, including the heads of state from the United Kingdom, France, Germany, Italy, and Finland, as well as NATO Secretary General Mark Rutte and European Commission President Ursula von der Leyen, to discuss the terms of a peace deal in Ukraine. The meeting followed President Trump's one-day summit with Russian President Vladimir Putin in Alaska, which we have previously written on. The meeting with Zelensky and the other EU leaders did not result in any clear decisions with respect to additional sanctions targeting Russia, which President Trump had previously threatened but seemingly put on hold following his meeting with President Putin.

Against the backdrop of these talks, some US lawmakers have continued to criticize the Trump administration for not increasing pressure on the Kremlin through more stringent sanctions and export controls. Senator Elizabeth Warren (D-MA), the Ranking Member of the Senate Banking Committee, released a statement asserting that President Trump "has failed to recognize" that the US has "cards to play" in peace negotiations. Senator Jeanne Shaheen (D-NH), the Ranking Member of the Senate Foreign Relations Committee, similarly warned the Trump administration that, if it "can't hold Putin's feet to the fire, Congress will act" by passing the Sanctioning Russia Act of 2025, a sweeping sanctions- and tariff-related bill that enjoys strong bipartisan support, but has been placed on hold by Republican leadership as Trump pursues further negotiations with Russia.

Trump Signs Bipartisan Export Control Transparency Law

On August 19, President Trump signed the bipartisan "Maintaining American Superiority by Improving Export Control Transparency Act." The Act requires the Secretary of Commerce to annually submit a report to Congress on end-use checks undertaken by the Bureau of Industry and Security (BIS) and license applications or other requests for authorization submitted to BIS for the export, re-export, release, and in-country transfer of items that are subject to the Export Administration Regulations to an entity that is on the Entity List or the Military End-User List and located in an arms embargoed country, including China.

For license applications or requests for authorization, the report must include (i) the name of each applicant or requestor; (ii) a brief description of the related item, including the Export Control Classification Number (ECCN) and the reason for control; (iii) the name of the end-user; (iv) the end-user's location; (v) a value estimate of the sale; and (vi) the decision with respect to the application or request. For end-use checks, the report must include the date, location, and result of the end-use check. The report must also include aggregated statistics on all license applications and other requests for authorization. Other than the aggregated statistics, the contents of the report are exempt from public disclosure.

The Act was introduced by Sen. Jim Banks (R-IN) and Sen. Mark Warner (D-VA), who expressed concern that BIS "lack[ed] transparency" in its licensing decisions and "rarely enforce[d] export controls on sensitive technology sales to China." The Act garnered strong bipartisan support and passed the House through a voice vote and the Senate through unanimous consent.

OFAC Increases Pressure on Iranian Oil Networks

On August 21, the Department of the Treasury's Office of Foreign Assets Control (OFAC) announced that it was sanctioning individuals and entities across multiple jurisdictions for their alleged involvement in Iranian oil exports, including via an illicit network purportedly run by Antonios Margaritis. Concurrently, the State Department announced that it was imposing sanctions on two China-based crude oil and petroleum products terminal and storage operators for their alleged role in trading Iranian oil. This is the fourth round of sanctions targeting China-based terminal operators.

The US continues to apply pressure on Iran in accordance with President Trump's National Security Presidential Memorandum 2 (NSPM-2). These sanctions, in particular, follow a recent trend of sanctioning individuals and entities allegedly connected with Iranian oil networks. They also come as Iran claims the moment for "effective" nuclear talks with the US has not arrived, and as the United Kingdom, France, and Germany (the "E3") consider triggering the "snapback" mechanism to reinstate United Nations (UN) sanctions on Iran over its nuclear program.

Treasury Sanctions Costa Rican Narcotraffickers

OFAC has designated four Costa Rican nationals and two Costa Rica-based entities for their alleged involvement in narcotics trafficking and money laundering. John Hurley, the recently confirmed Under Secretary for Terrorism and Financial Intelligence, stated that Treasury will "continue to use all available tools to disrupt narcotrafficking organizations that threaten the safety of Americans," including coordination with partners in third countries.

OFAC's designation of Costa Rican individuals and entities was done in collaboration with the Drug Enforcement Administration's (DEA) San José Country Office, Dallas Field Office, and Costa Rica's Office of the Attorney General. It was the first public collaboration with Costa Rican authorities since the November 15, 2023 designation of Costa Rican narcotics trafficker Gilbert Hernan de Los Angeles Bell Fernandez.

State Department Sanctions ICC Judges and Prosecutors

The Department of State designated two International Criminal Court (ICC) judges—Kimberly Prost and Nicolas Yann Guillou—and two ICC prosecutors—Nazhat Shameem Khan and Mame Mandiaye Niang—for allegedly "directly engag[ing]" in efforts to investigate, arrest, detain, or prosecute US or Israeli nationals without the consent of either nation.

Specifically, the Department of State sanctioned Prost for ruling to authorize the ICC's investigation into US personnel in Afghanistan; Guillou for ruling to authorize the ICC's issuance of arrest warrants for Israeli Prime Minister Bejamin Netanyahu and former Minister of Defense Yoav Gallant; and Shameem Khan and Niang for "continuing to support" ICC actions against Israel, including upholding the ICC's aforementioned arrest warrants since they assumed leadership for the ICC's Office of the Prosecutor (OTP).

These designations follow similar sanctions imposed on ICC personnel on June 5, as well as on the United Nations Human Rights Council "Special Rapporteur on the Situation of Human Rights in the Palestinian Territories Occupied since 1967," on July 9.

UK Developments

UK Sanctions Financial and Crypto Networks Exploited by Russia

OFSI has designated three individuals and five entities involved in sanctions circumvention, including through the use of cryptocurrencies, under the Russia sanctions regime. According to a UK government press release, the three individuals are alleged to be directors of companies involved in the Russian financial services sector, or involved in the destabilisation of Ukraine by facilitating Russian payments for military goods. These individuals are: (i) Leonid Shumakov (director of A7A5, the company behind a Russian ruble-backed token), (ii) Kantemir Kaparbekovich Chalbayev (director of Kyrgyzstan-based Capital Bank); and (iii) Zhanyshbek Uulu Nazarbek. One of the newly sanctioned entities, Altair Holding SA, is registered in Luxembourg and is designated for its alleged involvement in the Russian financial services sector. The remaining four entities are registered in Kyrgyzstan and again are said to be involved in the Russian financial services sector. These four entities are: (i) CJSC Tengricoin, (ii) Grinex LLC, (iii) Capital Bank of Central Asia; and (iv) Old Vector LLC. Both Grinex LLC and Old Vector LLC also were designated by the US for their affiliation with Russian crypto exchange, Garantex Europe OU. According to UK Sanctions Minister, Stephen Doughty, these new sanctions demonstrate the UK's commitment to cracking down on the international sanctions evasion mechanisms that are helping to fund Russia's invasion of Ukraine.

UK Sanctions Iran's Network of Destabilising Activity

OFSI has designated one individual and four entities whose revenue supports Iran's destabilising activities under the Iran sanctions regime. According to a UK government press release, the individual and four entities are alleged to be a part of a trading network that enables Iran to support proxies and partners across the Middle East region and facilitate state threats on UK soil. Iranian oil magnate, Hossein Shamkhani, has been sanctioned by the UK government and is now subject to an asset freeze, director disqualification sanctions and a UK travel ban. The following entities also are subject to an asset freeze and director disqualification sanctions: (i) Petrochemical Commercial Company, (ii) Admiral Group, (iii) Ocean Leonid Investments; and (iv) Milavous Group. According to UK Minister for the Middle East, Hamish Falconer, these designations demonstrate the UK's commitment to working against those who operate on behalf of Iran and fuel its attempts to undermine stability in the Middle East and global security.

UK Adds New FAQs to Clarify Use of Russia General Licence for Brokerage Accounts Held at Designated Brokerage Firms

OFSI has issued FAQs 162, 163, and 164, addressing the scope of General Licence INT/2025/6641960 ("Brokerage General Licence"). The FAQs clarify that assets held in, by, or via the UK sanctioned National Settlement Depository ("NSD") are not covered by the Brokerage General Licence and do not authorise the NSD to transfer funds that it holds direct or indirect custody over. OFSI also clarifies that it does not consider a licence necessary to terminate a brokerage relationship between a non-designated client and a UK designated broker once the client's funds are removed. The new FAQs respond to questions received by OFSI concerning the scope of the Brokerage General Licence and provide welcome guidance on OFSI's interpretation of the conduct permitted under it.

EU Developments

EU's Strategy for Russian Energy in the 19th Sanctions Package

As the European Union is preparing to unveil its 19th sanctions package against Russia next month, EU officials have signaled that options for significant new measures targeting the oil sector are limited.

Building on its REPowerEU roadmap, which aims to phase out Russian gas and oil imports by 2027, the EU has already taken major steps to reduce reliance on Russian energy. The recently adopted 18th sanctions package included a ban on imports of refined petroleum products derived from Russian crude oil and a complete transaction ban on Nord Stream 1 and 2 pipelines. These measures raise questions about what additional steps the EU can take to exert further pressure on Russia.

Specialist reports indicate that the upcoming 19th sanctions package will prioritize strengthening existing measures rather than introducing new wide-ranging restrictions. Several EU officials have indicated that one likely action could involve expanding the blacklist of Russian shadow fleet vessels involved in sanctions circumvention.

Asia-Pacific Developments

Japan Strengthens Support for Ukraine Through Sanctions and Security Commitments

On August 19, 2025, Japanese Prime Minister Shigeru Ishiba reportedly signaled Japan's increased commitment to Ukraine's security by announcing plans to "thoroughly discuss what our nation can and should do." Central to Japan's efforts has been the implementation of robust sanctions measures against Russia. Since the Russian invasion in 2022, Japan has imposed several measures, including freezing Russian sovereign assets, sanctioning private entities that finance Russia's military activities, and taking steps to reduce reliance on Russian energy imports.

SeaLead Denies Iranian Links Amid Sanctions Crackdown

On August 22, 2025, Singapore-based container shipping group SeaLead reportedly denied any connections to the Iranian regime after being drawn into a sweeping US sanctions package that targets a network allegedly linked to sanctions busting and financial flows into Iran. Following the US Treasury's decision to impose sanctions on 16 vessels chartered by SeaLead last month, the company has begun terminating its charter agreements and unloading affected ships at suitable ports. While SeaLead itself has not been sanctioned, the ships targeted were reportedly connected to a network overseen by Mohammad Hossein Shamkhani, the son of Ali Shamkhani, a prominent Iranian political adviser. SeaLead emphasized its stringent compliance measures, citing "regular [know your customer checks], sanctions screening, and due diligence on vessel owners prior to entering into any charter arragenments." The group disavowed any ongoing ties with its ex-founder Jaideep Saigal, who has been linked to Draco Buren, a technical management firm alleged to have ties to the Hossein network. Additionally, SeaLead stated that it had never engaged in transporting goods for the Iranian government and maintained no direct or indirect connections to entities associated with Iran.

Russian LNG Tankers Depart Arctic Facility Following Sanctions and Compliance Concerns

Recently, several liquefied natural gas (LNG) tankers reportedly departed from Russia's Arctic LNG 2 facility, which is sanctioned by the US. The vessels Iris and Voskhod began moving toward North Asia on August 15 after weeks of inactivity, joined by two additional tankers last week, according to Bloomberg. US sanctions are creating significant hurdles for Russia's ability to secure buyers, while the facility reportedly relies on a fleet of ice-capable vessels—some with deliberately obscured ownership through frequent management shifts—to circumvent restrictions. This situation serves as a reminder of the complexities and risks surrounding global sanctions compliance. Gaps in enforcement can lead to both legal liabilities and financial repercussions.