Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today designated Iranian liquified petroleum gas (LPG) trader Seyed Asadoollah Emamjomeh, his son Meisam Emamjomeh, and their global network of companies and vessels for facilitating the export of Iranian LPG and crude oil in violation of U.S. sanctions.

The United States on April 15 lifted sanctions imposed in January on the head of Hungarian Prime Minister Viktor Orban's cabinet, Antal Rogan, over accusations of corruption and cronyism. Rogan was sanctioned January 7th for public corruption which "is affecting Hungary's decision-making on issues that impact the security of the United States of America and our allies."

On April 16, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released updated guidance for the maritime sector titled Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion. In coordination with the advisory, OFAC also designated seven entities and five vessels allegedly engaged in Iranian petroleum and petrochemical sales. One of the most prominent targets is a Chinese “teapot” refinery, sanctioned for purchasing over $1 billion worth of Iranian crude.

The Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions against five Iran-based entities and one individual for providing support to Iran’s nuclear program. Separately, OFAC sanctioned drug trafficker Jesus Alfredo Beltran Guzman, known as “El Mochomito.”

The U.S. Department of Justice’s Final Rule restricting the export of sensitive U.S. data to foreign entities took effect April 8, 2025. The rule targets data transactions involving individuals or entities linked to designated “countries of concern”—including China (with Hong Kong and Macau), Russia, Iran, North Korea, Cuba, and Venezuela.

A bipartisan group of U.S. lawmakers has called on the Departments of State and Treasury to revise longstanding sanctions on Syria, warning that existing restrictions—imposed over a decade ago—are impeding reconstruction, destabilizing the region, and potentially undermining U.S. national security objectives.

The U.S. Departments of Justice and Treasury took coordinated action to disrupt an Iranian procurement network that illicitly acquired U.S.-origin technology to support Iran’s drone program and its military-industrial complex. April 1, 2025, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on eight individuals and six entities across Iran, the United Arab Emirates (UAE), and the People’s Republic of China (PRC) for their roles in acquiring components for unmanned aerial vehicles (UAVs) used by Iran’s military.

A civil forfeiture complaint was filed March 26 in the U.S. District Court for the District of Columbia alleging that $47 million in proceeds from the sale of nearly one million barrels of Iranian petroleum is forfeitable as property of, or affording a person a source of influence over, the Islamic Revolutionary Guard Corps (IRGC) or its Qods Force (IRGC-QF), designated Foreign Terrorist Organizations (FTOs).

Treasury’s Office of Foreign Assets Control (OFAC) today designated five individuals and three companies involved in a Lebanon-based sanctions evasion network that supports Hizballah’s finance operations. The designated entities are tied to a network managing commercial enterprises and oil smuggling operations in coordination with Iran’s Islamic Revolutionary Guard Corps–Qods Force (IRGC-QF) to fund Hizballah’s terrorist activities.

President Trump signed an executive order Tuesday authorizing a 25 percent tariff on imports from countries that continue to import Venezuelan oil, either directly or indirectly. The proposed levies would increase the cost of goods imported from China to nearly 50 percent.

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a final rule March 25th,  amending the Export Administration Regulations (EAR) by adding 80 foreign entities to the Entity List. Sales to listed entities are presumed denied and require an export license. The new restrictions, while not altering the legal framework of the Export Administration Regulations (EAR), appear to chart a trajectory toward broader control measures.

The Trump Administration exacted retribution on former Argentine President Cristina Elisabet Fernández de Kirchner and her former Planning Minister Julio Miguel De Vido, "for their involvement in significant corruption during their time in public office." The two have been banned from travel to the United States.  "These designations reaffirm our commitment to counter global corruption, including at the highest levels of government," said Secretary of State Marco Rubio.

The Office of Foreign Assets Control (OFAC) has finalized a rule extending the recordkeeping period under 31 CFR parts 501 and 515 from five to ten years. This change aligns with the amended statute of limitations for civil and criminal violations under the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA), as enacted in Section 3111 of the 21st Century Peace through Strength Act.

In a striking move, the United States took yet another step back from Ukraine and its allies by abstaining from a key vote at the International Labour Organization (ILO). This is the second such abstention in Geneva, following a similar move at the World Trade Organization last month. At the UN General Assembly, the US went even further, voting with North Korea and other Russian allies against a western-backed resolution denouncing the invasion and tabling a more conciliatory text, raising concerns that Ukraine may no longer rely on the US as a leading force to plead its cause at multilateral bodies.

The United States has filed a civil forfeiture complaint in the Southern District of Florida against a Dassault Falcon 900 EX aircraft, tail number T7-ESPRT, used by Nicolás Maduro Moros and his regime in violation of U.S. sanctions and export laws. The aircraft was seized last year in the Dominican Republic at the request of the U.S.

Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned the Foxtrot Network, a Sweden-based transnational criminal organization (TCO), along with its fugitive leader, Rawa Majid. The network, involved in drug trafficking and violent crimes across Europe, orchestrated an attack on the Israeli Embassy in Stockholm in January 2024 on behalf of Iran.

Despite the Justice Department's dismantling of inter-agency cooperation to enforce sanctions and combat corruption, cases begun before the change of regime continue to wend their way though the courts. March 10, The U.S. District Court for the Southern District of New York granted the government’s motion to strike the ownership claim of Eduard Khudainatov and Millemarin Investments Ltd. concerning the Motor Yacht Amadea.

President Donald Trump has issued contradictory signals regarding sanctions on Russia, simultaneously threatening punitive economic measures while reportedly exploring avenues for relief. On Friday, Trump warned of large-scale banking sanctions, tariffs, and additional economic penalties on Moscow in an effort to push Russia and Ukraine toward a peace settlement. Despite his threats of increased economic pressure on Russia, reports indicate that the Trump administration is simultaneously considering sanction relief.

In a further sign of the Trump White House's rapprochement with the Kremlin, The Treasury and Department of State have been ordered to compile a  list of sanctions to be lifted. Europe may soon find itself enforcing measures against Moscow alone.

Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions on seven senior members of Ansarallah, commonly known as the Houthis, for their roles in smuggling military-grade weapons into Houthi-controlled areas of Yemen and negotiating arms procurement deals with Russia. Additionally, OFAC has designated a Houthi-affiliated operative and his company for recruiting Yemeni civilians to fight for Russia in Ukraine, generating revenue to support Houthi militant operations.

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