Sanctions Watch | Weekly Vol. 80

Sanctions Watch Vol 80

In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

1. OFAC Issues Russia-Related General Licenses 1B and 115

The U.S. government issued General License No. 1B, effective December 18, 2024, authorizing certain activities involving the Federal State Budgetary Institution Marine Rescue Service (MRS) under specified conditions. This license permits transactions prohibited by Executive Orders 14039 and 14024 or the Protecting Europe’s Energy Security Act (PEESA), provided they are unrelated to the Nord Stream 2 or TurkStream pipeline projects, including any successor projects. However, it excludes activities involving vessels listed as blocked property of MRS or entities with a 50% or greater MRS ownership, as well as transactions restricted under specific directives of E.O. 14024, such as those related to foreign financial institutions, Russia’s central financial authorities, and other statutory sanctions. General License No. 1A, dated August 20, 2021, is now superseded. These clarifications aim to maintain sanctions while allowing non-pipeline-related activities to proceed under strict compliance with U.S. regulations.

General License No. 115, issued under Executive Order 14024, authorizes certain transactions involving Gazprombank and its subsidiaries related to civil nuclear energy. These transactions are permitted until June 30, 2025, provided they solely maintain or support civil nuclear projects initiated before November 21, 2024. The license, however, excludes activities related to the Paks II nuclear power plant project and prohibits transactions involving the Central Bank of Russia, National Wealth Fund, or Ministry of Finance. Additionally, transactions barred under Directive 2 of E.O. 14024 or the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR Part 587) remain unauthorized, except those explicitly covered by the license. This measure aims to facilitate existing civil nuclear energy projects while upholding broader sanctions against Russia.

2. EU implements 15th sanctions package against Russia over ongoing illegal war in Ukraine

The European Commission has welcomed the adoption of the EU’s 15th sanctions package against Russia, focusing on tackling sanctions circumvention, targeting Russia’s shadow fleet, and imposing stricter measures on individuals and entities supporting Russia’s war against Ukraine. The package bans port access for 52 additional vessels engaged in high-risk shipping practices, enhancing maritime safety and reducing Russia’s ability to transport crude oil. It also imposes asset freezes, travel bans, and other restrictions on 84 entities and individuals, including Russian military-industrial companies and senior energy sector managers, and sanctions Chinese actors for the first time for aiding Russia’s war efforts.

Stricter export restrictions are applied to dual-use and advanced technology items, and 32 companies across several jurisdictions have been blacklisted. Measures to protect EU operators include prohibitions on enforcing certain Russian court rulings and extending derogations for EU companies to divest from Russia. In the financial sector, amendments provide safeguards for EU Central Securities Depositories (CSDs) to address retaliatory actions by Russia.

The sanctions aim to degrade Russia’s military and technological capabilities, cut its access to global markets, and impose economic costs, supporting the EU’s goal of achieving a just and lasting peace. Enhanced monitoring and international cooperation aim to combat circumvention efforts effectively.

3. EU imposes sanctions on additional Russian officials and cracks down on shadow oil and gas fleet

The European Council has extended its restrictive measures concerning the Democratic Republic of the Congo (DRC) until 12 December 2025, targeting 23 individuals and one entity. These sanctions address human rights violations, electoral obstruction, and actions fueling armed conflict, instability, and insecurity in the region.

The measures impose an asset freeze and prohibit EU citizens and companies from providing funds to the sanctioned individuals and entity. Additionally, affected individuals face travel bans, barring entry or transit through EU member states.

Initially adopted in 2016, these measures respond to grave human rights abuses and electoral disruptions in the DRC. In December 2022, the EU expanded the criteria to include sanctions against entities and individuals who support or benefit from armed conflict, instability, or the illicit exploitation and trade of natural resources in the region.

The EU maintains continuous monitoring of the DRC’s situation and retains the authority to renew or adjust the sanctions list based on on-the-ground developments.

These measures underscore the EU’s commitment to addressing the root causes of instability and promoting accountability in the DRC.

4. US Imposes New Sanctions Tied to Nord Stream 2 Pipeline

The United States has imposed new sanctions targeting Russia-based entities involved in the Nord Stream 2 gas pipeline, reinforcing its opposition to the project. The sanctions, announced by the U.S. State Department, include measures against previously sanctioned entities, new vessel owners, marine service providers, and the state-owned maritime rescue service. Notably, Nord Stream 2 AG, the pipeline operator, and a Russian insurer involved in the project were also targeted. Deputy spokesperson Vedant Patel emphasized U.S. commitment to preventing Russia from leveraging its energy resources for geopolitical influence.

Nord Stream 2, a pipeline built by Russia’s Gazprom to transport natural gas to Germany, faced sabotage on September 26, 2022, following Russia’s invasion of Ukraine. The pipeline’s destruction has been linked to geopolitical tensions, with Russia blaming the U.S., Britain, and Ukraine, claims those countries deny. Some Western officials suspect Russia of sabotaging its own infrastructure, a notion dismissed by President Vladimir Putin. Reports have also suggested prior intelligence of Ukrainian plans to attack the pipeline.

The U.S. has long opposed Nord Stream 2, citing its potential to bypass Ukraine, depriving it of crucial transit revenues and undermining its defense against Russian aggression. The latest sanctions reaffirm Washington’s stance against reviving the project.

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Sanctions Watch is a weekly recap of events and news related to sanctions around the world.