Sanctions Watch | Weekly Vol. 84

Sanctions Watch Vol 84

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

1. OFAC Issues New Russia- and Ukraine-Related General Licenses: 122, 123, and 26A

The U.S. Department of the Treasury’s OFAC issued General License No. 122, authorizing the wind-down of transactions involving certain blocked Russian entities under E.O. 14024. Effective until March 1, 2025, it permits transactions with listed entities if payments to blocked persons are made to blocked accounts in compliance with Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587.

The U.S. Department of the Treasury’s OFAC issued General License No. 123, authorizing transactions related to divestment, transfer, and wind-down of derivative contracts involving Wafangdian Bearing Company Limited or its affiliates under E.O. 14024. Effective until March 1, 2025, the license permits limited operations while requiring compliance with Russian sanctions regulations.

The U.S. Department of the Treasury’s OFAC issued General License No. 26A under the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589. It permits specific transactions involving blocked entities listed in the annex, provided these transactions comply with applicable sanctions and directives. General License 26A supersedes General License 26, effective January 15, 2025.

2. OFAC Grants Temporary Authorization for Yemen Kuwait Bank Transactions Under General License 32

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued General License No. 32 under the Global Terrorism Sanctions Regulations (31 CFR part 594). The license permits the wind-down of transactions involving Yemen Kuwait Bank for Trade and Investment Y.S.C and its subsidiaries holding a 50% or greater ownership. This authorization is valid till, February 16, 2025.

The license allows for transactions that are ordinarily incidental and necessary to wind down operations, provided that payments to blocked persons are deposited into blocked accounts in compliance with GTSR. However, any other transactions prohibited under GTSR remain unauthorized unless separately permitted.

This regulatory measure aims to provide a structured transition for businesses and stakeholders impacted by the sanctions while maintaining alignment with counterterrorism objectives. Entities involved must ensure strict adherence to the conditions of the license to avoid penalties.

The issuance of this license highlights OFAC’s commitment to balancing national security interests with mitigating unintended disruptions to legitimate financial activities.

3. U.S. Expands Measures on Syria: Executive Order Enacts Additional Sanctions to Address Ongoing Crisis

On January 15, 2025, President Joseph R. Biden Jr. issued an executive order to update measures under Executive Order 13894, initially declared on October 14, 2019, addressing the ongoing national emergency in Syria. This amendment reflects evolving dynamics in the region and aims to ensure comprehensive sanctions against destabilizing actors.

The revised order modifies critical provisions by removing references to Turkey’s prior military actions in northeast Syria and streamlining sanctions criteria. It emphasizes blocking property and interests of individuals or entities providing material, financial, or technological support to those already sanctioned. Additionally, the order simplifies language for entities owned, controlled, or indirectly associated with sanctioned parties. This refinement enhances the United States’ capacity to respond to evolving threats in Syria, strengthening sanctions enforcement.

This decisive action reaffirms the United States’ commitment to peace and stability in Syria while ensuring national security interests are upheld. It also signals a robust approach to addressing challenges posed by sanctioned individuals and entities contributing to regional instability.

4. OFSI Publishes General License INT/2025/5632740 for Basic Necessities of UK Designated Persons

The Office of Financial Sanctions Implementation (OFSI) has issued General License INT/2025/5632740 under the UK Autonomous Sanctions Regulations, effective from January 15, 2025. The license allows designated UK persons (UK DPs) to access funds for essential needs up to a monthly cap of £350. This temporary relief is valid for two months from the date of designation.

Permitted payments include essentials such as food, beverages, medicines, and household products. The license explicitly excludes individuals designated under United Nations compliance obligations. Transactions are limited to regulated entities, including those authorized under the Financial Services and Markets Act 2000, Payment Services Regulations, or Electronic Money Regulations.

Key conditions include record-keeping requirements and strict adherence to the £350 monthly limit. Direct or indirect payments to other sanctioned persons outside this authorization remain prohibited. Newly designated persons under counterterrorism or UN regimes must approach OFSI for specific licenses to meet their basic needs.

This measure reflects OFSI’s commitment to balancing enforcement of sanctions with humanitarian considerations, ensuring basic necessities are accessible to those under financial restrictions. Stakeholders must adhere to outlined conditions to avoid violations.

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