Sanctions Watch | Weekly Vol. 91

Sanctions Watch Vol 90

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

1. OFAC Issues General License 22A Easing Sanctions on Humanitarian Aid to Yemen

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 22A, replacing General License No. 22 from January 17, 2024. The updated license authorizes specific transactions involving Ansarallah, a sanctioned group, and its affiliates, under the Global Terrorism Sanctions Regulations (GTSR) and Foreign Terrorist Organizations Sanctions Regulations (FTOSR). These transactions must be ordinarily incident and necessary to the provision (including sale) of agricultural commodities, medicine, medical devices, replacement parts, components for medical devices, or software updates for medical devices, intended for Yemen or persons in third countries purchasing specifically for provision to Yemen.

The license defines agricultural commodities broadly, including food for humans and animals, seeds for food crops, fertilizers, and reproductive materials for food production. Medicine and medical devices follow definitions under the Federal Food, Drug, and Cosmetic Act.

However, the license does not authorize financial transfers to blocked persons beyond specific payments like taxes, fees, import duties, and public utility services. It also excludes transactions involving other persons blocked under the GTSR or FTOSR unless separately authorized.

The document clarifies that the license does not exempt compliance with other federal laws or regulatory requirements. This measure aims to balance humanitarian aid with maintaining sanctions pressure on Ansarallah and affiliated entities.

2. OFAC Issues General License 41A to Facilitate Chevron’s Wind Down Operations in Venezuela

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 41A, replacing and superseding General License No. 41 from November 26, 2022. This new license authorizes the wind-down of certain transactions related to Chevron Corporation’s joint ventures (JVs) in Venezuela. These transactions involve Petróleos de Venezuela, S.A. (PdVSA) or entities in which PdVSA holds a 50 percent or greater ownership interest. The authorization covers activities previously permitted under General License 41 and applies to operations and management by Chevron or its subsidiaries in Venezuela. The license remains valid through 12:01 a.m. EDT on April 3, 2025.

However, the license specifically prohibits several activities. It does not authorize the payment of taxes or royalties to the Government of Venezuela, nor the payment of dividends—including dividends in kind—to PdVSA or its affiliates. It also forbids the sale of petroleum or petroleum products produced by Chevron JVs for export to jurisdictions other than the United States. Additionally, any transaction involving a Venezuelan entity owned or controlled by a Russian Federation-based entity is not authorized. Further, the license excludes any other transactions otherwise prohibited under the Venezuela Sanctions Regulations (VSR), unless separately authorized.

OFAC emphasizes that compliance with other federal agency requirements, such as those of the Department of Commerce’s Bureau of Industry and Security, remains mandatory.

3. UN Security Council Extends Somalia Sanctions Regime, Tightens Measures Against Al-Shabaab and Regional Arms Flows

The UN Security Council unanimously adopted Resolution 2776 (2025), extending the authorization for Member States to intercept vessels violating Somalia’s arms and charcoal embargoes until 13 December 2025. The Council also renewed the mandate of the Panel of Experts assisting the Al-Shabaab sanctions regime until 13 January 2026.

Acting under Chapter VII of the UN Charter, the resolution reinforces measures preventing arms and military equipment deliveries to Somalia, except for authorized government forces. The decision aims to curb Al-Shabaab’s access to weapons and funding, amid growing concerns over arms trafficking from Yemen and links between Al-Shabaab and the Houthis.

Council members emphasized the importance of supporting Somalia’s efforts while reviewing the sanctions regime’s effectiveness. The resolution mandates a report from the Secretary-General by 1 November 2025 to assess the embargo’s impact. The United Kingdom, France, and the United States highlighted the need for coordinated actions between the Yemen and Somalia sanctions committees to address cross-border threats. Meanwhile, Russia stressed the importance of separating the Yemen issue and ensuring African states’ perspectives are prioritized.

Pakistan’s delegate underscored the need for comprehensive strategies addressing terrorism’s root causes, including economic development and humanitarian aid. The resolution marks a continued international commitment to degrading Al-Shabaab’s capabilities and supporting Somalia’s stability.

4. Switzerland Eases Sanctions on Syria to Support Civilian Population and Political Transition

The Swiss Federal Council announced the easing of specific sanctions against Syria, following the European Union’s similar decision on 24 February. The move comes in response to the ousting of former President Bashar al-Assad on 8 December 2024 and is aimed at facilitating a peaceful political transition in Syria. Effective from 6 pm on 7 March, Switzerland has lifted restrictions on Syria’s energy and transport sectors, along with permitting certain financial services and banking relationships.

While this measure seeks to ease the humanitarian situation and support the civilian population, the Federal Council clarified that other sanctions remain in place. Notably, the easing does not involve the unfreezing of any previously blocked funds or assets. Switzerland first imposed sanctions against Syria in May 2011 in response to violent crackdowns on civilians. These sanctions were regularly updated in alignment with the EU.

The Federal Council emphasized its continued vigilance over developments in Syria and left open the possibility of re-imposing lifted measures if necessary.

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