Sanctions Watch | Weekly Vol. 92

Sanctions Watch Vol 92

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

1. UK Grants Petrol Station Payment License for Nationals in Kyrgyzstan and Tajikistan

The UK government, through HM Treasury’s Office of Financial Sanctions Implementation, has granted a General Licence under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019. The licence, identified as INT/2025/5886860, permits UK nationals in Kyrgyzstan and Tajikistan to purchase petrol from Gazprom Neft or its subsidiaries. The purchase must be for personal vehicle use, and transactions can be facilitated through relevant UK financial institutions.

This decision ensures that UK citizens residing or traveling in these regions can access fuel without violating sanctions imposed on Russia. The permission extends to necessary activities that facilitate the transaction, ensuring seamless payments and adherence to financial regulations. However, the licence does not allow actions that breach other provisions of the Russia Regulations unless specifically permitted.

Effective from 14 March 2025 to 15 March 2027, the licence provides much-needed relief for UK nationals who rely on personal transportation. HM Treasury retains the authority to modify, revoke, or suspend the licence if required. This move demonstrates the UK’s commitment to balancing sanctions enforcement with the needs of its citizens abroad.

2. U.S. Tightens Sanctions on Russian Energy Transactions, Strengthening Global Compliance Measures

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L to expire, effectively prohibiting energy-related transactions with major Russian financial institutions on the Specially Designated Nationals (SDN) list. Originally issued under the Biden administration, GL 8 had permitted transactions involving oil, gas, coal, uranium, and other energy resources with SDN banks like Sberbank, VTB Bank, and Alfa-Bank to prevent disruptions in global markets.

With the expiration of GL 8L under the Trump administration, financial institutions and energy sector participants must now seek individual OFAC licenses or reconsider transactions involving Russian energy to avoid U.S. sanctions. This move significantly tightens restrictions, impacting both U.S. and non-U.S. entities engaged in Russian energy dealings. Moreover, U.S. secondary sanctions extend to foreign entities, even without a direct U.S. nexus.

These developments underscore the heightened enforcement of Russia-related sanctions and signal potential further restrictions depending on geopolitical events. Companies globally must reassess their compliance frameworks to align with evolving U.S. regulations.

3. U.S. Sanctions Target Iran’s Illicit Oil Trade and Revenue Networks

The U.S. Department of State and Department of the Treasury have imposed new sanctions to curb Iran’s illicit oil trade and disrupt revenue streams used to fund destabilizing activities. The State Department sanctioned three entities and identified three vessels engaged in ship-to-ship transfers in Southeast Asia, enabling Iran’s disguised oil exports. Simultaneously, the Treasury Department designated Iran’s Minister of Petroleum, Mohsen Paknejad, and multiple entities involved in transporting Iranian oil to China, blocking their vessels as property.

These measures, executed under Executive Orders 13846 and 13902, aim to enforce the U.S. policy of maximum pressure, reducing Iran’s oil exports to zero and preventing financial support for nuclear threats, missile programs, and terrorist groups. This marks the third round of sanctions on Iranian oil sales since National Security Presidential Memorandum 2 was issued on February 4, 2025. The U.S. remains committed to limiting Iran’s financial resources and holding corrupt officials accountable.

4. UK Strengthens Financial Sanctions Framework for High Value Dealers and Art Market Participants

The UK government has expanded financial sanctions regulations to include High Value Dealers (HVDs) and Art Market Participants (AMPs), effective from 14 May 2025. This move, led by the Office of Financial Sanctions Implementation (OFSI), aims to curb sanctions evasion within the high-value goods and art sectors. The UK, a global hub for luxury assets, reported $11.05 billion in art sales in 2023, ranking third worldwide. However, concerns about sanctions evasion through high-value transactions, intermediaries, and offshore accounts prompted stricter compliance requirements.

The new regulations mandate enhanced due diligence, requiring HVDs and AMPs to report suspected financial sanctions breaches directly to OFSI. This aligns with existing obligations for financial institutions, reducing gaps in enforcement. Luxury cars, precious metals, gemstones, and fine wines are also included, ensuring a broader scope of compliance.

A recent case demonstrated the urgency of these measures when UK authorities seized £1 million worth of artwork linked to a sanctioned terrorist financier. The artwork was stored in UK warehouses and sold through offshore firms. The enforcement action led to the arrest of a suspect for terrorist financing. The new regulatory framework enhances compliance awareness, preventing financial crime in the luxury goods sector.

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