Sanctions Watch | Weekly Vol. 93

Sanctions Watch Vol 93

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

1. UK Unveils Open General Licence for AUKUS Nations, Boosting Defence Trade with US and Australia

The UK government issued a revised Open General Licence (OGL) for the AUKUS nations—Australia, the United Kingdom, and the United States—to simplify and facilitate the transfer of dual-use items and military-grade goods, technology, and software among the alliance. This move follows the United States’ August 2024 certification that UK export controls meet US standards, granting the UK exemption from ITAR regulations. In reciprocity, the UK established this OGL to align its export permissions with US and Australian standards. The licence allows the export and re-export of eligible items among AUKUS members, even if such items are embedded in other products.

However, it imposes strict conditions on classified materials and requires exporters to be registered “Authorised Users.” It also prohibits transfers to non-AUKUS countries. Detailed compliance procedures, record-keeping mandates, and audit provisions are laid out, including security clearance for sensitive material and the use of MOD Form 680 for classified exports. The licence explicitly excludes prohibited technologies such as MANPADS, nerve agents, cluster munitions, and other controlled weapons and software. With this framework, the UK aims to strengthen trilateral defence collaboration while maintaining strict oversight and national security controls. The new licence will come into force on 20 March 2025.

2. OFAC Issues Alert on International Cartels as Foreign Terrorist Organizations

The Office of Foreign Assets Control (OFAC) has issued an alert following recent U.S. government designations of eight international cartels including Mara Salvatrucha (MS-13), Sinaloa Cartel, Tren de Aragua, Cartel de Jalisco Nueva Generacion, Cartel del Noreste, La Nueva Familia Michoacana, Gulf Cartel, and Carteles Unidos—as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). These designations, authorized under Executive Order 14157 issued on January 20, 2025, significantly escalate sanctions and criminal liability risks for both U.S. and foreign financial institutions and entities that interact with or financially expose themselves to these organizations.

The immediate consequence of these designations is the blocking of all property and property interests of the listed cartels within U.S. jurisdiction, accompanied by a comprehensive prohibition against U.S. persons engaging in any transactions with these groups. Non-U.S. persons also risk severe penalties if they facilitate or conspire to facilitate violations of these sanctions, potentially facing sanctions themselves.

OFAC emphasizes that these counterterrorism measures empower the U.S. government with enhanced legal tools aimed at disrupting cartel financing and reducing their capacity for terrorism and drug trafficking activities. Financial institutions worldwide, especially those operating in high-risk jurisdictions, are advised to rigorously strengthen sanctions compliance programs to mitigate exposure to these severe penalties.

3. Switzerland Divides Sanctions Ordinance to Align with UN Resolutions on ISIL, Al-Qaida, and Taliban

The Swiss Federal Council announced the division of its existing sanctions ordinance targeting individuals and entities linked to Usama bin Laden, Al-Qaida, and the Taliban into two distinct legal instruments. This action follows a series of modifications made by the United Nations Security Council (UNSC), which had previously split its sanctions regime in 2011 into separate lists for Taliban-affiliated and Al-Qaida-linked individuals, with ISIL (Da’esh) added in 2015. Initially, Switzerland did not change its domestic legal framework, as the nature of the sanctions remained identical. However, recent changes introduced by the UNSC, particularly regarding humanitarian exemptions, prompted Switzerland to revise its implementation approach.

Effective 15 May 2025, the new structure includes a distinct ordinance for sanctions related to the Taliban and a revised ordinance now titled Ordinance on Measures against Persons and Organisations with Links to ISIL and Al-Qaida. Correspondingly, annexes listing sanctioned individuals and entities have also been split. This adjustment brings Swiss policy in line with evolving UN directives and aims to enhance clarity and implementation efficiency without altering the nature of existing sanctions or humanitarian carve-outs. The move underscores Switzerland’s ongoing commitment to global peace and security through multilateral cooperation and compliance with international mandates.

4. UK Freezes £25 Billion in Russian Assets Amid Toughest Sanctions Yet 

The HM Treasury and Economic Secretary to the Treasury Emma Reynolds announced that the UK has frozen over £25 billion in Russian assets, marking a significant milestone in its sanctions regime. These figures were published in the Office of Financial Sanctions Implementation’s (OFSI) Annual Review for 2023–24. The sanctions, introduced in response to Russia’s illegal invasion of Ukraine, are described as the most severe the country has ever faced. Since February 2022, coordinated efforts by the UK and its allies have deprived Russia of over $400 billion—an amount equivalent to four years of its military spending.

This economic pressure has contributed to Russia’s budget deficit, a weakened rouble, rising inflation, high interest rates, and a skilled labour shortage. OFSI has ramped up enforcement, more than tripling its closed investigations and publicly naming non-compliant firms. Notably, International Concierge Services Limited (ICSL) and Herbert Smith Freehills Moscow were fined in August 2024 and March 2025 respectively. These represent the first wave of enforcement cases directly linked to Russia’s invasion, with further actions expected in 2025. The asset freeze policy blocks UK individuals and businesses from dealing with sanctioned Russian entities and ensures that no resources benefit designated persons.

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