One of Russia’s largest oil companies, Lukoil, has announced its intention to sell its international assets to Swiss commodities trader Gunvor Group after it was sanctioned by the US and the UK in October 2025. Gunvor Group is reportedly awaiting permission from OFAC, along with necessary licenses. The US and UK additionally sanctioned major Russian oil company Rosneft, whilst the EU adopted its 19th sanctions package targeting, inter alia, Russia’s banking and energy sectors.
Iran’s Foreign Ministry has claimed the UN’s snapback sanctions lack a legal basis as the UK designated 43 people and companies to reflect UN regulations. Meanwhile, the US sanctioned 38 individuals and 73 companies throughout October for procuring arms for Iran, operating in Iran’s petrochemical sector, and supporting the Iranian Revolutionary Guard Corps (“IRGC”).
In the enforcement space, BNP Paribas was ordered to pay $20 million to three Sudanese refugees after a New York jury found it liable for enabling genocide in Sudan. Separately a New York court allowed terrorism financing claims against the bank brought by 288 victims of terrorist attacks committed in Israel and Iraq between 2006 and 2018.
Russia and Iran
- Key sanctions against Russia in October came in the form of the US and UK’s joint action, designating Lukoil and Rosneft, Russia’s two largest oil producers. This action was part of a wider swathe of sanctions, with the US also designating 34 subsidiaries of the oil majors. The UK additionally sanctioned five people and 35 companies, also listing 51 Russian vessels as prohibited from accessing UK ports. Although the US began the month issuing a license postponing sanctions on the Russian-owned Serbian oil refinery operator Serbian Oil Industry (“NIS”), the waiver expired on 9th October, and US sanctions on NIS entered into force.
- The EU adopted its 19th Russia sanctions package, which targets Russia’s banking and energy sectors, including a ban on Russian LNG imports and sanctions on Russia’s shadow fleet, as well as sanctions on crypto networks and banks said to be circumventing EU sanctions. The package also included designations related to the forced deportation of Ukrainian children, producers of military and dual-use goods, and the implementation of service authorisations on all work with the Russian government.
- In line with UN snapback sanctions on Iran, the UK updated designated 23 people and 20 entities, and updated its regulations to reflect UN control lists. Designations included Iranian nuclear scientists, senior members of the IRGC, and the Atomic Energy Organisation of Iran. On 18th October the Iranian Ministry of Foreign Affairs published a statement claiming that the snapback sanctions lacked legal basis, stating Iran should be removed from the UN’s sanctions lists as a non-nuclear-weapon state. The UK later sanctioned one Iranian national for allegedly providing economic resources to the IRGC.
- Meanwhile, the US designated 22 entities and 22 people said to be involved in procuring weaponry for the Iranian Ministry of Defence and military, as well as 10 individuals, 49 companies, and 32 ships for operating in Iran’s petrochemical sector, and two companies and six people for supporting the IRGC and two Iran-aligned militia groups in Iraq.
Designations and De-Listings
- The US designated 8 people and 11 entities linked to the Los Chapitos faction of the Sinaloa Cartel under its counter-narcotics programme. In late October the US continued its counter-narcotics sanctions with the designations of Colombian President Gustavo Petro, his family, and the Colombian Interior Minister Armando Benedetti. The US additionally designated two Haitian individuals under its counter-terrorism sanctions, both of whom were later also designated by the UN.
- In another joint action, the Prince Group, a network that operates illegal scam centres in Southeast Asia, was targeted by the UK and US. The US sanctioned 146 individuals and entities for ties to the Prince Group, whilst the UK sanctioned 12 associated companies and people. The UK additionally designated 12 people and 1 entity with alleged ties to a Western Balkans people smuggling route and the Kosovo-based organised crime group the Krasniqi network. Elsewhere, the EU announced its intention to add the DRC-based militant group the Allied Democratic Forces to its ISIL and Al Qaida sanctions on top of its existing listing under DRC sanctions.
- OFAC removed 52 individuals and entities from its Balkans sanctions regime. OFAC also delisted Turkish company Kuzey Star Shipyard, which had been sanctioned in January 2025 for its connection to Russian maritime company Atomflot, as well as the former Paraguayan President Horacio Manuel Cartes Jara, and his five companies, having been designated in February 2023.
- The EU General Court annulled the listings of Russian national Galina Pumpyanskaya, and Belarusian businessman Mikhail Gutseriev. The EU General Court, however, rejected the appeals of Russian nationals Gennady and Elena Timchenko and Moldovan national Maria Albot regarding their designations. In the case of the Timchenkos, their appeal challenged the legality of sanctions reporting obligations. The same claim has previously been rejected on three occasions when brought by sanctioned businessmen and politicians Mikhail Fridman, Petr Aven and German Khan.
Enforcement
- French bank BNP Paribas has faced significant enforcement action in October 2025. The month began with the US District Court for the Southern District of New York allowing terrorism financing claims based on sanctions breaches against the bank to proceed to trial. The claim was brought by 288 victims of terrorist attacks committed in Israel and Iraq between 2006 and 2018, who alleged that BNP Paribas provided services to US-sanctioned Iranian oil companies used as fronts for the IRGC. On 17th October a New York federal jury found BNP Paribas liable for its role in enabling the genocide committed by former dictator Omar Al Bashir against Black African civilians in Sudan. The bank has been ordered to pay $20 million to three Sudanese refugees as a result of the decision.
- The US Bureau of Industry and Security (“BIS”) published details of two settlements related to breaches of the Export Administration Regulations in October 2025. Biotechnology company Luminultra Technologies Inc received a civil penalty of $685,000 for exporting controlled items to Iran, and BVI entity Hallewell Ventures Ltd was handed a civil penalty of $374,000 for exporting an aircraft to Russia without a license.
- In the EU, Latvian authorities have charged two people with breaching EU sanctions against Russia for renting out the premises of Moscow House in Riga, which was owned by the Moscow City Property Department. Another Latvian national also pleaded guilty to conspiring to sell aircraft technology to Russia in breach of US export controls, whilst a Spanish national was sentenced to 31 months in prison for conspiring to export US radio technology to Russia via Latvia without a license. In Finland, the Helsinki District Court dismissed charges against three crew members of a ship said to be part of Russia’s shadow fleet, whilst a student with Russian citizenship received a 14-month suspended sentence after pleading guilty to delivering dual-use items to Russia in breach of EU export control laws.
- The UK Court of Appeal rejected an appeal against the High Court’s decision, which granted Palestine Action permission to challenge its proscription under the Terrorism Act 2000 in July 2025. Later in the month the UK removed the terrorism proscription of Syrian group Hay’at Tahrir al-Sham.
Other Regulatory Updates
- The EU extended several sanctions programmes until October 2026, including sanctions against Russian hybrid threats, chemical weapons, Niger, ISIL/Al Qaida, and Moldova. The UN additionally renewed its Haiti sanctions for another 13 months.
- The UK lifted the arms embargo on Armenia and Azerbaijan that had been in place since 1992. The UK government also announced it will move to a single consolidated list for designations by the treasury and the foreign office. This is set to come into force by the end of January 2026.
- OFAC granted a sanctions licence to the government of Trinidad and Tobago and the National Gas Company of Trinidad and Tobago to enter transactions necessary to negotiations with the Venezuelan Government related to an offshore gas field development project in Venezuela. The BIS renewed its temporary denial of export privileges against Ural Airlines JSC. The BIS later added 26 companies (16 Chinese, nine Turkish and one Emirati) to the US Entity List, meaning exports are subject to additional licensing requirements.
