Prior to this weekend’s unprecedented events in Venezuela, the US had been ramping up sanctions on the country throughout December. The month began with the seizure of the sanctioned crude oil tanker Skipper off the Venezuelan coast for transporting petroleum between Venezuela and Iran, followed shortly by President Trump’s announcement of a blockade on all sanctioned vessels travelling to and from Venezuela. The US also designated members of President Nicolás Maduro’s immediate family, key business associates including Panamanian businessman Ramón Carretero Napolitano and his relatives, and six shipping companies linked to sanctioned oil transport. On the counterterrorism front, seven individuals and four entities connected to the Tren de Agua network were sanctioned. In parallel, the EU extended its Venezuela sanctions regime for another year.
Beyond Venezuela, December saw wide-ranging sanctions activity and enforcement. The US, UK, and EU added new listings tied to the Sudan conflict, Russian oil, cyber and information operations, Iran’s shadow fleet and Syrian regime-linked actors, while the EU rejected a series of prominent Russian and Syrian delisting applications, signalling limited scope for relief. Enforcement actions included major settlements and fines for sanctions breaches involving Iran, Russia, North Korea and export controls. Most notable among these was the settlement of a $1.5 billion investor lawsuit against Standard Chartered, linked to alleged Iranian sanctions breaches. Meanwhile, regimes targeting Mali, the Democratic Republic of Congo, and Somalia have been extended, and the scope of an arms embargo on the Central African Republic amended in light of improved security conditions.
Venezuela
- Among the most notable actions taken by the US in December was the seizure of sanctioned vessel the Skipper off the coast of Venezuela, a crude oil tanker transporting petroleum products between Venezuela and Iran. A week later, President Trump announced a blockade on all sanctioned vessels travelling to and from Venezuela
- This was followed by a wave of designations targeting members of President Nicolas Maduro’s family, including his parents, wife, daughter, and three nephews, in addition to designations for Panamanian businessman and Maduro associate Ramon Carretero Napolitano and six shipping companies reported to be transporting sanctioned oil. Members of Carretero’s family were also sanctioned. On the counterterrorism front, the US also designated seven individuals and four entities for their links to Venezuela’s Tren de Agua, including a cell leader and a partner of Tren de Agua’s leader.
- Action against Venezuela was not limited to that taken by the US, as the EU also extended its sanctions regime against Venezuela for another year, maintaining restrictions on the 69 people included on the list.
Designations and De-Listings
- Pressure on Russia continued throughout December, as OFSI sanctioned two individuals and five entities reported to be linked to Russian foreign misinformation campaigns and political interference operations, including political scientist Aleksandr Dugin and blogger Mikhail Zvinchuk. Three entities founded or directed by Zvinchuk were also sanctioned. In addition, the UK designated two entities under its cyber sanctions regime, namely Integrity Technology Group, a covert network of over 260,000 devices that has targeted UK public sector IT systems, and Sichuan Anxun Information Technology Co, which has enabled Chinese access to and interference with UK public and private sector IT systems. Finally, five people and 19 entities linked to Russia’s oil sector were sanctioned, including four major oil companies: PJSC Taftneft, PJSC Russneft, LLC NNK-Oil and LLC Rusneftegaz.
- The EU also targeted 12 people and two entities under its hybrid threats regime, comprising foreign policy analysts, media figures and members of the Russian military intelligence unit all involved in manipulating information entering the EU and/or conducting cyber-attacks against EU infrastructure. A further five people and four entities involved in oil trading activities reported to be circumventing sanctions against Russia were designated along with 41 vessels.
- In Iran, the US designated 3 people, 17 entities and 29 vessels for their Iranian shadow fleet involvement. Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr was also designated for owning and operating many of the management companies for the vessels. While the UK removed the IRGC and two connected individuals from its Syrian sanctions list, these remain designated through sanctions on Iran. Separately, 9 Assad-linked individuals and militias were added to OFSI’s Syrian sanctions list.
- Elsewhere, the US sanctioned two ICC judges from Georgia and Mongolia respectively for their efforts to investigate, arrest, and prosecute Israeli nationals and designated Colombia’s Clan de Golfo as a Foreign Terrorist Organisation. The EU designated former Haitian President Michel Martelly, his former political advisor, and a former senator for their involvement in human rights abuses in the country. In Sudan, the US sanctioned four people and four entities found to be part of a transnational network recruiting Colombian nationals to fight in Sudan’s civil war on behalf of the RSF. The UK similarly sanctioned four RSF commanders, two of whom are also sanctioned by the US and EU respectively.
- December saw a string of unsuccessful de-listing applications in relation to EU sanctions on Russia, including those submitted on behalf of leading Russian business figure Gennady Timchenko and his wife Elena; mining magnate Musa Bazhaev; Sberbank subsidiary SBK Art; Eurochem owner Andrey Melnichenko and his wife Aleksandra; and businessman Igor Rotenberg. Outside of Russia, the EU rejected Amer Foz’s Syrian delisting application on the grounds that Foz’s links to ISIL trade remain relevant and that his links to a cousin of Bashar Al Assad justify his associations with the Syrian regime.
- OFAC delistings were equally notable; Brazilian Supreme Court judge Alexandre de Moraes, previously judged to have undermined freedom of expression in Brazil, was removed from the Global Magnitsky sanctions list along with his wife and business interests.
Enforcement
- December saw several significant updates in the sanctions enforcement space. Standard Chartered Plc agreed to a settlement of a £1.5 billion lawsuit over allegations of breaches of Iranian sanctions. A group of 216 investors claimed that Standard Chartered had published untrue or misleading statements related to its sanctions compliance. The settlement follows a judgement handed down by the Court of Appeal ruling that Standard Chartered was obliged to disclose certain regulatory documents that the bank argued would leave it liable to regulatory sanctions or criminal proceedings overseas over its duty of confidentiality.
- OFAC published details of an $11.4 million settlement with Chicago private equity firm IPI Partners in light of the firm’s violation of Russian sanctions. These violations included wire transfers with an entity owned by sanctioned businessman and former Russian senator Suleiman Kerimov. A settlement of $3 million was also reached with Exodus Movement for their alleged violation of Iranian sanctions through the provision of digital wallet services to users in the country.
- Keeping with the US, virtual asset trading platform Paxful admitted to processing transactions involving sanctions evasion and agreed to pay a $4 million criminal penalty. The transactions were associated with North Korean cyber-criminal group Lazarus, which has been sanctioned by the US since 2019.
- A $7 million fine was handed down to a New York-based property management firm, Gracetown Inc, for its activities managing properties belonging to Oleg Deripaska, who was sanctioned in 2018. A US-based company also pleaded guilty to AI-related export control breaches, having attempted to export $160 million worth of Nvidia graphic processing units to China and Hong Kong. The company will be issued with a financial penalty while its owner faces ten years’ imprisonment.
- In the UK, HMRC concluded a £620,000 settlement with a UK business found to have exported military goods without a license.
Other Regulatory Updates
- The US granted Hungary an exemption from sanctions on Russian oil and gas following White House negotiations this month. This exemption enables Hungary to import oil and gas via the Druzhba and TurkStream pipelines, which both run through Hungary. The US also issued a general licence authorising transactions involving three Belarus potash companies after over 100 prisoners were released by President Alexander Lukashenko, including key opposition figures and a Nobel peace prize winner.
- The EU renewed its sanctions regimes targeting Mali, first established in 2017 in line with now-inactive UN sanctions; its global human rights regime, now extended until December 2026; the Democratic Republic of Congo, by which 31 individuals and two entities are currently sanctioned; and sectoral sanctions against Russia for a further six months. The UN has meanwhile extended its Al Shabaab sanctions regime in Somalia for another year.
- In addition, the EU has broadened its Belarus sanctions criteria to include those who engage in foreign information manipulation, target the functioning of democratic institutions, enter an EU member state without authorisation, and interfere with critical infrastructure. These amendments are said to be linked to recent meteorological balloon incursions into Lithuania’s airspace.
- In the UK, sanctions against the Central African Republic were amended to lift the arms embargo in recognition of the country’s progress towards stability in disarming two major armed groups. This applies to the CAR government and not to other armed groups in the Central African Republic, who remain prohibited from accessing weapons and ammunition.
