Sanctions developments in May continued to focus heavily on Iran, with the US significantly expanding its “Economic Fury” campaign targeting Iran’s oil trade, shadow banking networks, shipping operations, and weapons procurement channels. US designations targeted Iranian foreign exchange houses and front companies said to facilitate billions of dollars in transactions for sanctioned Iranian actors, including the Central Bank of Iran and the National Iranian Oil Company, as well as Islamic Revolutionary Guard Corps officials, Iraqi oil-sector actors, Chinese and Hong Kong shipping companies. Later in the month, the US also designated the Persian Gulf Strait Authority for collecting tolls on behalf of the IRGC in the Strait of Hormuz, while the EU expanded the scope of its Iran-related sanctions framework to cover actions impeding lawful transit and freedom of navigation through the Strait.
The UK imposed new designations targeting Russia’s drone supply chains, migrant trafficking networks, crypto-enabled sanctions evasion, and information warfare operations, while both the UK and EU designated individuals and entities linked to the forced deportation, militarisation, and indoctrination of Ukrainian children. The UK also introduced new Russia trade and transport sanctions covering emerging technologies, Russian-origin uranium, refined oil products processed from Russian crude, LNG maritime services, construction services, and specified ships.
In notable sanctions enforcement, OFAC reached a $275 million settlement with Adani Enterprises Limited for apparent breaches of the Iranian Transactions and Sanctions Regulations involving Iranian-origin liquefied petroleum gas, while OFSI imposed a £165,000 penalty on Deutsche Bank AG London Branch for Russia sanctions breaches involving payments to Okko LLC. Elsewhere, the US introduced a new Cuba sanctions framework, while the EU, UN, and UK updated extended regimes covering Syria, Libya, cyber threats, and ISIL/Al Qaida.
Iran
- In parallel with the ongoing war in the Middle East, the US continued its “Economic Fury” campaign against Iran’s oil trade and financial networks. On 5th May, OFAC and the State Department added six individuals, 21 entities, and one vessel to the Iran sanctions list. The measures principally targeted three Iranian foreign currency exchange houses as well as their front-company networks, which were said to facilitate billions of dollars in transactions annually on behalf of sanctioned Iranian actors, including the Central Bank of Iran and NIOC.
- The US also targeted Iranian-linked activity in Iraq’s oil sector. On 11th May, the US designated four individuals and four entities, including Iraq’s Deputy Minister of Oil Ali Maarji Al Bahadly, for facilitating the diversion of Iraqi oil products to US-sanctioned Iraqi businessman Salim Ahmed Said and the US-sanctioned terrorist militia Asa’ib Ahl Al-Haq (“AAH”). Other individuals designated included a leader and economic official of AAH, a former senior official of Kata’ib Sayyid al-Shuhada (“KSS”), and a senior KSS official.
- US measures later in the month targeted IRGC oil sales to China. On 13th May, the US designated three officials of the IRGC’s Shahid Purja’fari Oil Headquarters for enabling the sale and shipment of Iranian oil. The US also designated nine shell companies operating across Hong Kong, the UAE, and Oman. These entities were said to have arranged, purchased, or facilitated IRGC oil shipments, including shipments worth tens of millions of dollars carried by sanctioned tankers.
- On 20th May, the US added 60 individuals, entities, and vessels to its counterterrorism and Iran sanctions lists, combining measures against Hamas support networks and Iranian sanctions-evasion operations. The Iran-related designations targeted Ebrahimi and Associates Partnership Company, also known as Amin Exchange, together with associated front companies and vessels operating across the UAE, Turkey, and China. The same package also added eight individuals and one entity for supporting Hamas, including individuals linked to a pro-Hamas flotilla attempting to reach Gaza and coordinators associated with Samidoun.
- At the end of the month, the US designated the Persian Gulf Strait Authority for being linked to the IRGC. The Authority is responsible for collecting tolls on behalf of the IRGC in the Strait of Hormuz, and OFAC issued a related alert on toll payments for passage through the Strait. Separately, the EU amended its regime targeting Iranian support for Russia’s war in Ukraine, to cover people and entities involved in Iranian actions and policies impeding lawful transit passage and freedom of navigation, in particular in the Strait of Hormuz.
Russia
- The UK imposed a significant package of Russia-related designations on 5th May, adding 35 individuals and entities under the Russia sanctions regime and the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025. The Russia sanctions designations targeted three groups: individuals and entities linked to Russia’s Alabuga Start programme, through which migrants are recruited to work in drone production facilities; suppliers of drones and drone components within Russia; and entities based in Thailand and China supplying drone components or dual-use goods to Russia. The irregular migration designations targeted individuals and entities involved in trafficking foreign nationals into Russia and instrumentalising migration to destabilise Ukraine and Europe, marking the first use of the UK’s irregular migration regime for this purpose.
- The UK and EU also imposed sanctions linked to Russia’s deportation and indoctrination of Ukrainian children. The EU added 16 individuals and seven entities for responsibility for the unlawful deportation, forced transfer, and forced assimilation of Ukrainian children to Russia and occupied Ukrainian territories. The EU stated that Russia has deported or forcibly transferred nearly 20,500 Ukrainian children since the start of its full-scale invasion, and that more than 130 individuals and entities are now sanctioned in connection with the abductions.
- The UK separately added 85 individuals and entities to its Russia sanctions list on 13th May, covering two groups. 29 targets were linked to Russia’s campaign to deport and militarise Ukrainian children and a further 56 targets were linked to Kremlin information warfare, including 49 individuals working for the Social Design Agency (“SDA”), which the UK said had been tasked and funded by the Russian government to carry out influence operations designed to undermine democracy and weaken support for Ukraine, including planned interference in Armenian elections.
- Licensing and waivers affecting Russia-related trade continued alongside the new restrictions. The UK issued two general trade licences: one authorising certain imports of diesel and jet fuel processed from Russian-origin crude oil, and another authorising the maritime transportation of Russian LNG from the Sakhalin-2 and Yamal LNG terminals to third countries, or between third countries, until 1st January 2027. The US also issued a general licence authorising the delivery and sale of Russian-origin crude oil and petroleum products already loaded on vessels on or before 17th April 2026, extending the authorisation until 17th June 2026.
- The UK further targeted Russian crypto-enabled sanctions evasion. On 27th May, the UK designated four individuals and 14 entities linked to the A7 crypto network, used by Russia to evade existing sanctions. Targets included A7 director Sergey Mendeleev and OJSC Eurasian Savings Bank, a Kyrgyzstan-registered bank, as well as entities involved in Russia’s financial sector and Kyrgyz entities carrying on business of economic significance to the Russian government.
Enforcement
- OFAC announced a $275 million settlement with Adani Enterprises Limited (“AEL”) for over 32 apparent violations of the Iranian Transactions and Sanctions Regulations. Between 2023 and 2025, AEL imported Iranian-origin LPG from a Dubai supplier and sold it to customers in India. OFAC found that AEL overlooked red flags indicating Iranian origin, including significantly discounted prices, vessel manipulation of Automatic Identification System (“AIS”) data, unexplained AIS dark periods, frequent name and flag changes, and at least one payment being stopped due to sanctions concerns. AEL did not voluntarily self-disclose the apparent violations and OFAC treated the breaches as egregious, although the penalty was reduced to reflect cooperation and remedial measures.
- In the UK, OFSI imposed a £165,000 penalty on Deutsche Bank AG London Branch for breaches of sanctions on Russia. In 2022, the bank processed two transactions worth over £635,000 on behalf of a non-UK customer to Russian company Okko LLC while Okko was owned by UK-sanctioned JSC New Opportunities. The bank voluntarily disclosed the payments, but OFSI applied a 45% discount rather than the maximum 50% available for prompt and complete voluntary disclosure because the disclosure was not complete. The case is the second OFSI enforcement action relating to Okko and New Opportunities, following the £390,000 penalty imposed on Apple Distribution International.
Other Designations, De-Listings and Regulatory Updates
- The US continued to impose counterterrorism sanctions across several regimes. Alongside Hamas-related designations, the US added nine Hizballah-linked individuals for obstructing the peace process in Lebanon and impeding Hizballah’s disarmament. The EU separately agreed to sanction further Israeli settler groups and entities, as well as leading Hamas figures.
- US narcotics sanctions continued to target Sinaloa Cartel-linked networks. The US designated 11 individuals and two entities linked to the cartel’s fentanyl trafficking activities. Targets included Armando de Jesus Ojeda Aviles, for leading a network involved in laundering proceeds of fentanyl and other narcotics trafficking activities, Jesus Gonzalez Penuelas, for leading an organisation trafficking illicit drugs into the US and laundering cartel funds, and Alfredo Orozco Romero, described as a security adviser and debt collector. The two entities designated were Gorditas Chiwas and Grupo Especial Mamba Negra.
- The US removed Francesca Albanese, the UN Special Rapporteur on the Occupied Palestinian Territories, from the International Criminal Court sanctions list on 22nd May following a temporary injunction in LC v Trump and OFAC’s notice that her designation would not be enforced for the duration of the injunction. One week later, the US added her back to the same list, without indicating whether the designation was made on amended grounds.
- The EU rejected three appeals by members of the Makhlouf family and upheld their EU Syria sanctions listings, finding their evidence of estrangement from the family insufficient. These individuals were two daughters and a widow of Mohammed Makhlouf, a Syrian businessman and uncle of former President Bashar Al Assad.
- The EU and UN issued several regime renewals and guidance updates. The EU extended its cyber sanctions regime until 18th May 2027 and amended entries relating to cyber threat groups APT10 and Wizard Spider. The EU also renewed its Syria sanctions regime until 1st June 2027, while removing seven entities including Syria’s Ministries of Defence and Interior to support strengthened engagement with Syria. Finally, the EU renewed its Russia human rights sanctions regime until 28th May 2027, under which 72 individuals and one entity are currently listed.
- On 5th May, President Trump signed a new Executive Order authorising sanctions on persons responsible for repression in Cuba, threats to US national security, serious human rights abuses, corruption, material support to the Cuban government, and activity in key sectors including energy, defence, financial services and security. The order also authorised secondary sanctions on foreign financial institutions that conduct or facilitate significant transactions with designated persons. Across May, 12 individuals and five entities were designated under this framework, notably including Cuba’s Ministry of the Interior, the Policía Nacional Revolucionaria, the Directorate of Intelligence, and several senior government officials.
