November saw extensive US activity targeting terrorist and criminal networks worldwide. The US imposed new sanctions on facilitators moving tens of millions of dollars from Iran to Hezbollah, expanded scrutiny of the Muslim Brotherhood, and added numerous individuals and entities linked to Iranian ballistic-missile and UAV procurement networks. Beyond the Middle East, Washington designated several Antifa-affiliated groups in Europe, while the UK targeted the New Irish Republican Army and one of its members. Organised crime also remained a priority, with new US actions against the Hysa Organised Crime Group and sanctions on former Canadian Olympian Ryan Wedding and his associates. The US additionally designated Venezuela’s Cartel de los Soles as a Foreign Terrorist Organisation.
International authorities coordinated on several notable listings and delistings. The UN, UK, and US jointly removed Syrian President Ahmed Al Sharaa and Interior Minister Anas Hasan Khattab from terrorism sanctions lists, while the EU rejected a delisting request from Samer Al Assad. Meanwhile, the EU sanctioned Rapid Support Force commander Abdelrahim Hamdan Dagalo for violence in Sudan and imposed further penalties on Russian officials linked to human-rights abuses, including the death of Alexei Navalny. Cyber-related actions also expanded, with the US sanctioning North Korea-linked financial and technology entities and, alongside the UK, targeting Russian hosting providers Media Land and Azea Group for supporting cybercrime and threatening Ukrainian security. Additional measures hit Iranian aviation and global oil-shipping networks.
Sanctions enforcement intensified across multiple jurisdictions. OFAC levied a maximum $4.6 million penalty on an individual involved in the sale of a sanctioned Russian national’s property, while UK authorities charged two art-sector firms for breaching Russian sanctions. France extradited a Belarusian national to the US over aircraft-equipment export-control violations, and the US secured a settlement with Eleview International for illicit shipments to Russia. Regulatory updates included the US lifting its arms embargo on Cambodia, the EU expanding dual-use export controls to cover quantum and semiconductor technologies, and both the UK and US issuing general licences related to Lukoil, Rosneft, and Hungary’s Paks II nuclear project.
Counter Terrorism and Organised Crime
- In counter terrorism, November saw continued efforts from the US to target terrorist organisations across the Middle East. OFAC sanctioned three people said to have facilitated financial transfers from Iran to Hezbollah valued in the tens of millions over the course of 2025. Trump additionally issued an Executive Order calling for the Treasury and State Departments to report and designate chapters of the Muslim Brotherhood as foreign terrorist organisations where they are found to support violence and harm US citizens. The US also added 11 individuals and 21 entities to its counterterrorism and non-proliferation sanctions lists due to links to Iran’s ballistic missile and UAV procurement networks, said to be centred around a three-person venture named MVM Partnership, comprising Marco Klinge, Vahid Qayumi, and Majid Dolatkah.
- Outside of the Middle East, the US designated four organisations said to belong to the Antifa movement, including groups based in Germany, Greece, and Italy, the latter being the Informal Anarchist Federation/International Revolutionary Front. These groups have conducted attacks domestically and internationally, as well as threatening violence, bombs, and letter bombs against political and economic institutions. The UK designated Kieran Gallagher and the New Irish Republican Army for counterterrorism sanctions violations. Gallagher is also subject to director disqualification measures.
- The US continues to make organised crime a key focus of its sanctions designations, this month adding seven people and 20 entities to its transnational criminal organisations sanctions list for their reported links to the Hysa Organised Crime Group. The group is reported to operate with the consent of the Sinaloa Cartel and is involved in laundering money through gambling establishments and restaurants. Another high-profile subject of US sanctions this month was Ryan Wedding, a former Canadian Olympic snowboarder turned drug kingpin involved in importing cocaine to the US and Canada and laundering the proceeds via cryptocurrencies. A wife, girlfriend, associate, and lawyer of Wedding were all sanctioned for their involvement in the trafficking network. In Venezuela, the US designated Cartel de los Soles as a Foreign Terrorist Organisation, citing its links to President Nicolas Maduro and two FTO-designated cartels, Tren de Aragua and the Sinaloa Cartel.
Designations and De-Listings
- Taking joint action, the UN, UK, and US notably delisted Syrian President Ahmed Al Sharaa and Interior Minister Anas Hasan Khattab from their respective ISIL and Al Qaida sanctions lists, both of whom had previously been designated in 2013 for their roles in Al Qaida-affiliated Hayat Tahrir Al Shams. The UK additionally delisted Hayat Tahrir Al Shams. Meanwhile, a delisting application by Samer Al Assad was rejected by the EU, failing to argue that membership of the Assad family is a broad and discriminatory criterion.
- The EU sanctioned Abdelrahim Hamdan Dagalo, a commander in Sudan’s Rapid Support Force, in light of his role in sustained violence in El Fasher, Sudan where the RSF is responsible for ethically motivated killings and violations of international human rights. A further ten individuals were sanctioned for violating human rights sanctions in Russia, including prison officials, members of the Russian judiciary, and those associated with the death of Alexei Navalny.
- In the cyber space, the US added two entities and eight individuals to its cyber and North Korea sanctions lists, including Ryujong Credit Bank, Korea Mangyongdae Computer Technology Company, and related banking professionals. The UK and US also took coordinated action in sanctioning Media Land LLC, a Russian hosting web service provider allegedly linked to cybercrime and ransomware operations and Azea Group LLC, a similar provider whose actions threaten Ukrainian national security. A sister company of Media Land and four employees were also sanctioned by the UK while four companies affiliated with Azea Group were sanctioned by the US.
- There were also several notable actions taken against and in favour of airlines this month. Belarus’ Belavia was delisted by OFAC while several entities and individuals linked to Iran’s Mahan Air were added to US sanctions lists. In shipping, two people, eight entities, and four vessels were sanctioned by the US for their roles in transporting and selling Iranian oil, including companies based in Singapore, the Marshall Islands, the Seychelles, the UAE, and Vietnam.
- 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.
Enforcement
- OFAC issued a $4.6 million fine in November to an unnamed individual involved in the sale of a property in Atlanta, Georgia belonging to a sanctioned Russian person. Details published by OFAC stated the violations of Russian Harmful Foreign Activities Sanctions to be egregious, and due to the lack of voluntary self-disclosure, the maximum penalty was issued.
- The US Bureau of Industry and Security also released details this month of a settlement with Eleview International, a Virginia-based freight forwarding company that shipped goods subject to export controls to Russia between February 2022 and June 2023. The settlement saw Eleview pay a fine of $125,000 as well as agreeing to export compliance training and a three-year suspension of its ability to apply for export licenses. Separately, Belarussian national Yana Leonova was extradited from France to the US to face charges for conspiring to violate export controls by procuring avionics and aircraft equipment to be exported to Russia. The case is being investigated by the FBI in Kansas City, Atlanta, and New York.
- In the UK, the London branch of Swiss art gallery Hauser & Wirth and arts logistics company Artay Rauchwerger Solomons were charged with breaching Russian sanctions by enabling the purchase of a work of art by an individual connected to Russia. While the individual was not himself sanctioned, the sale violated export controls on luxury goods.
Other Regulatory Updates
- The US lifted its arms embargo on Cambodia, first imposed in 2021 due to violations of human rights and Chinese involvement in the country’s military. This lifting comes amidst renewed engagement between Cambodia and the US regarding defence, although defence-related export controls remain in place and exemptions will be considered on a case-by-case basis.
- Amendments to the EU’s dual-use regulation came into force in November, adding new items subject to export controls to include quantum technology, semiconductor manufacturing and testing equipment, advanced computing integrated circuits and electronic circuits, coatings for high temperature applications, and peptide synthesisers. The EU also extended its sanctions regime against Turkey related to unauthorised drilling activity in Cypriot-claimed waters for another year and UN sanctions against Yemen will similarly remain in force until November 2026.
- OFSI issued a general licence, active until February 2026, authorising transactions with two Bulgarian subsidiaries of Lukoil, which was sanctioned in October 2025. Later in the month, this was extended to a further two subsidiaries in Bulgaria. The US issued similar Lukoil and Rosneft-related exemptions. Other US General Licenses issued this month include authorisations for transactions related to the Paks II nuclear plant project in Hungary.
