Sanctions and Export Controls Update

United States 

Syria Sanctions  

On July 1, 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) implemented President Trump’s Executive Order revoking broad sanctions on Syria, supporting the country’s transition under its new government. As part of the shift, OFAC removed 518 individuals and entities from the SDN List, unblocking assets tied to Syria’s development and reconstruction. However, sanctions remain on Bashar al-Assad, his associates, and others tied to terrorism, human rights abuses, or drug trafficking. OFAC also designated 139 individuals and entities under amended authorities to ensure continued accountability for past regime-linked actions and regional destabilizers, while facilitating Syria’s re-entry into global commerce.  

• June 30: Treasury Implements President’s Termination of Syria Sanctions 

• June 30: Providing for the Revocation of Syria Sanctions 

U.S. Secretary of State Marco Rubio announced that President Trump will be revoking the foreign terrorist organization (FTO) designation of al-Nusrah Front, also known as Hay’at Tahrir al-Sham (HTS), under the Immigration and Nationality Act, effective July 8. The move is in line with President Trump’s pledge to lift sanctions on Syria. The action follows the announced dissolution of HTS and the Syrian government’s commitment to counter terrorism in all its forms, and recognizes the positive actions taken by Syrian President Ahmed al-Sharaa. 

• July 7: Revoking the Foreign Terrorist Organization Designation of Hay’at Tahrir al-Sham 

Iran Sanctions 

OFAC sanctioned several entities involved in the illicit transportation and sale of Iranian oil, with a focus on networks that have been smuggling oil disguised as Iraqi oil. This includes a network controlled by Iraqi businessman Salim Ahmed Said, whose companies blend Iranian oil with Iraqi oil to bypass sanctions, using ship-to-ship transfers and fake documentation. Said’s operations also involve bribing Iraqi officials to facilitate these sales. The sanctions also target vessels and shipping companies involved in these activities, including those used by Iran’s shadow fleet. OFAC’s actions aim to disrupt Iran’s access to the financial resources fueling its destabilizing activities, while increasing pressure on the Iranian regime’s oil trade. Additionally, sanctions have been imposed on companies involved with the IRGC-QF, a key player in Iran’s oil smuggling operations, including its use of vessels to transport Iranian oil under false pretenses. 

• July 3: Treasury Targets Diverse Networks Facilitating Iranian Oil Trade 

OFAC sanctioned 22 entities across Hong Kong, the UAE, and Türkiye for their involvement in facilitating the sale of Iranian oil that funds the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. These entities, including front companies, were used to bypass sanctions by transferring funds to the IRGC-QF through offshore accounts. The proceeds from these oil sales support Iran’s weapons programs and terrorist activities in the Middle East. OFAC’s action is part of a broader effort to disrupt Iran’s shadow banking system and prevent its destabilizing actions. The sanctions, issued under Executive Order 13224, target both the companies involved in these illicit transactions and those directly controlled by the IRGC. 

• July 9: Treasury Targets Additional Elements of Iran’s “Shadow Banking” Network 

In its largest Iran-related sanctions package since 2018, the U.S. Department of the Treasury targeted the illicit oil shipping and money laundering networks of Mohammad Hossein Shamkhani, the son of a top political advisor to the Supreme Leader of Iran. Shamkhani used his father’s political influence to raise tens of billions of dollars primarily through the export of Iranian and Russian oil, most often to customers in China. The networks were supported by a fleet of vessels, ship management firms, front companies, and accomplices around the world, and ultimately benefitted the Iranian regime and Shamkhani personally. Over 115 persons across 20 jurisdictions were sanctioned in Treasury’s action. 

• July 30: Treasury Takes Massive Action Against High-Profile Iranian Network 

Venezuelan Criminal Organizations 

OFAC designated the leader of Tren de Aragua and five other key members as Specially Designated Global Terrorists. The individuals are responsible for organizing illegal mining operations, sourcing military-grade weapons for the group, the murder of Venezuelan officials, narcotics and human trafficking, and money laundering, among other activities. Treasury’s targeted sanctions were the result of U.S interagency coordination, including with the Department of Justice’s Joint Task Force Vulcan. Tren de Aragua, a Venezuelan transnational criminal organization, was designated as a Foreign Terrorist Organization by the Trump administration in February 2025.  

• July 17: Treasury Sanctions Top Leaders of Tren de Aragua 

OFAC sanctioned the Cartel de los Soles, a Venezuelan organization headed by President Nicolas Maduro Moros and members of his regime, as a Specially Designated Global Terrorist. The Cartel de los Soles provided material support to Tren de Aragua and the Sinaloa Cartel, both of which are involved in narcotics trafficking, human smuggling and trafficking, money laundering, and other criminal activities, and have been designated as Foreign Terrorist Organizations by the Department of State. Treasury’s action highlights the Maduro regime’s sponsorship of narco-terrorism and underscores the United States’ commitment to dismantle cartels and other actors contributing to destabilizing activities.    

• July 25: Treasury Sanctions Venezuelan Cartel Headed by Maduro 

Other Sanctions Issues 

OFAC sanctioned seven senior officials and one entity linked to Hizballah’s financial institution, Al-Qard Al-Hassan (AQAH). These individuals, who have played key roles at AQAH, facilitated the group’s evasion of U.S. sanctions, enabling Hizballah to access the formal financial system and funnel money for its operations. This action reinforces the United States’ commitment to disrupting Hizballah’s financial network and supporting efforts by the Lebanese government to limit the group’s influence. Treasury’s move targets AQAH officials who have long been involved in hiding Hizballah’s financial transactions and furthering its agenda, undermining Lebanon’s economy and exposing banks to money laundering risks. 

• July 3: Treasury Sanctions Hizballah Financial Officials 

The U.S. has significantly rolled back permissions for exporting liquefied petroleum gas (LPG) to Venezuela, based on a revised general license from OFAC. Under the updated sanctions, LPG can only be offloaded if it was loaded onto a vessel by July 7 and arrives in Venezuela by September 5. The new rules also ban payment-in-kind involving petroleum or related products and prohibit any dealings with blocked individuals or entities except for Petróleos de Venezuela (PDVSA) and select government-affiliated organizations. This update, outlined in General License No. 40D effective July 7, replaces the earlier License 40C issued in 2024. 

• July 7: Authorizing the Offloading of Liquefied Petroleum Gas in Venezuela 

The Department of State imposed visa restrictions on officials of the Cuban government and prison personnel involved in human rights violations related to the detention and torture of demonstrators in the July 2021 protests. Eleven regime-linked properties were also added to the Cuba Restricted List and Cuba Prohibited Accommodations List to restrict the government’s access to U.S. financial resources. The sanctions are the first to be issued in-line with National Security Presidential Memorandum-5, published on June 30, 2025, which sets forth the Trump administration’s policy approach toward Cuba.  

• July 11: Justice for the Cuban People on the Fourth Anniversary of the July 11 Protests 

Export Controls  

Bahram Mohammad Ostovari, an Iranian national and U.S. lawful permanent resident, was indicted on four charges for allegedly exporting electronics used in railway signaling and telecommunications systems from the United States to Iran by way of the UAE. Ostovari controlled a Tehran-based engineering company that supplied Iran and its government with sophisticated computer processors and other electronic components, allegedly routing the goods through two front companies he controlled in the UAE without acquiring a license from U.S. authorities. The Departments of Homeland Security and Commerce are investigating the case, and if convicted, Ostovari faces a maximum penalty of 20 years in prison for each count.   

• July 11: CEO of an Iranian Engineering Company Arrested for Allegedly Shipping Sophisticated Electronics from the U.S. to Iran in Violation of U.S. Sanctions  

Cadance Design Systems pleaded guilty to violating export controls related to its sale of electronic design automation (EDA) hardware, software, and semiconductor design intellectual property technology to the National University of Defense Technology (NUDT) of China. Between February 2015 and April 2021, Cadence and its Chinese subsidiary conspired to transfer EDA tools subject to the Export Administration Regulations to NUDT, which was placed on the Entity List in 2015 for its use of U.S.-origin components in supporting nuclear explosive simulation and military simulation activities for the PRC’s Central Military Commission. Candence admitted that its employees conspired to conceal the identity of the end user, transferred the restricted items to NUDT, and installed hardware on its campuses. The company agreed to pay over $140 million in civil and criminal penalties for its violations.  

• July 28: Cadence Design Systems to Pay $95 Million Penalty to BIS for Unauthorized Exports to Chinese Entities Tied to Development of Military Supercomputers  

• July 28: Cadence Design Systems Agrees to Plead Guilty and Pay Over $140 Million for Unlawfully Exporting Semiconductor Design Tools to a Restricted PRC Military University