Sanctions and Export Controls Update

Monthly Roundup – April 2025

📅 May 5, 2025

Welcome to this month’s Sanctions and Export Controls Update, highlighting IFI’s take on key developments from April 2025.

U.S. authorities took numerous actions to increase pressure on Iran—most notably designating a bank in Yemen, a terminal operator and an independent “teapot” refinery in China, and several UAE-based intermediaries. The U.S. also continued to target Mexican cartels involved in trafficking fentanyl and other drugs and implemented a new program to protect Americans’ sensitive data from foreign adversaries.

The EU imposed additional sanctions against Iran for serious human rights violations, renewed sanctions against actors responsible for destabilizing Moldova, and updated its arms export control framework. Meanwhile, the UK imposed additional restrictions on trade with Russia and relaxed sanctions on Syria.

United States

U.S. sanctions in April focused almost exclusively on Iran and counternarcotics, reflecting the Trump administration’s national security and foreign policy priorities to maximize pressure on Iran and to combat drug cartels and stop the flow of deadly drugs into the United States. The U.S. also began implementing a Data Security Program that establishes what are effectively export controls that prevent foreign adversaries from accessing U.S. government-related data and Americans’ sensitive personal data.

Iran Sanctions

The Treasury and State Departments collectively took eleven actions to impose additional sanctions on Iran and its proxies.

“As Treasury Secretary, I want to assure the American people that I am fully committed to using every available tool to prevent Iran and its terrorist proxies from gaining access to the U.S. dollar and the broader financial system. Iran continues to conduct its foreign exchange activities through a covert shadow banking network, and my message to financial institutions worldwide is unequivocal: safeguard your institutions from being exploited by this malign network, so you can continue to serve your legitimate clients with integrity.”

– Treasury Secretary Scott Bessent, April 2, 2025, public-private partnership event

The most notable Iran sanctions actions included:

Houthi Support Networks: State designated the Houthis as a Foreign Terrorist Organization (FTO) and Treasury designated a bank in Yemen being used by the Houthis to access the international financial system; a network of individuals and entities in Russia, Hong Kong, and Türkiye procuring weapons and commodities from Russia for the Houthis; three vessels and their Marshall Islands– and Mauritius-registered owners for delivering oil derivatives to the Houthis; and identified eight digital asset wallets used by the Houthis to transfer funds.
Military and Nuclear Procurement Networks: Treasury and Justice took action against a network of entities and individuals based in Iran, the UAE, and China responsible for procuring unmanned aerial vehicle (UAV) components for Iran’s military, including three UAE-based companies serving as financial intermediaries; a separate network of individuals and entities in Iran and China for their role in procuring ballistic missile propellant ingredients on behalf of Iran’s IRGC; and five entities and an individual based in Iran that procure and manufacture critical technologies for Iran’s nuclear program.
Iran’s Oil Network: In five separate actions, Treasury and State imposed sanctions on a UAE– and India-based Iranian petroleum transportation network including nearly 30 vessels; a China-based terminal operator and a China-based independent “teapot” refinery that purchased more than a billion dollars’ worth of Iranian crude oil; several vessels that are part of Iran’s “shadow fleet” responsible for oil shipments to China and their owners, managers, and operators based in Panama, Malaysia, Marshall Islands, and Hong Kong; and one Türkiye-based and four UAE-based entities that have exported hundreds of millions worth of shipments containing Iranian-origin petrochemical products to third party countries.

OFAC also issued an updated sanctions advisory to assist global shipping and maritime stakeholders in detecting and mitigating Iranian oil sanctions evasion and in implementing compliance best practices to guard against such sanctions risks.

April 1: Treasury and Justice Take Action Against Iranian Weapons Procurement Network

April 2: Treasury Sanctions Houthi Network Procuring Weapons and Commodities from Russia

April 9: State Designates Ansarallah (the Houthis) as a Foreign Terrorist Organization

April 9: Treasury Imposes Sanctions Against Enablers of Iran’s Nuclear Program

April 10: Treasury and State Impose Sanctions on Iran’s Oil Network

April 16: Treasury Increases Pressure on Chinese Importers of Iranian Oil

April 17: Treasury Targets International Bank of Yemen for Support to the Houthis

April 22: Treasury Targets Iranian Liquified Petroleum Gas Magnate and his Corporate Network

April 28: Treasury Targets Vessels Delivering Oil Derivatives to the Houthis

April 29: Treasury Targets Network Procuring Missile Propellant Ingredients for Iran

April 30: State Sanctions Illicit Traders of Iranian Petroleum and Petrochemical Products

Drug Cartel Sanctions

Building on its sanctions against criminal operators and money launderers for the notorious Sinaloa Cartel at the end of March, the Treasury Department in April took action against two additional Mexican drug trafficking organizations and issued a 20-page Financial Trend Analysis focused on patterns and trends identified in Bank Secrecy Act (BSA) data linked to fentanyl-related illicit finance.

“As Treasury continues to prioritize combating the illegal production and trafficking of fentanyl, our public-private partnerships are vital,” said Secretary of the Treasury, Scott Bessent.  “As today’s analysis shows, the information we receive from financial institutions is a critical element in our ability to more effectively investigate and disrupt the malicious actors that profit off this unprecedented epidemic, and ultimately aids in the effort to save American lives.”

OFAC designated four individuals affiliated with La Nueva Familia Michoacana (LNFM), a Mexican cartel designated as a Foreign Terrorist Organization. The action was taken in coordination with the Department of Justice, which indicted two of the individuals, and the Department of State, which announced Narcotics Rewards Offers for information leading to their arrests, as well as the Drug Enforcement Administration, Homeland Security Investigations, and Mexico’s Financial Intelligence Unit.
OFAC sanctioned a key leader of the Mexico-based Beltran Leyva Organization (BLO), one of the most powerful drug trafficking organizations in the world, for playing a significant role in transporting and distributing fentanyl and other drugs to the United States. The Treasury announcement highlighted that in December 2024 Mexican forces conducted operations against BLO resulting in the largest seizure of fentanyl in Mexican history—over a thousand kilos, the equivalent of 20 million doses of fentanyl.

Concurrent with the BLO designation, FinCEN issued a Financial Trend Analysis that highlighted various aspects of the illicit fentanyl supply chain—including precursor chemical procurement, fentanyl trafficking, and fentanyl-linked money laundering—that have touchpoints across the U.S. financial sector.
April 9: Treasury Targets Key Leader of Violent Mexican DTO Implicated in Record-Breaking Seizure of Fentanyl
April 9: FinCEN Analysis of Fentanyl-Related Threat Patterns and Trends in Bank Secrecy Act Reports
April 15: Treasury Sanctions Leaders of La Nueva Familia Michoacana Drug Cartel

Data Security Program

The Department of Justice National Security Division announced the implementation of a Data Security Program to prevent China, Russia, Iran, and other foreign adversaries from using commercial activities to access and exploit U.S. government-related data and Americans’ sensitive personal data to commit espionage and economic espionage, conduct surveillance and counterintelligence activities, develop AI and military capabilities, and otherwise undermine our national security.

April 11: Justice Department Implements Critical National Security Program to Protect Americans’ Sensitive Data from Foreign Adversaries

European Union

The Council of the EU imposed sanctions against seven individuals and two entities responsible for serious human rights violations in Iran and decided to prolong sanctions against those responsible for destabilizing, undermining, or threatening the sovereignty and independence of Moldova. Poland imposed sanctions on a Russian supermarket chain with locations Europe for supporting Russia’s aggression against Ukraine, and Estonian authorities sentenced a woman to over a year in prison for violating EU sanctions against Russia. Finally, the EU Council updated its arms export control framework reaffirming its commitment to responsible and transparent arms trade, preventing diversion to unauthorized users, and aligning Member States’ policies under the Common Foreign and Security Policy.

April 14: Iran: seven individuals and two entities targeted by EU’s sanctions over serious human rights violations

April 14: Control of arms exports: Council reviews the EU framework to strengthen control and accountability in the international arms trade

April 15: Estonian woman jailed for violating EU sanctions against Russia

April 28: Republic of Moldova: EU restrictive measures renewed until 29 April 2026

April 29: Poland imposes sanctions on MyPrice Russian discount supermarket chain

United Kingdom

The UK imposed new trade sanctions on Russia that prohibit the export of certain specified items—including chemicals, electronics, machinery, plastics, metals, technology, and software—and ban the import of Russia-sourced helium and diamonds processed in third countries. The UK also lifted sanctions on some sectors in Syria including financial services and energy production, with the aim of helping to facilitate essential investment in Syria’s energy infrastructure and supporting the Syrian people to rebuild their country and economy. OFSI published threat assessment reports on the legal services and property and replated services sectors, and the Department for Business and Trade issued a new license allowing UK exporters to send specific dual-use items to permitted destinations for oil, gas, and renewable energy projects.

April 3: OFSI published Legal Services Threat Assessment

April 10: OFSI published Property and Related Services Threat Assessment

April 15: Open General Export License (Oil and Gas Exploration: Dual-Use Items)

April 24: UK Government Imposes New Restrictive Measures Against Russia

April 24: UK bolsters support for Syrian people by amending Syria sanctions

Recorded Webinar

On May 21st, IFI, Crowell & Moring, and K2 Integrity hosted a discussion on the current global framework for sanctions and export controls, including a look ahead to what’s on the horizon.

In recent years, sanctions and export controls have escalated to an unprecedented level of complexity. With the shift in U.S. administration, new policy priorities are emerging bringing changes in enforcements, regulatory expectations, and international standards.

Whether you’re looking to deepen your subject-matter expertise or build strategic initiatives into your compliance program, this webinar offers practical guidance for staying ahead in a shifting regulatory environment.

Watch the Recording

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