Sanctions and Export Controls Update
Monthly Roundup – April 2025
📅 May 5, 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.
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.
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:
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.
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.”
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.
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.
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.
Join IFI, Crowell & Moring, and K2 Integrity on May 21st for an expert-led masterclass that examines the current global framework for sanctions and export controls—and looks 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 will offer practical guidance for staying ahead in a shifting regulatory environment.
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