Sanctions and Export Controls Update

Monthly Roundup – October 2025

📅 November 5, 2025

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

The three most significant developments in October included:

The shift in policy by the Trump administration to impose new sanctions on Russia
The largest ever action by the U.S. and UK targeting cybercriminal networks in Southeast Asia
The suspension of BIS’s new 50% Affiliates Rule

The West significantly intensified pressure on Moscow in late October, most prominently by the EU adopting its 19th sanctions package and the U.S. and UK sanctioning Rosneft and Lukoil—Russia’s two largest oil companies. The U.S. and UK also imposed sweeping sanctions against hundreds of targets associated with a Cambodia-based transnational criminal organization responsible for industrial scale cyberfraud operations globally. After trade talks with China, the U.S. announced the suspension of BIS’s new 50% Affiliates Rule, which would have dramatically expanded the number of Chinese companies subject to U.S. trade restrictions.

Major Intensification of Russia Sanctions

In a major shift in the Trump administration’s sanctions policy, Treasury imposed blocking sanctions on Rosneft and Lukoil. These were the first designations targeting Russia by the second Trump administration and came after plans for a summit between Presidents Trump and Putin in Budapest fell through amidst a sustained lack of progress towards a peace deal by Russia and Ukraine. Rosneft and Lukoil produce more than 5 billion barrels of crude oil annually, which is around 50% of total Russian oil production. The U.S. sanctions were magnified the UK unleashing its strongest sanctions yet on Russia and by the EU adopting a sweeping package of new sanctions targeting Russian energy, third-country banks, and crypto providers.

Treasury’s rollout included 34 subsidiaries of Rosneft and Lukoil that operate in oil and gas production, refining, and distribution. Moreover, all entities owned 50% or more, directly or indirectly, by Rosneft, Lukoil, and their designated subsidiaries are also considered blocked. Treasury Secretary Scott Bessent said that Treasury is prepared to take further action, if necessary, which could signal future secondary sanctions measures against foreign financial institutions that facilitate significant transactions for these firms.
The UK introduced a new package of sanctions against Russia targeting 90 entities, including Rosneft and Lukoil, four Chinese oil terminals, 44 shadow fleet tankers transporting Russian oil, and India-based Nayara Energy, which imported 100 million barrels of Russian crude in 2024. The UK said it will also ban imports of oil products refined in third countries from Russian-origin crude to limit Russia’s access to global markets.
The EU approved its 19th package of sanctions against Russia. Key measures include a phased ban on Russian liquefied natural gas imports by 2027, sanctions on Chinese and UAE entities aiding Russian oil exports, and restrictions on 557 vessels circumventing the oil price cap. The EU sanctions also target Russian crypto operations linked to war financing and ban several banks from Russia, Belarus, and Central Asia involved in sanctions evasion.

Coordinated Actions Targeting the Prince Group

Source: OFAC

The U.S. and UK took what the Treasury Department called the largest action ever targeting cybercriminal networks in Southeast Asia. They imposed sweeping actions on over 100 targets associated the Prince Group Transnational Criminal Organization, a Phnom Penh-based network led by Cambodian national Chen Zhi. The Prince Group has reportedly carried out numerous transnational crimes including the construction, operation, and management of scam compounds reliant on human trafficking and modern-day slavery where industrial scale cyberfraud operations target victims around the world. The bilateral sanctions actions were accompanied by the unsealing of a criminal indictment in U.S. district court against Chen Zhi.

FinCEN concurrently finalized a rule under section 311 of the USA PATRIOT Act to sever the Cambodia-based financial services conglomerate, Huione Group, from the U.S. financial system. Huione Group reportedly serves as a critical node for laundering proceeds of cyber heists carried out by North Korea and for transnational criminal organizations in Southeast Asia perpetrating virtual currency investment scams, commonly known as “pig butchering” scams, among others.
As part of the crackdown, UK authorities froze a £12 million mansion in North London, a £100 million office building in the City of London, and seventeen flats in South London. In addition, the Singapore police seized six properties and various financial assets, including bank accounts, securities accounts, a yacht, 11 cars, and cash, with a total estimated value of over S$150 million.
Three days after the Prince Group sanctions dropped, the Organized Crime and Corruption Reporting Project (OCCRP) published a report identifying 29 prestigious properties in Dubai that were purchased by Jack Zhu, a Prince Group executive who was part of the tranche of designations.

Suspension of BIS’s 50% Affiliates Rule

During a televised interview on 31 October, Treasury Secretary Scott Bessent announced that the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) will suspend implementation of the “Affiliates Rule” that was adopted in September. Under the rule, BIS expanded the scope of the Entity List to also apply to non-U.S. entities owned, directly or indirectly, 50% or more by another party or parties included on the Entity List. This would have dramatically expanded the number of Chinese companies subject to U.S. trade restrictions. According to Bessent, the rule would be suspended for one year in exchange for China’s suspension of its proposed export controls on rare earth minerals.

Other Significant Developments

Iran

Treasury Identifies $9 Billion of Potential Iranian Shadow Banking Activity in 2024

Treasury’s FinCEN issued a 20-page report identifying approximately $9 billion of potential Iranian shadow banking activity that occurred through U.S. correspondent accounts in 2024, based on reporting from U.S. financial institutions. According to FinCEN, Tehran relies on shadow banking networks of Iran-based exchange houses and foreign front companies to evade sanctions, which are connected across continents – most prominently through the UAE, Hong Kong, and Singapore.

U.S. Imposes Sanctions on Iraqi Network Laundering Money for Iran

Treasury designated multiple Iraqi individuals and entities linked to Iran’s Islamic Revolutionary Guard Corps–Quds Force (IRGC-QF) involved in laundering money and aiding operations against American interests. The targets allegedly laundered tens of millions of dollars for Iran and engaged in corruption through political and commercial ties. According to Treasury, Iran continually seeks to take advantage of Iraq’s economy to evade sanctions, despite progress made by many Iraqi government and financial professionals to secure and modernize their institutions.

Treasury Announces New Sanctions on Iran’s Petroleum Shipment Facilitators

OFAC imposed new sanctions on more than 50 individuals, entities, and vessels linked to Iran’s petroleum and petrochemical exports. The move targets networks that have facilitated billions of dollars in Iranian oil and liquefied petroleum gas sales, including a China-based crude oil terminal and an independent “teapot” refinery.

Treasury Designates Military Procurement Networks

OFAC designated 21 entities and 17 individuals tied to Iranian procurement networks supporting the Ministry of Defense and Armed Forces Logistics (MODAFL), ballistic missile development, and military aircraft production. The designations follow the September 27 U.N. “snapback” sanctions on Iran. OFAC targeted networks operating in Iran, China, Hong Kong, Germany, Türkiye, Portugal, and Uruguay procuring sensitive technologies.

U.S. Supreme Court Rejects Appeal by Turkey’s Halkbank

The U.S. Supreme Court rejected an appeal by Turkey’s Halkbank, leaving the state-controlled lender to face criminal charges that it helped Iran to evade economic sanctions and launder billions of dollars through the American financial system.

UK Announces Sanctions on Iranian Banker for Financial Support to IRGC

The UK imposed sanctions on Iranian national Aliakbar Ansari for his role in financially supporting the Islamic Revolutionary Guard Corps (IRGC). The measures include an asset freeze, director disqualification, and a travel ban. The United Kingdom has now sanctioned more than 500 individuals and entities as part of its Iran sanctions program.

Transnational Organized Crime

U.S. Designates Fentanyl Supply Network Linked to Sinaloa Cartel

OFAC imposed sanctions on eight Mexican nationals and 12 companies tied to the Sinaloa Cartel’s Los Chapitos faction, a group led by the sons of Joaquin “El Chapo” Guzman Loera. The network allegedly supplied precursor chemicals used in illicit fentanyl production. The action targeted Culiacan-based Sumilab and related firms operated by the Favela Lopez family, which continued chemical sales to cartel-linked producers even after earlier sanctions. OFAC also sanctioned broker Martha Emilia Conde Uraga and her front companies for supplying chemicals to drug traffickers and lab operators working for the faction.

U.S. Imposes Sanctions on Mexican Human Smuggling Network

Treasury announced sanctions against the Bhardwaj Human Smuggling Organization (HSO), its leader Vikrant Bhardwaj, three associates, and 16 affiliated companies involved in human smuggling, drug trafficking, and money laundering. The group allegedly smuggled thousands of migrants from Europe, the Middle East, South America, and Asia into the U.S.

U.S. Designates Colombian President’s Support Network Over Corruption, Illicit Financing

Treasury designated three close associates of Colombian President Gustavo Petro—his son Nicolas Petro, First Lady Veronica Alcocer, and Interior Minister Armando Benedetti—for their alleged involvement in corruption and illicit financial activities supporting the president.

U.S. Sanctions Haitian Gang Leaders Tied to Terrorist Group Viv Ansanm

OFAC sanctioned former Haitian police officer Dimitri Herard and gang leader Kempes Sanon for supporting the Haitian gang coalition Viv Ansanm, designated earlier this year as a foreign terrorist organization. Herard, linked to the 2021 assassination of President Jovenel Moïse, allegedly trained and armed gang members after escaping from prison in 2024.

Export Controls and Investment Security

U.S., Japan Agree to Strengthen Critical Minerals Supply Chains

The U.S. and Japan established a new bilateral framework to strengthen cooperation on critical minerals and rare earths vital to both nations’ industries. Through coordinated investment and economic policy tools, the framework seeks to accelerate the development of diversified and transparent markets for mining, separation, and processing. It also aims to enhance resilience and security across supply chains while expanding both countries’ production capacities.

U.S. Renews Denial of Export Privileges for Ural Airlines

The U.S. Commerce Department renewed a ban on Ural Airlines’ export privileges for another year due to ongoing violations of U.S. export controls. The Bureau of Industry and Security (BIS) cited repeated, deliberate breaches of the Export Administration Regulations, including unauthorized flights into and within Russia using U.S.-origin aircraft parts.

Commerce Department, Luminultra Reach Settlement Over Unauthorized Exports to Iran

According to BIS, the Canadian firm shipped three PhotonMaster luminometers and 25 aqueous test kits to Iran in 2022 without U.S. authorization. A luminometer is an instrument used to measure visible light emitted by a sample, typically produced by a chemical or biological reaction. The company allegedly disguised the shipment by listing a UAE-based entity as the consignee to conceal that Iran was the true destination. Luminultra agreed to pay a $685,051 civil penalty and conduct annual export compliance audits for three years.

Cyprus Passes Law to Tighten Foreign Investments Screening

Cyprus’ parliament approved legislation to strengthen the screening of foreign direct investment (FDI) in sectors deemed sensitive to national security. The law establishes a national mechanism to monitor foreign investments worth at least EUR 2 million (USD 2.3 million), aligning Cyprus with the European Union’s 2020 FDI Screening Regulation. It covers transactions involving vital infrastructure, including land and property designated as strategically important. The country’s finance ministry will issue temporary guidelines until a national map of critical sites is completed.

UN and EU Sanctions Program Renewals

UN Renews Haiti Sanctions

The UN Security Council has unanimously adopted Resolution 2794 (2025), renewing for one year the sanctions regime on Haiti, including travel bans, asset freezes, and an arms embargo targeting individuals and entities destabilizing the country through illicit resource trade. The resolution also extends the mandate of the Panel of Experts on Haiti for 13 months. Haiti’s representative welcomed the renewal, calling the sanctions a key tool to deter gangs and support national stability alongside the newly formed Gang Suppression Force.

EU Extends Sanctions on ISIL, Al-Qaeda Affiliates

The Council of the EU renewed autonomous restrictive measures against ISIL (Da’esh), Al-Qaeda, and their associated groups for another year, extending them until October 31, 2026. The sanctions target 15 individuals and 7 groups through asset freezes and, for individuals, travel bans to the EU. The measures, which complement UN sanctions, underscore the EU’s continued commitment to counter global terrorism and act against those financing or supporting extremist activities.

EU Renews Russia Destabilization Sanctions

The European Council extended restrictive measures against those responsible for Russia’s destabilizing actions abroad until October 9, 2026, citing continued hybrid activities, including foreign information manipulation and interference. The sanctions regime, covering 47 individuals and 15 entities, imposes asset freezes and travel bans and bars EU citizens and companies from providing funds or economic resources.

EU Extends Sanctions Against Moldova’s Transnistrian Leaders

The Council of the EU extended Decision 2010/573/CFSP, which was set to expire on October 31, by another year. The Decision imposes restrictive measures on leaders of Transnistria, a breakaway region internationally recognized as part of the Republic of Moldova. The extension follows the proposal from the High Representative of the Union for Foreign Affairs and Security Policy.

EU Extends Sanctions Over Chemical Weapons Use

The Council of the EU extended by one year its restrictive measures targeting the proliferation and use of chemical weapons, keeping them in place until October 16, 2026. The sanctions, including asset freezes, funding restrictions, and EU travel bans, currently apply to 25 individuals and six entities. The sanctions framework allows for updates based on new developments, such as the May 2025 addition of three Russian entities linked to chemical weapons use in Ukraine.

Recommended Blogs

Navigating the Convergence of Sanctions Evasion, Export Control Evasion, and Money Laundering

October 22, 2025

Explore the convergence of illicit finance domains through real-life examples including Russia’s procurement of drone components, Iran’s evasion networks, and China’s acquisition of restricted chips.

The BIS 50% Rule

October 2, 2025

Under the new BIS Affiliates Rule, any entity at least 50% owned by a listed party is subject to the same export control restrictions as the parent. The objective of the rule is to close a loophole and more effectively counter diversion of sensitive and restricted items.

Sanctions and Export Controls Update

Monthly Roundup – October 2025

Major Intensification of Russia Sanctions

Coordinated Actions Targeting the Prince Group

Suspension of BIS’s 50% Affiliates Rule

Other Significant Developments

Iran

Transnational Organized Crime

Export Controls and Investment Security

UN and EU Sanctions Program Renewals

Recommended Blogs

Navigating the Convergence of Sanctions Evasion, Export Control Evasion, and Money Laundering

The BIS 50% Rule

September 2025 Sanctions and Export Controls Update

August 2025 Sanctions and Export Controls Update

July 2025 Sanctions and Export Controls Update

Out of the Shadows

Canada’s Strong Borders Act

June 2025 Sanctions & Export Controls Update

May 2025 Sanctions & Export Controls Update