Sanctions in 2024: Global Pressure Points in the UN, U.S., EU, and UK

Since the beginning of 2024, there has been a significant evolution in global sanctions as western nations continue to respond to geopolitical challenges like the war in Ukraine, human rights abuses, and evolving threats from actors such as Iran, Russia, and Belarus. Significant sanctions developments from the United Nations, United States, European Union, and United Kingdom, underscored each jurisdiction and organization’s specific developments and illustrated their coordinated stance.

United Nations

While the UN Security Council has no sanctions regime against Russia, because Russia is a permanent member and has veto power, it continued enforcing sanctions on jurisdictions such as North Korea, Yemen, Syria, and various African countries.

• Sanctions on North Korea: The UN maintained strict sanctions on North Korea in response to continued missile tests. The UN Security Council failed to extend the mandate of the Panel of Experts on North Korea, after Russia vetoed the resolution, arguing that these sanctions were ineffective and outdated. The veto, which drew widespread condemnation from many Council members, was seen as undermining global non-proliferation efforts and weakening the international sanctions regime. UN sanctions against North Korea are still in effect, and several nations have committed to enforcement of those sanctions.
• Sanctions on Africa: The UN expanded sanctions on African conflict zones, with special focus on regions plagued by conflict, such as the Democratic Republic of Congo (DRC). In early 2024, the UN announced sanctions targeting illegal mining operations in DRC, aiming to curb funding for militias and reduce regional instability.
• Humanitarian Exemptions and Sanctions Reform: Amid calls for sanctions reform, the UN introduced more robust humanitarian exemptions to mitigate sanctions’ unintended effects on civilian populations. These exemptions, designed for regions like Syria and Yemen, allow for greater flexibility in delivering humanitarian aid without risking compliance penalties. These measures reflect the growing need for a balanced approach that limits harm to vulnerable populations​.

U.S. Sanctions Updates

The United States in 2024 increased its sanctions pressure, particularly in relation to Russia and Iran, and introduced measures impacting various sectors.

• Iran and Secondary Sanctions: The Iran-China Energy Sanctions Act, signed into law in April, 2024, as part of the 21^st Century Peace Through Strength Act, expands secondary sanctions against Iran to cover all transactions between Chinese financial institutions and sanctioned Iranian banks used to purchase Iranian petroleum products. The legislation also authorizes sanctions against foreign financial institutions involved in the purchase of Iranian unmanned aerial vehicles (UAVs), UAV parts, or related systems. The Act marks an effort to curtail support for Iran’s military-industrial complex on a global scale, limiting its profits from the sale of petroleum products and drones, and further complicating China-U.S. relations​​.
• Russia Sanctions: In response to ongoing conflict in Ukraine, the United States issued sanctions targeting Russia’s energy sector and military-industrial supply chain. The United States also targeted Russian maritime operations, placing restrictions on Russian ships and entities that operate in European waters, in collaboration with EU counterparts​. In June 2024, the U.S. Treasury Department published updated guidance on sanctions targeting Russia’s military-industrial base, which stated that any individual or entity sanctioned under EO 14024 is considered by the United States as being part of Russia’s war economy, and is therefore subject to secondary sanctions risk. Foreign financial institutions can be sanctioned for transacting with any individual or entity designated pursuant to EO 14024, even if the transaction does not involve a U.S. person or the U.S. financial system.
• Enforcement Measures and Compliance Guidance: OFAC, along with the Department of Justice (DOJ) and the Bureau of Industry and Security (BIS), this year issued joint guidance emphasizing risk-based compliance strategies for both U.S. and non-U.S. entities. The agencies also issued various guidance on their own, such as the BIS guidance to financial institutions on best practices for compliance with the Export Administration Regulations (EAR). These notes encourage firms to proactively manage sanctions risks, highlighting whistleblower rewards as incentives for disclosing potential sanctions violations. This underscores the complexity of U.S. sanctions and export controls, as well as the difficulties detecting and deterring evolving ​sanctions evasion techniques. Although U.S. authorities have issued several guidance documents regarding enforcement and evasion, further guidance likely will be released to help combat evolving evasion techniques.

European Union Sanctions Updates

The EU’s 2024 sanctions reflect an increasingly coordinated approach, particularly with the U.S. and UK, targeting Russia’s war economy and Iran’s arms supply network.

• 13th Sanctions Package on Russia: The EU adopted its 13th package of sanctions against Russia in February 2024 for the second anniversary of Russia’s invasion of Ukraine. This package targeted Russia’s military-industrial complex, with 194 individuals and entities designated, including companies involved in drone and missile production and those supporting Russian war in Ukraine via third countries. The EU also strengthened export restrictions, targeting key technologies for military use, and continues to work with international partners to prevent sanctions evasion, ensuring that Russia is further deprived of critical resources to sustain its war efforts.
• 14th Sanctions Package on Russia: The EU adopted its 14th package of sanctions against Russia in June 2024, intensifying measures to reduce the Kremlin’s ability to finance its war in Ukraine. Key actions include a ban on investments and exports to Russian liquefied natural gas projects, restrictions on vessels supporting Russia’s military, and a financial sanctions package targeting Russian banks and third-country banks facilitating Russian defense activities. The EU also imposed additional export restrictions on advanced technologies and industrial goods, while stepping up efforts to curb sanctions circumvention. The sanctions reinforce EU support for Ukraine and aim to further isolate Russia economically and technologically.
• Belarus and Coordination with the U.S., Canada, and UK: In a coordinated effort with the United States, Canada, and the UK, the EU imposed sanctions on Belarusian entities that support Russia’s war efforts. New restrictions in June targeted Belarus’s aviation industry, prohibiting maintenance and service transactions involving Belarusian aircraft that could potentially support Russian logistics​.
• Enhanced Trade and Export Controls: The EU introduced tighter export controls on goods that could support authoritarian regimes or aid their military development, including restrictions on sensitive technology exports to third countries that might resell or provide resources to Russia or other sanctioned entities. The EU’s controls are specifically stringent regarding dual-use goods that might indirectly benefit Russia’s military capabilities​.

United Kingdom Sanctions Updates

The UK implemented autonomous sanctions targeting Russian and Iranian actors, often in coordination with the EU and the United States but reflecting its own post-Brexit approach to international sanctions.

• Sanctions on Iranian Missile and UAV Programs: Following Iran’s alleged involvement in supplying drones and missile technology to Russia, the UK sanctioned Iranian firms and key officials involved in these programs. The UK also imposed asset freezes and travel bans on senior officials in Iran’s military and aerospace sectors, aiming to disrupt the flow of Iranian-manufactured drones to the Ukrainian conflict. The UK also designated five Russian cargo ships for their role in transporting military supplies to Russia from Iran.
• Expanding Financial Restrictions on Russia and Belarus: The UK’s Foreign, Commonwealth & Development Office (FCDO) coordinated with the EU and United States to announce sanctions in August 2024 against Belarusian entities and individuals, marking the anniversary of the 2020 Belarusian presidential election widely deemed fraudulent. In addition, this year’s sanctions focused on Belarus’s defense and aviation sectors and imposed restrictions on the access to UK financial markets, preventing sanctioned Russian and Belarusian actors from financing military efforts through British banks​.
• The UK in November 2024 significantly expanded its sanctions on Russia’s military-industrial complex, announcing a package of 56 sanctions, marking the largest sanctions package since May 2023. The designations include measures against Russian-backed mercenary groups in Africa, as well as individuals involved in the 2018 nerve agent attack in the UK. The sanctions also target suppliers of critical components, such as microelectronics and ball bearings, from countries like China, Türkiye, and Central Asia, with the goal of undermining Russia’s military capabilities.

• Asset Freezes and Compliance Monitoring: In an effort to increase transparency and accountability, the UK’s sanctions now include enhanced reporting requirements for financial institutions to monitor and report suspicious transactions linked to sanctioned individuals. This complements the UK’s broader anti-money laundering (AML) efforts, particularly for high-profile Russian oligarchs holding assets in the UK​.
• Creation of the Office of Trade Sanctions Implementation (OTSI): The OTSI was established to enhance the UK’s enforcement of trade sanctions, with a focus on civil enforcement related to UK services and international trade. OTSI’s powers, effective from October 10, 2024, include the ability to impose monetary penalties, make public disclosures, and require information from businesses. It helps companies comply with sanctions and trade restrictions through guidance and engagement, provides licenses for services like professional and business services, and enforces reporting obligations on certain sectors. OTSI works alongside HM Revenue & Customs (HMRC), which handles criminal enforcement, and can refer serious cases of sanctions evasion for potential prosecution.

Sanctions Evasion

Sanctions evasion remained a critical challenge in 2024, with the United States, EU, and UK intensifying efforts to detect and disrupt criminal actors that try to circumvent sanctions. The United States reinforced its export controls and leveraged new legislation to impose secondary sanctions on foreign firms suspected of aiding sanctioned actors, especially in high-risk jurisdictions such as Russia and China. OFAC released new guidance urging businesses to monitor supply chains closely for indirect connections to sanctioned parties.

The EU and the UK expanded focus on sanctions and trade control evasion by placing stricter controls on dual-use goods and targeting intermediary companies that support sanctioned industries. In a joint effort with the United States and Canada, the UK in October implemented its largest sanctions package against Russia’s “shadow fleet” of oil tankers, banning them from UK ports and barring access to British maritime services for violating restrictions on Russian energy exports. These coordinated efforts reflect a shared commitment to enforcing sanctions and addressing the sophisticated evasion tactics that criminal actors attempt to use on a global scale.