Month: December 2025

  • Office of Financial Sanctions Implementation HM Treasury
    OFSI General Licence INT/2025/8202932, Russian Oil Companies Wind Down issuedOn 18 December 2025, the General Licence INT/2025/8202932 was issued. The General Licence allows for Persons to wind down from any transactions involving the Designated Person to which that Person is a party.Any persons intending to use General Licence INT/2025/8202932 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements.

    and here’s the new General Licence:

  • As per the OFSI Notice, the following changes have been made to the Russian sanctions program:

    Additions

    Individuals

    ALIYEV, Chingiz

    • Group ID: 17265
    • Nationality: Azerbaijan
    • Address: Geneva, Switzerland
    • Other Information: (UK Sanctions List Ref): RUS3164. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 18/12/2025.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect that Chingiz ALIYEV is an involved individual under the Russia (Sanctions) (EU Exit) Regulations 2019 because he is or has been involved in: obtaining a benefit from or supporting the Government of Russia, through working as a director.
    • Supplemental Information: Chingiz Aliyev is an oil trader associated with entities involved in the trading of Russian crude oil.

    DOBRINOV, Sergei Viktorovich

    • Group ID: 17269
    • Other Information: (UK Sanctions List Ref): RUS3166.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect that Sergei DOBRINOV is an involved person under the Russia (EU Exit) (Sanctions) Regulations 2019 on the basis of the following ground: Sergei DOBRINOV is or has been involved in obtaining a benefit from or supporting the Government of Russia.
    • Supplemental Information: Sergei Dobrinov is a business associate linked to networks of oil trading companies facilitating the export of Russian energy products.

    LAKHANI, Murtaza Ali

    • Group ID: 17266
    • DOB: 08/03/1962
    • POB: Karachi, Pakistan
    • Nationality: (1) Pakistan (2) Canada
    • Address: London, United Kingdom
    • Other Information: (UK Sanctions List Ref): RUS3165. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 18/12/2025.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect that Murtaza Ali Lakhani, hereafter LAKHANI, is an involved person under the Russia (Sanctions) (EU Exit) Regulations 2019 because: LAKHANI is or has been involved in obtaining a benefit from or supporting the Government of Russia, by owning and/or controlling, directly or indirectly, Tejarinaft FZCO, Amur II – FZCO, and Fossil Trading FZCO, entities carrying on business in a sector of strategic significance to the Government of Russia, namely the Russian energy sector.
    • Supplemental Information: Murtaza Lakhani is the founder and CEO of Mercantile & Maritime Group. He is a veteran oil trader who has historically acted as an intermediary for Rosneft, including facilitating oil deals and advising on Vostok Oil projects.

    MUMINOV, Rustam Rakhimdzhanovich

    • Group ID: 17280
    • Name (non-Latin script): Рустам Рахимджанович Муминов
    • DOB: 26/12/1953
    • POB: Tashkent, Uzbekistan
    • Nationality: (1) Uzbekistan (2) Israel (3) Russia
    • National Identification Number: INN: 773600669995
    • Other Information: (UK Sanctions List Ref): RUS3176.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect that Rustam Rakhimdzhanovich MUMINOV is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 because he is or has been involved in destabilising Ukraine or undermining or threatening the territorial integrity.
    • Supplemental Information: Rustam Muminov is a businessman linked to supply chains supporting Russia’s military-industrial complex, specifically involving chemical components.

    PALEVICH, Andrej Anatolevich

    • Group ID: 17271
    • Name (non-Latin script): Андрей Анатольевич Палевич
    • National Identification Details: INN: 780500259160
    • Position: 100% Shareholder of LLC TEKSTIL-SERVIS
    • Other Information: (UK Sanctions List Ref): RUS3169. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 18/12/2025.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect that Andrej Anatolevich PALEVICH is an “involved person” under the Russia (Sanctions) (EU Exit) Regulations 2019 because he is, or has been, involved in destabilising Ukraine or undermining or threatening the territorial integrity.
    • Supplemental Information: Andrej Palevich controls LLC Tekstil-Servis, a company implicated in the supply of materials such as nitrocellulose to the Russian defence industry.

    Entities

    ALTRUM GROUP FZCO

    • Group ID: 17285
    • Other Information: (UK Sanctions List Ref): RUS3185.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect that ALTRUM GROUP FZCO is an involved person under the Russia (EU Exit) (Sanctions) Regulations 2019 on the basis of the following ground: ALTRUM GROUP FZCO is or has been involved in obtaining a benefit from or supporting the Government of Russia.
    • Supplemental Information: Altrum Group FZCO is a UAE-based entity involved in logistics and trading networks facilitating Russian commodity exports.

    AMUR II FZCO

    • Group ID: 17267
    • a.k.a: AMUR TRADING – FZCO
    • Other Information: (UK Sanctions List Ref): RUS3183. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 18/12/2025.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect AMUR II FZCO is or has been involved in obtaining a benefit from or supporting the Government of Russia by carrying on business in a sector of strategic significance to the Government of Russia, namely the Russian energy sector.
    • Supplemental Information: Amur II FZCO is linked to Murtaza Lakhani and is part of the network used to transport and trade Russian oil.

    FARGONA KIMYO ZAVODI LLC

    • Group ID: 17272
    • Other Information: (UK Sanctions List Ref): RUS3170.
    • Supplemental Information: Fargona Kimyo Zavodi (Fergana Chemical Plant) is an Uzbekistan-based chemical manufacturer that produces cotton cellulose, a key ingredient for explosives and propellants.

    FOSSIL TRADING FZCO

    • Group ID: 17273
    • Other Information: (UK Sanctions List Ref): RUS3181.
    • Supplemental Information: Fossil Trading FZCO is a UAE-based trading vehicle owned or controlled by Murtaza Lakhani, used for dealing in Russian energy products.

    GELION BUSINESS TRADE MCHJ

    • Group ID: 17274
    • Other Information: (UK Sanctions List Ref): RUS3171.
    • Supplemental Information: Gelion Business Trade MCHJ is an Uzbekistan-based company involved in the supply chain of raw materials to Russia.

    GIMLI TRADE LLC-FZ

    • Group ID: 17282
    • Other Information: (UK Sanctions List Ref): RUS3177.
    • Supplemental Information: Gimli Trade LLC-FZ is a Dubai-based entity involved in the trade of goods restricted under sanctions regimes.

    KIFIKO LLC

    • Group ID: 17275
    • Other Information: (UK Sanctions List Ref): RUS3180.
    • Supplemental Information: Kifiko LLC is a Russian company involved in the wholesale of chemical products.

    LLC JV CHEMISTRY INTERNATIONAL

    • Group ID: 17276
    • Other Information: (UK Sanctions List Ref): RUS3172.
    • Supplemental Information: LLC JV Chemistry International is involved in the chemical industry, specifically the supply of nitrocellulose.

    LLC NNK-OIL

    • Group ID: 17264
    • Other Information: (UK Sanctions List Ref): RUS3163.
    • Supplemental Information: LLC NNK-Oil (Nezavisimaya Neftegazovaya Kompaniya) is a Russian oil and gas company led by Eduard Khudainatov, often associated with Rosneft.

    LLC RUSNEFTEGAZ GROUP

    • Group ID: 17262
    • Other Information: (UK Sanctions List Ref): RUS3161.
    • Supplemental Information: LLC Rusneftegaz Group is a Russian energy company involved in oil and gas extraction.

    LLC TEKSTIL-SERVIS

    • Group ID: 17277
    • Other Information: (UK Sanctions List Ref): RUS3173.
    • Supplemental Information: LLC Tekstil-Servis is a Russian company designated for its role in supplying materials like cotton pulp to the defence sector.

    LLC VATA FACTORY 24

    • Group ID: 17278
    • Other Information: (UK Sanctions List Ref): RUS3174.
    • Supplemental Information: LLC Vata Factory 24 is a manufacturer of cotton wool and cellulose products, materials used in explosives manufacturing.

    MERCANTILE & MARITIME GROUP

    • Group ID: 17284
    • Other Information: (UK Sanctions List Ref): RUS3184.
    • Supplemental Information: Mercantile & Maritime Group is a Singapore and London-based oil and gas trading company founded by Murtaza Lakhani, involved in trading Russian crude oil.

    PJSC RUSSNEFT

    • Group ID: 17261
    • Name (non-Latin script): Публичное акционерное общество РуссНефть
    • Address: 69, Pyatnitskaya st., Moscow, Russia, 115054
    • Business Reg No: INN: 7717133960
    • Other Information: (UK Sanctions List Ref): RUS3160. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 18/12/2025.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect that PJSC RUSSNEFT is an involved entity under the Russia (Sanctions) (EU Exit) Regulations 2019 because it is or has been involved in: obtaining a benefit from or supporting the Government of Russia, through carrying on business in a sector of strategic significance, namely, the Russian energy sector.
    • Supplemental Information: PJSC RussNeft is one of the largest crude oil producers in Russia, previously controlled by the Gutseriev family.

    PJSC TATNEFT

    • Group ID: 17263
    • Name (non-Latin script): ПАО Татнефть
    • a.k.a: PJSC TATNEFT named after V.D. Shashin
    • Address: 75, Lenin Street, Almetyevsk, Russia, 423 400
    • Business Reg No: INN: 1644003838
    • Other Information: (UK Sanctions List Ref): RUS3162. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 18/12/2025.
    • UK Statement of Reasons: The Secretary of State has reasonable grounds to suspect that PJSC TATNEFT is an involved entity under the Russia (Sanctions) (EU Exit) Regulations 2019 because it is or has been involved in: obtaining a benefit from or supporting the Government of Russia, through carrying on business in a sector of strategic significance, namely, the Russian energy sector.
    • Supplemental Information: PJSC Tatneft is the fifth-largest oil company in Russia, headquartered in Tatarstan, and operates the TANECO refinery complex and a tire manufacturing business.

    RAW MATERIALS CELLULOSE MCHJ

    • Group ID: 17279
    • Other Information: (UK Sanctions List Ref): RUS3175.
    • Supplemental Information: Raw Materials Cellulose MCHJ is an Uzbekistan-based entity involved in the export of cellulose products to Russia.

    REDWOOD GLOBAL SUPPLY FZ-LLC

    • Group ID: 17283
    • Other Information: (UK Sanctions List Ref): RUS3178.
    • Supplemental Information: Redwood Global Supply FZ-LLC is a UAE-based company involved in supply chains associated with restricted goods.

    SAPHIRA ENERGY FZE

    • Group ID: 17270
    • Other Information: (UK Sanctions List Ref): RUS3167.
    • Supplemental Information: Saphira Energy FZE is a UAE-based energy trading company.

    TEJARINAFT FZCO

    • Group ID: 17268
    • Other Information: (UK Sanctions List Ref): RUS3182.
    • Supplemental Information: Tejarinaft FZCO is a Dubai-based company owned or controlled by Murtaza Lakhani, involved in the trading of petroleum products.
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  • NTE 2025/34: update to general trade licence Russia sanctions – fertilisers

    Published 18 December 2025

    Introduction

    The Export Control Joint Unit (ECJU) has updated the General trade licence Russia sanctions – financial services and funds related to fertilisers to include anhydrous ammonia within its scope.

    Licence information

    The general licence permits the provision of financial services and making funds available to a person connected with Russia for the supply or delivery of specified fertiliser goods from Russia to a third country and making specified fertiliser goods available from Russia to a person in a third country, where they are intended for agricultural use only.

    Read the general trade licence

    A full list of the specified fertiliser goods is available within the general trade licence document.

    Contact ECJU

    General queries about strategic export licensing

    Export Control Joint Unit
    Department for Business and Trade
    Old Admiralty Building
    Admiralty Place
    London
    SW1A 2DY

    Email exportcontrol.help@businessandtrade.gov.uk

    Telephone 020 7215 4594

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  • From the OFAC Notice yesterday:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 55E, “Authorizing Certain Services Related to Sakhalin-2;” and Russia-related General License 115C, “Authorizing Certain Transactions Related to Civil Nuclear Energy.”

    Additionally, OFAC is amending eight Russia-related Frequently Asked Questions: FAQs 967, 978, 999, 1011, 1117, 1182, 1203, and 1216.

    Here are the two updated GLs:

    and:

    Here’s a link to a page with all the updated FAQs (in reverse numerical order, for some reason).

  • I will post the other updates (the Russia-related General License updates and the updated FAQs) separately. But here are the designations from the OFAC Notice:

    Transnational Criminal Organizations Designations; Issuance of Amended Russia-related General Licenses; Publication of Updated Russia-related Frequently Asked Questions

    Treasury Press Release:

    Secretary Bessent Orders Sanctions Against Violent Mexican Cartel

    Additions:

    [TCO]

    Transnational Criminal Organizations Sanctions Regulations

    CARTEL DE SANTA ROSA DE LIMA

    AKAs: SANTA ROSA DE LIMA CARTEL, “CSRL”1

    • Address: Mexico
    • Organization Established Date: 2014
    • Target Type: Criminal Organization

    Supplemental Information: According to the Treasury press release, the Cartel de Santa Rosa de Lima (CSRL) is a Guanajuato-based criminal organization that derives the vast majority of its illicit revenue from industrial-scale fuel and oil theft (known as “huachicol”) from Mexico’s state-owned energy company, Pemex.2 The group engages in a violent conflict with the Cartel Jalisco Nueva Generacion (CJNG) for control of the “Bermuda Triangle” region in Guanajuato, where critical pipelines and a refinery are located.3 CSRL steals fuel by bribing employees, tapping pipelines, and hijacking trucks, selling it on the black market or smuggling crude oil into the U.S. disguised as waste oil.4

    YEPEZ ORTIZ, Jose Antonio

    AKAs: “El Marro”

    • Address: Mexico
    • DOB: 23 Jul 1980
    • POB: Guanajuato, Mexico
    • Nationality: Mexico
    • Gender: Male
    • C.U.R.P.: YEOA800723HGTPRN07 (Mexico)
    • Type: (individual)

    Linked to: CARTEL DE SANTA ROSA DE LIMA

    Supplemental Information: Jose Antonio Yepez Ortiz, also known as “El Marro” (The Sledgehammer), is the leader of the Cartel de Santa Rosa de Lima.5 Although he was arrested in August 2020 and is currently serving a 60-year sentence in Mexico, U.S. officials state he continues to orchestrate the cartel’s operations from prison by sending instructions through lawyers and family members.6

    Press Chart:

  • OFSI General Licences INT/2025/7628424 and INT/2025/7323088 amended. FAQ 175 added.

    On 17 December 2025, OFSI General Licences INT/2025/7628424 and INT/2025/7323088were amended.

    There has been an update to the definition of “IT Providers” and an amendment to the permissions in General Licence INT/2025/7628424.

    The definition of “Legal Services” has been updated in General Licence INT/2025/7323088. See FAQ 175 for details of this amendment.

    Any persons intending to use General Licence INT/2025/7628424 and General Licence INT/2025/7323088 should consult the copy of the Licence for full details of the permissions and usage requirements.

    General Licence INT/2025/7628424:

    General Licence INT/2025/7323088:

    FAQ 175:

    Yes. On 17 December 2025, the Legal Services General Licence INT/2025/7323088 was amended to clarify that legal advice and/or representation in dispute resolution is included in the definition of “Legal Services”.

    This was first clarified in a version of the Legal Services General Licence issued 28 March 2025 (INT/2024/5334756). It was not captured in the subsequent issue of the expired General Licence: INT/2025/6160920 dated 28 April 2025, and although not included in the original version of the current Legal Services General Licence INT/2025/7323088 (due to expire 28 April 2026), this has now been amended.

    Added on: 17 Dec 2025

  • Government of Canada announces new sanctions under the Special Economic Measures (Iran) Regulations

    Further to Global Affair Canada’s news release, December 15, 2025, this message serves as a reminder that businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) must report completed or attempted financial transactions to FINTRAC when there are reasonable grounds to suspect that the transaction is related to a money laundering, terrorist financing or sanctions evasion offence.

    Additionally, businesses subject to the PCMLTFA must update their processes to include these newly listed entities, review any past transactions and consider the need to report to FINTRAC, as required.

    Canada is imposing additional sanctions against 4 Iranian senior officials who have been involved in gross and systematic human rights violations in the Islamic Republic of Iran (Iran) and have had a significant role in facilitating and directing repressive policies.

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  • Email notice from UK Government:

    Today, 17 December, the UK government has delisted the following 1 individual and 2 entities from the Syria sanctions regime, and one individual from the Syria sanctions regime and Iran Nuclear sanctions regime.

    Please note that these delistings remove duplicative designations. All four will remain listed under one of the following regimes: the Iran sanctions regime, the Iran Nuclear sanctions regime, or the Chemical Weapons sanctions regime. Therefore, there is no change in their status as designated persons.

    Delisting:

    Name:Old Unique ID (Delisted):OFSI Group ID:Unique ID:
     Hossein TAEB SYR008911788IRN0039
    Mohammad Ali JAFARI SYR0161 and INU0011 10638IRN0058
    ISLAMIC REVOLUTIONARY GUARDS CORPS – QODS FORCESYR0310  11241INU0082
    SCIENTIFIC STUDIES AND RESEARCH CENTRE (SSRC)SYR0286  12426CHW0006

    However, this update shows a weakness of the OFSI notice format. None of the notices have revocation/delisting/removal sections; because each designated party is represented by one listing that doesn’t explicitly say which programs it’s listed under (like OFAC’s program tags), if a party is designated under two programs, and is removed from one, it appears in the OFSI Notices as an amended listed, not a revoked one.

    For example, the Syria Notice summary says:

    4. The following entries have been removed from the Syria regime, however they remain

    subject to an asset freeze under different regimes:

    Remaining subject to sanctions under the Iran regime:

    • Mohammad Ali JAFARI (Group ID: 10638)

    • Hossein TAEB (Group ID: 11788)

    1Remaining subject to sanctions under the Iran (Nuclear) regime:

    • ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC) QODS FORCE (Group ID: 11241)

    Remaining subject to sanctions under the Chemical Weapons regime:

    • SCIENTIFIC STUDIES AND RESEARCH CENTRE (SSRC) (Group ID: 12426)

    But the Annex lists all four parties under an Amendments section. For example:

    SCIENTIFIC STUDIES AND RESEARCH CENTRE (SSRC)

    a.k.a: (1) Center for Scientific Studies and Research (SSRC) (2) Center for Study and

    Research (CERS) (3) Centre de Recherche de Kaboun (4) Centre d’Etude et de Recherche

    Scientifique (CERS) (5) Scientific Research Council (SRC) (6) Scientific Studies and

    Research Council (7) Syrian Scientific Research Council (SSRC) Address: (1) P.O. Box

    31983, Barzeh. (2) Barzeh Street, PO Box 4470, Damascus, Syria. Other Information: (UK

    Sanctions List Ref): CHW0006 and SYR0286. Listed under the Chemical Weapons and

    Syria sanctions regimes. (UK Statement of Reasons): There are reasonable grounds to

    suspect that they are an involved person under the Syria (Sanctions) (EU Exit) Regulations

    2019 because they are or have been involved in activities carried out on behalf of the

    Assad regime, implementing, or connected to the repressive policies of that regime. In

    particular, carrying on prohibited activities related to chemical weapons in Syria. The

    Scientific Studies and Research Center (SSRC) is the Syrian regime’s principal entity for

    the development of chemical weapons. The SSRC is responsible for the development

    and production of chemical weapons, as well as the missiles and artillery to deliver them,

    operating at a number of sites in Syria. (Phone number): Telephone: 6668114/5 Telefax:

    6620317 (Type of entity): Investment. Private (Subsidiaries): Bena Properties (subsidiary),

    Cham Holding Building, Daraa Highway, Ashrafiyat Sahnaya Rif Dimashq, Syria, P.O. Box

    59525. Higher Institute for Applied Sciences and Technology. HISAT. National Standards

    & Calibration Laboratory. NSCL Listed on: 21/01/2019 UK Sanctions List Date

    Designated: 31/12/2020 Last Updated: 25/04/2025 17/12/2025 Group ID: 12426.

    Iran Notice

    Iran (Nuclear) Notice

    Chemical Weapons Notice

    Syria Notice

  • On 17 December 2025, the General Licence INT/2025/5635700 was amended to add the Zohr project to the list of Exempt Projects. Additionally, the permissions of the General Licence were amended. The General Licence now authorises a Person to continue business operations and exercise shareholder rights in relation to an Exempt Project where the share registrar for that project is a Designated Person, including but not limited to the following activities:

    • A Person may make payments for administration fees in connection with share registrar services,
    • A Person may receive dividend payments that have been processed by, or by 
      reference to, a share registrar who is also a Designated Person. 

    Any persons intending to use General Licence INT/2025/5635700 should consult the copy of the Licence for full details of the permissions and usage requirements.

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