Mr. Sanctions

Category: Syria

  • March 17, 2026: TradeStation Securities, Inc. settles with OFAC for $1,110,661

    This report summarizes the enforcement release regarding TradeStation Securities, Inc., a Florida-headquartered brokerage firm that operates online securities trading platforms.

    What Happened

    Between June 21, 2021, and June 15, 2022, TradeStation provided investment services—specifically allowing 481 securities trades—to customers who were physically located in Iran, Syria, and the Crimea region of Ukraine.

    The problem originated from a failure in the company’s “geo-blocking” systems, which are designed to identify where a customer is located and block them if they are in a sanctioned country. While TradeStation had two layers of this technology, the second layer contained a critical technical blind spot: instead of checking the customer’s location, the system mistakenly checked the location of TradeStation’s own U.S.-based servers. This error meant that customers using the company’s mobile app were not restricted from trading for nearly a year, even though those attempting to use the web platform were successfully blocked.

    The issue persisted because TradeStation’s compliance team failed to properly test and validate that these tools were working as intended. Specifically, in November 2021, the company stopped using an automated tool that was meant to test its servers for exactly these types of vulnerabilities.

    The Penalty

    TradeStation agreed to pay $1,110,661 to settle its potential civil liability for the 481 apparent violations.

    • Violation Type and Status: All 481 violations were determined by OFAC to be non-egregious and were voluntarily self-disclosed by TradeStation.
    • Base Penalty Breakdown: The total value of the illegal trades was $4,442,645. Under OFAC’s guidelines for self-disclosed, non-egregious cases, the base penalty is calculated as one-half of the transaction value.
      • Base Penalty Total: $2,221,322.
    • Final Settlement: The final penalty of $1,110,661 reflects a 50% reduction from the base penalty due to the company’s cooperation and remedial efforts.

    Aggravating Factors

    • Failure to Exercise Minimal Caution
      • General Factor involved: Degree of Care.
      • Applicability: TradeStation allowed significant compliance weaknesses to remain unaddressed for a full year. Crucially, the company had received a “Cautionary Letter” from OFAC earlier in 2021 regarding similar geo-blocking failures, meaning they were already aware of the risks but failed to ensure their systems were properly tested.
    • Discontinuing Necessary Testing Tools
      • General Factor involved: Management of Compliance Program.
      • Applicability: In November 2021, TradeStation intentionally stopped using an automated testing tool for its on-premises servers, which directly contributed to the failure to detect the system error that allowed sanctioned users to trade.

    Mitigating Factors

    • Prompt and Comprehensive Correction
      • General Factor involved: Remedial Response.
      • Applicability: After discovering the error, TradeStation quickly implemented new technical controls and solutions to ensure that future failures in its geo-blocking or alert systems would be identified immediately.
    • Limited Scope and Low Financial Benefit
      • General Factor involved: Nature and Complexity of Operations / Economic Benefit.
      • Applicability: The illegal trades represented a very small percentage of TradeStation’s total transaction volume during that year, and the company earned less than $2,000 in total revenue from these specific trades.
    • Substantial Cooperation
      • General Factor involved: Cooperation with OFAC.
      • Applicability: The company filed a detailed self-disclosure report, was highly cooperative throughout the investigation, and agreed to “toll” the statute of limitations (giving OFAC more time to complete the case).
    • Clean Five-Year History
      • General Factor involved: Prior Record.
      • Applicability: TradeStation had not received a formal Penalty Notice or Finding of Violation from OFAC in the five years leading up to these events.

    To find more details on this case, please see the full Enforcement Release provided by OFAC.

    What are the Takeaways?

    • Test and Audit Regularly: This case shows that even if you have “two tiers” of defense, they only work if they are correctly implemented. Companies must regularly test their compliance tools to ensure they are actually blocking what they are supposed to block.
    • Don’t Ignore Warning Signs: If a regulator sends a cautionary letter or points out a flaw, treat it as a high-priority alert. TradeStation’s failure to act on a previous warning was a major factor in the size of the penalty.
    • Verify After Every Update: Technical changes—such as migrating to new servers or updating software—can accidentally break your compliance filters. Testing should be a standard part of any system maintenance.
    • Use Diverse Indicators: Effective geo-blocking should look at more than just a single IP address; it should include tools like VPN detection and location-based alerts to prevent users from bypassing restrictions.

    and the full enforcement release:

    20260317_tradestationDownload

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  • February 25, 2026: OFAC Enforcement costs an individual $3,777,000 for 20 Syrian sanctions violations

    Gemini’s quick summary:

    Based on the enforcement release from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) dated February 25, 2026, here is the reformatted and simplified summary of the action.

    What Happened

    A U.S. citizen (referred to as “U.S. Person-1”) worked as a high-level executive and board member for four real estate companies based in Syria. Even though the U.S. had strict sanctions against doing business in Syria at the time, this individual continued to manage these companies between 2018 and 2021. Their work included tasks like:

    • Reviewing and signing off on financial records.
    • Approving money spent on business operations and employee pay.
    • Overseeing the collection of service fees.

    Because these activities provided “managerial services” to Syrian businesses, they broke U.S. law. This case is a reminder that U.S. citizens must follow these rules no matter where in the world they live.

    The Penalty

    U.S. Person-1 agreed to pay $3,777,000 to settle the case. OFAC determined that the violations were “egregious,” meaning they were particularly serious, and noted that the individual did not come forward to report the mistakes voluntarily.

    Analysis of Factors

    OFAC used its official Enforcement Guidelines to decide on this penalty by looking at several “General Factors”:

    • Willfulness and Awareness (Aggravating Factor): * Applicable General Factor:General Factor A (Willfulness or Recklessness) and General Factor B (Awareness of Conduct).
      • Explanation: The individual was a sophisticated executive who held senior roles in multiple international companies. Given their position, they either knew or should have known that managing Syrian companies was illegal under U.S. sanctions.
    • Harm to Sanctions Program (Aggravating Factor):
      • Applicable General Factor: General Factor C (Harm to Sanctions Program Objectives).
      • Explanation: By providing high-level management to Syrian entities, the individual directly undermined U.S. foreign policy goals intended to pressure the Syrian regime.
    • Lack of Disclosure (Aggravating Factor):
      • Applicable General Factor: General Factor J (Voluntary Self-Disclosure).
      • Explanation: The individual did not report these activities to the government; instead, the government discovered them through an investigation supported by the FBI.
    • Cooperation (Mitigating Factor):
      • Applicable General Factor: General Factor I (Cooperation with OFAC).
      • Explanation: While the individual broke the law, they eventually cooperated with the investigation, which helped prevent an even higher fine.

    What are the Takeaways?

    This case provides several important lessons for staying compliant with U.S. laws:

    • Sanctions Apply to People, Not Just Places: If you are a U.S. citizen or permanent resident (Green Card holder), you must follow U.S. sanctions even if you live and work entirely outside of the United States.
    • Management is a “Service”: You don’t have to send money to a sanctioned country to break the law. Providing “managerial services”—like approving budgets or signing documents—is also a violation.
    • Individual Responsibility: OFAC will hold individuals personally accountable for sanctions violations, especially when they hold senior leadership roles.
    • The Importance of Vetting Roles: Before accepting a board seat or an executive position in a foreign company, U.S. persons should conduct a thorough “risk assessment” to ensure the company does not operate in sanctioned regions or with sanctioned people.

    Other Resources

    For more information on how to follow these rules or to see other recent cases, you can visit:

    • OFAC’s Recent Actions Page: A list of the latest updates to sanctions lists and enforcement news.
    • Civil Penalties Chart: A detailed summary of fines and settlements paid by companies and individuals for the current year.

    Actually, Gemini did leave out two minor points in the scheme of things: the individual signed a tolling agreement, and the usual “no enforcement actions in the last 5 years” factor. Minor enough that I didn’t feel the need to have it re-do the response.

    The Enforcement Release:

    20260225_individualDownload

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  • January 27, 2026: What’s an administrative update? OFSI shows us??

    UK Gov logo, 50% resolution.png

    Today, Tuesday 27 January, the following administrative amendments have been made to the OFSI Consolidated List. This is to ensure the Consolidated List and UK Sanctions List match before the Consolidated List is retired tomorrow. More information on the move to a single UK Government sanctions list can be found here. All amended individuals and entities remain designated.

    Individuals amended:

    Name:OFSI Group ID:Unique ID:
    HOUMAM Jazai’iri13148SYR0090
    KIM Su Gwang 13664DPR0056

    Entities amended:

    Name:OFSI Group ID:Unique ID:
    LLC RUSNEFTGAZ GROUP17262RUS3161
    BANK SADERAT IRAN11185INU0302

    and here are the 4 Notices:

    Notice_Democratic_People_s_Republic_of_Korea_270126Download
    Notice_Iran__Nuclear__270126Download
    Notice_Russia_270126Download
    Notice_Syria_270126Download

    The UK Sanctions List from FCDO lists which people, entities and ships are designated or specified under the Sanctions and Anti-Money Laundering Act 2018, and why.

    The OFSI Consolidated List from HMT provides information relating to asset freeze and investment ban targets across all financial sanctions regimes implemented in the UK. This list will close at 09:00GMT on Wednesday 28 January 2026. Guidance has been published to help you prepare for the change. 

    Find out more about UK Sanctions and how to contact us here: UK sanctions – GOV.UK

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  • December 23, 2025: Amended Syria Tri-Seal Advisory & PAARSS designation updates

    First, from today’s OFAC Notice:

    Today, the U.S. Department of State, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control, have issued an amended Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria, to reflect the repeal of the Caesar Syria Civilian Protection Act of 2019 (Caesar Act). 

    Additionally, there are PAARSS designations which have been updated:

    Amendments:

    PAARSS-related Designations

    [PAARSSR-EO13894] Promoting Accountability for Assad and Regional Stabilization Act of 2019; Executive Order 13894

    The [SYRIA-CAESAR] Program Tag has been removed from the following PAARSS-related designations:

    AL-ADHAM EXCHANGE COMPANY AKAs: AL-ADHAM FOREIGN EXCHANGE Address: May 29th Street, Saroujah, Damascus, Syria; Hisham Al-Atassi Street, Al-Salam Building, Ground Floor, Homs, Syria; Al-Assi Square, Al-Quwwatli Street, Hama, Syria; Al-Quds Street, Tartous, Syria Website: https://aladham-exchange.com.syOrganization Established Date: 16 Feb 2009 Commercial Registry Number: 15691 (Syria)

    AL-ASSAD, Samer Kamal AKAs: AL-ASAD, Samer Address: Syria DOB: 19 May 1973 POB: Qardaha, Syrianationality: Syria Gender: Male Passport: 86368 (Syria) National ID No.: 06200000449 (Syria) Type: Individual

    AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY AKAs: AL-FADEL EXCHANGE AND INTERNATIONAL TRANSFER COMPANY, AL-FADEL EXCHANGE PRIVATE JOINT STOCK COMPANY, AL-FADEL MONEY TRANSFER AND EXCHANGE PRIVATE JSC Address: Al-Fardous Street, Damascus, Syria; March 8th Street, Al-Sarraj Building, Ground Floor, Lattakia, Syria; Al-Express Street, Al-Farqan Quarter, Aleppo, Syria; Al-Mazza Highway, Damascus, Syria; Sayyida Zeynab, Damascus, Syria; Main Street, Jeremana, Damascus, Syria Website:https://alfadelex.com

    ARFADA PETROLEUM PRIVATE JOINT STOCK COMPANY AKAs: ARFADA PETROLEUM COMPANY JSC, ARVADA PETROLEUM COMPANY JSC Address: Mashroua Dummar, Lot No. 13, Building 12/2, Damascus, SyriaWebsite: https://www.arfada.com/ Organization Established Date: 24 Apr 2018 Organization Type: Support activities for petroleum and natural gas extraction Registration Number: 18394 (Syria)

    BALWI, Fadel Ma’ruf AKAs: AL-BALAWI, Fadel Address: Syria DOB: 01 Jan 1983 POB: Nubl, Syria nationality:Syria Gender: Male Passport: 2251748 (Syria) Type: Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    BALWI, Muhammad Ma’ruf AKAs: AL-BALAWI, Muhammad, AL-BALWI, Muhammad Ma’ruf Address: Sayyida Zeynab, Damascus, Syria DOB: 01 Jan 1981 POB: Nubl, Syria nationality: Syria Gender: Male Passport: 1982538 (Syria) Type: Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    BALWI, Mut’i Ma’ruf AKAs: AL-BALAWI, Mut’i, BALAWI, Mut’i, BALWI, Maarouf, BALWI, Moutee MaaroufAddress: Syria DOB: 01 Jan 1985 POB: Nubl, Syria nationality: Syria Gender: Male Passport: 2488186 (Syria) Type:Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    HAMIEH, Khaldoun Address: Syria DOB: 25 Dec 1973 nationality: Lebanon Gender: Male Passport: LR1939852 (Lebanon) Type: Individual

    JAMALEDDINE, Nazir Ahmad Mohammed AKAs: JAMAL EDDIN, Mohammed Nazer, JAMAL EDDINE, Natheer Ahmed Mohammed, JAMAL EDDINE, Nathier Ahmed Mohammed Address: Damascus, Syria DOB: 02 Jan 1962POB: Damascus, Syria nationality: Syria Gender: Male Passport: N011612445 (Syria) alt. Passport: 002-17-L022286 (Syria) National ID No.: 010-30208342 (Syria) Type: Individual

    LIMITED LIABILITY COMPANY STG LOGISTIC AKAs: OOO STG LOGISTIK, STG STROYTRANSGAZ LOGISTIC, “STG LOGISTIC” Address: 12 Universitetsky Ave, Moscow 119330, Russia; Damascus, SyriaOrganization Established Date: 04 Sep 2009 Tax ID No.: 5027148148 (Russia) Registration Number:1095027004236 (Russia)

    MAYA EXCHANGE COMPANY AKAs: MAYA FOR EXCHANGE AND INTERNATIONAL HAWALAS Address:Ground Floor, Property Number 17/9/2230, Baqi Zadeh Building, Fardus Street, Salhiyah, Damascus, Syria; First Real Estate Zone, Property Number 936, Section 2, Ground Floor, Haju Building, Abd al-Hamid al-Durubi Street, Homs, Syria; Tartus Real Estate Zone, Section 8, Property Number 3881, Revolution Street, Al-Baraniyah, Tartus, Syria; Ground Floor, Second Real Estate Zone, Sections 7-9, Property 2533, Aziziyah Falls, Baghdad Station, Aleppo, SyriaOrganization Type: Other monetary intermediation

    QADDOUR, Khalid AKAs: QADDOUR, Khaled Nasser Address: Yaafour, Damascus, Syria DOB: 23 Apr 1970 POB:Damascus, Syria nationality: Syria Gender: Male National ID No.: 01020097227 (Syria) Type: Individual Linked to:AL-ASSAD, Maher

    RAMAK DEVELOPMENT AND HUMANITARIAN PROJECTS LLC AKAs: RAMAK COMPANY FOR DEVELOPMENT AND HUMANITARIAN PROJECTS LLC Address: Rural Damascus, Syria Organization Established Date: 08 Aug 2011 Organization Type: Real estate activities with own or leased property alt. Organization Type: Construction of buildings

    SALLIZAR SHIPPING SAL Address: 1st Floor, Shuwairi Bldg., Boulevard Saib Salam, al-Masraa, Beirut Corniche, Lebanon Organization Established Date: 12 Apr 2018 Registration Number: 1024992 (Lebanon)

    TAMAYOZ LLC AKAs: EXCELLENCE LIMITED LIABILITY COMPANY Address: Damascus, Syria Organization Type: Real estate activities with own or leased property

    WINGS PRIVATE JSC AKAs: AL-AJNAHA PRIVATE JOINT STOCK COMPANY, WINGS COMPANY, WINGS PRIVATE JOINT STOCK COMPANY Address: Rural Damascus, Syria Organization Type: Real estate activities with own or leased property

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  • December 19, 2025: OFSI updates 1 in Russia program, adds 9 to the Syria one

    Here are the reformatted Syria designations:

    Based on the OFSI Notice Syria 19/12/2025, the following entries have been added to the Consolidated List.

    Additions

    Individuals

    • Mohammed Hussein AL-JASIM
      • Group ID: 17250
      • Title: Brigadier General
      • DOB: (1) –/–/1985, (2) –/–/1987, (3) –/–/1986, (4) –/–/1988
      • POB: Jousa, Hama Governorate, Syria
      • a.k.a: AMSHA, Abu (non-Latin script: أبو عمشة)
      • Nationality: (1) Syria, (2) Turkey
      • Other Information: (UK Sanctions List Ref): SYR0420.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Mohammed al-Jasim is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: AL-JASIM is or has been involved in repressing the civilian population of Syria.
      • Supplemental Information: Al-Jasim, widely known as “Abu Amsha,” is the commander of the Sultan Suleiman Shah Division (also known as Al-Amshat), a faction of the Syrian National Army (SNA) operating in Turkish-controlled areas like Afrin; his group is notorious for severe human rights abuses, including extortion, kidnapping, sexual violence against Kurdish women, and looting, and has been involved in recruiting Syrian mercenaries for conflicts in Libya and Azerbaijan.
    • Sayf Al-Din BOULAD
      • Group ID: 17251
      • DOB: (1) –/–/1988, (2) –/–/1987
      • POB: Bza’ah, al-Bab District, Syria
      • a.k.a: BAKR, Abu (non-Latin script: أبو بكر)
      • Nationality: (1) Turkey, (2) Syria
      • Other Information: (UK Sanctions List Ref): SYR0421.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Sayf BOULAD is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: BOULAD is or has been involved in repressing the civilian population of Syria.
      • Supplemental Information: Boulad (also known as Sayf Abu Bakr) is the commander of the Hamza Division, a Syrian National Army faction implicated in arbitrary arrests, torture, and other abuses in Afrin and Ras al-Ain, and has facilitated the deployment of fighters to foreign conflicts.
    • Ghaith Suleiman DALLA
      • Group ID: 17249
      • DOB: 31/07/1971
      • POB: Beit Yashout, Latakia, Syria
      • a.k.a: (1) DALLA, Ghaith, Suleiman (non-Latin script: غيث دلة), (2) DALLA, Ghayath, Suleiman, (3) DALLA, Ghayth, Suleiman, (4) DALLA, Ghiath, Suleiman, (5) DALLA, Gyath, Suleiman
      • Nationality: Syria
      • Other Information: (UK Sanctions List Ref): SYR0419.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Ghaith DALLA is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: DALLA is or has been involved in repressing the civilian population of Syria.
      • Supplemental Information: A Brigadier General in the Syrian Army’s elite 4th Armoured Division (commanded by Maher al-Assad), Dalla is known as the “Lion of the 4th Division” (Ghayth al-Ghayth) and has commanded brutal military campaigns in the Damascus suburbs (Ghouta) and Idlib/Latakia fronts.
    • Miqdad Loay FATIHA
      • Group ID: 17248
      • POB: Jableh, Syria
      • a.k.a: JAAFAR, Abu
      • Nationality: Syria
      • Other Information: (UK Sanctions List Ref): SYR0418.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Miqdad Fatiha is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: FATIHA is or has been involved in repressing the civilian population of Syria.
      • Supplemental Information: A high-ranking military official often associated with the Syrian regime’s security apparatus and the 4th Division, linked by the EU to crimes against humanity and fueling sectarian violence.
    • Mudallal KHOURY
      • Group ID: 17255
      • DOB: 18/06/1957
      • POB: Homs, Syria
      • a.k.a: (1) KHOURI, Mudallal, (2) KHOURY, Madalal, (3) KHOURY, Mtanyus, (4) KHOURY, Mudalal, (5) KHURI, Mudallal (non-Latin script: مدلل خوري)
      • Nationality: (1) Russia, (2) Syria
      • Address: Moscow, Russia
      • Other Information: (UK Sanctions List Ref): SYR0425.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Mudallal KHOURY is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: KHOURY is or has been involved in activities supporting or benefitting from the regime.
      • Supplemental Information: A prominent financier and banker based in Moscow, he serves as an intermediary for the Syrian regime’s financial transactions and has been sanctioned by the US for facilitating the procurement of materials for Syria’s chemical weapons and ballistic missile programs.
    • Imad Mtanyus KHOURY
      • Group ID: 17256
      • DOB: 03/10/1964
      • a.k.a: (1) KHOURI, Imad, (2) KHOURY, Emad, (3) KHURI, Imad, (4) KHURI, Imad, Mtanyus, (5) KHURI, Mtanyus, (6) KHURY, Imad, (7) KHURY, Mtanyus (non-Latin script: عماد خوري)
      • Nationality: (1) Russia, (2) Syria
      • Other Information: (UK Sanctions List Ref): SYR0426.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that Imad KHOURY is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: KHOURY is or has been involved in activities supporting or benefitting from the regime.
      • Supplemental Information: Brother of Mudallal Khoury and a businessman involved in the family’s financial networks; he has been designated by the EU and US for materially supporting the Syrian regime and its military activities.

    Entities

    • HAMZA DIVISION
      • Group ID: 17254
      • a.k.a: (1) al-Hamza Division, (2) Hamzat Division (non-Latin script: فرقة الحمزة)
      • Other Information: (UK Sanctions List Ref): SYR0424.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that the Hamza Division is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: the Hamza Division is or has been involved in repressing the civilian population.
      • Supplemental Information: An armed opposition faction within the Turkish-backed Syrian National Army (SNA), the Hamza Division has been widely accused by international rights groups of war crimes, including torture, looting, and sexual violence in Kurdish-majority areas like Afrin.
    • SULTAN MURAD DIVISION
      • Group ID: 17252
      • a.k.a: (non-Latin script: فرقة السلطان مراد)
      • Other Information: (UK Sanctions List Ref): SYR0422.
      • Statement of Reasons: The Secretary of State considers that there are reasonable grounds to suspect that the Sultan Murad Division is an involved person under the Syria (Sanctions) (EU Exit) Regulations 2019 on the basis of the following ground: the Sultan Murad Division is or has been involved in repressing the civilian population.
      • Supplemental Information: A Turkmen-dominated faction of the Syrian National Army (SNA) operating in northern Syria; it has been implicated in the recruitment of child soldiers, the transfer of mercenaries to conflicts in Libya and Nagorno-Karabakh, and human rights abuses against civilians.
    • SULTAN SULEIMAN SHAH DIVISION
      • Group ID: 17253
      • Supplemental Information: Also known as Al-Amshat and led by Mohammed Hussein Al-Jasim (Abu Amsha), this SNA faction controls the Sheikh Hadid district in Afrin and is accused of running a “fiefdom” characterized by extortion, confiscation of property, and severe mistreatment of the local Kurdish population.

    and the changed Russia one:

    Based on the OFSI Notice provided (Russia, 19/12/2025), there are no additions listed in the Notice summary, only amendments.

    Amendments

    Entities

    LIMITED LIABILITY COMPANY RESPONSIBILITY OF “RBRU SPECIALIZED DEPOSITORY”

    • Group ID: 16924
    • a.k.a: LLC “RBRU SD”
    • Other Information: (UK Sanctions List Ref): RUS2682.
    • Financial sanctions imposed in addition to an asset freeze:Added: Correspondent banking relationships etc. The prohibition on correspondent banking relationships etc. measure was imposed on 19/12/2025.Trust services. Date trust services sanctions imposed: 20/05/2025.
    • (UK Statement of Reasons): Limited Liability Company responsibility of “RBRU Specialized depository” is an “involved person” 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 by carrying on business in sectors of strategic significance to the Government of Russia, namely the Russian financial services sector.
    • (Business Reg No): 9704154155
    • Listed on: 20/05/2025 UK Sanctions List
    • Date Designated: 20/05/2025
    • Last Updated:Removed: 20/05/2025Added: 19/12/2025

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  • December 17, 2025: OFSI modifies 4 sanctions programs

    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

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  • FCDO’s Syria guidance for businesses and NGOs, simplified

    Go read the guidance document for all the links and detail if you want to know more…

    Background

    Interest from UK businesses in operating within Syria has grown recently, prompting the UK government to clarify the legal and policy landscape. The government supports UK businesses investing and trading in Syria, provided they follow UK laws and the activity is actually destined for Syria. However, businesses must assess their own risks, particularly regarding bad actors who might try to exploit the situation or use deceptive tactics to bypass rules.

    The political situation in Syria has shifted significantly. Following the fall of the Assad regime in December 2024, the UK government removed many sanctions in April 2025 to aid recovery. Further steps toward normalization occurred in late 2025: the UK removed Hay’at Tahrir Al-Sham (HTS) from its list of banned terrorist organizations in October, and in November, the UK removed the Syrian President and Interior Minister from the specific ISIL/Al-Qaida sanctions list. While Syria remains a high-risk environment, the new government is working toward stability, and there are potential commercial opportunities in this lower middle-income market.

    What has (and hasn’t) changed

    Significant changes to the UK’s Syria sanctions rules took effect on April 24, 2025. To help the Syrian people rebuild, the UK lifted bans on trade, finance, aviation, and energy production. Financial freezes were also removed from entities previously controlled by the Assad regime, such as the Central Bank of Syria, government ministries, and energy or media companies. The current Government of Syria itself is not subject to sanctions.

    Despite these relaxations, strict prohibitions remain in place to hold specific individuals accountable. You still cannot do business with people or entities subject to asset freezes. There are also continued bans on exporting chemical and biological weapons technology, goods used for internal repression or spying, and military equipment. Specific trade restrictions apply to the “Governing Authority of Syria”—which includes the transitional authorities and the Central Bank—regarding gold, precious metals, and diamonds. Luxury goods also cannot be sent to Syria. If you are a specific type of regulated firm, you have a legal duty to report suspected sanctions breaches.

    UN counter-terrorism sanctions

    Separate from the UK’s own rules, the United Nations maintains a counter-terrorism sanctions list (the ISIL/Al-Qaida regime) that still affects business in Syria. While the UK has removed the Syrian President and Interior Minister from its version of this list, other individuals and groups remain designated. Notably, while the UK has de-listed HTS domestically, HTS remains on the UN sanctions list.

    The Government of Syria is not on this UN list, meaning interactions with the government generally do not violate these sanctions. However, strict asset freezes and bans on military goods apply to anyone who is on the UN list. This prohibits providing funds or economic resources to them directly or indirectly. Limited exceptions exist, primarily to allow for the payment of basic expenses, but these usually require a licence.

    Relevant UK counter-terrorism laws

    Under UK law, the Terrorism Act 2000 defines which organizations are “proscribed” (banned). As of October 2025, HTS is no longer a proscribed organization, meaning membership or support for it is no longer a criminal offense in the UK. However, the group Da’esh (ISIL/ISIS) remains banned and poses a threat.

    The government aims to ensure that counter-terrorism laws do not stop legitimate humanitarian work. The Crown Prosecution Service (CPS) has guidance stating that prosecuting genuine aid organizations is generally not in the public interest. Additionally, the law offers specific protections: there is a legal defense for “genuinely benign” meetings with banned groups (such as for delivering aid), and organizations can apply to the National Crime Agency for a defense against potential terrorist financing charges for specific transactions.

    Humanitarian exceptions and exemptions

    Petroleum exceptions

    The regulations include a specific rule allowing the use of funds to purchase or supply petroleum products for humanitarian purposes. Since the general ban on petroleum trade was lifted in April 2025, this rule now primarily protects aid organizations if they need to deal with frozen assets to get fuel. If an organization relied on this rule for activities before April 2025, they must notify the government by the end of the year. For activities after April 2025, notification is only needed if the activity would otherwise breach an asset freeze.

    General licence

    In February 2025, a “General Licence” was issued to facilitate aid. This allows eligible aid organizations (and the banks that serve them) to carry out activities necessary for humanitarian assistance and basic human needs without violating asset freezes. This licence applies to the UK’s independent sanctions but not to the UN sanctions, which have their own separate humanitarian exemption.

    Related guidance documents

    Businesses and organizations should consult the specific statutory guidance for both the Syria and ISIL/Al-Qaida sanctions regimes to understand the full technical details of prohibitions and licences. A “sanctions hub” on the government website creates a central place to search for all relevant policies.

    In addition to sanctions and terrorism laws, other legal frameworks still apply. You must comply with export controls for military and dual-use goods, anti-money laundering regulations, and laws against bribery and corruption. If you are unsure whether your planned activities might break the law—especially given the complexity of the different legal regimes—you should seek independent legal advice.

    So, what do you think of this summary? Is it “enough” for you, or are you better served by the guidance document, for a first read?

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  • Backgrounder: UK removes Syria sanctions in April 2025

    The following is a summarized version of the original press release from the Foreign, Commonwealth & Development Office (FCDO):

    The UK government changed Syria sanctions to help the country rebuild following the fall of the Assad regime.

    Here is a simple breakdown of what happened and why:

    What changed?

    • Easing Restrictions: The UK removed bans on key industries like bankingand energy production. This was done to encourage investment and help get Syria’s infrastructure working again.
    • Lifting Sanctions: Specific sanctions have been dropped against 12 major entities, including the Syrian Ministry of Defence, the Ministry of Interior, and various media companies. This followed the earlier unfreezing of assets for the Central Bank of Syria and the national airline.

    Why did they do this?

    • To Help Rebuild: The main goal is to let money flow back into the country so the Syrian people can repair their economy and infrastructure after years of conflict.
    • To Support Stability: The UK believes a stable Syria is safer for the region and for the UK itself.

    What is staying the same?

    • Punishing the Old Regime: Sanctions remain in place against individuals from the former Assad regime and those involved in the illegal drug trade (specifically the synthetic stimulant captagon).
    • Accountability: The new rules still allow the UK to punish human rights violations committed by Assad and his associates.

    Additional Support

    • The UK pledged £160 million in 2025 to help with Syria’s recovery and humanitarian needs.

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