With the inauguration of Donald Trump as President of the US, global news coverage in January focused on how the new US administration will use sanctions. In his first days in office Trump signed several executive orders both rescinding orders made in the previous administration and introducing new regimes. The most highly-reported was the threat of the imposition of sanctions on Colombia. Whilst Trump’s threat of a trade war with Colombia appears to have been abated, the snap announcement from Trump could indicate the more emotional use of global political tools by the Trump administration over the next four years in comparison with the Biden administration’s more rational outlook.
The beginning of 2025 saw the US, UK, and EU focusing on the continuation of designations in Russia and Venezuela. Other designations included individuals in Sudan, Hungary and the Balkans, as well as those targeting transnational terrorist organisations and cyber criminals.
January was quieter than December in terms of sanctions enforcement, with the US issuing only two penalties totalling $2.1 million across the month. The General Court of the EU and the UK Courts rejected six de-listing applications and challenges to sanctions targeting Russia.
Trump Administration’s First Moves
- One of Trump’s first moves as President was to issue an Executive Order rescinding several of President Biden’s sanctions policies and latest decisions in government. This includes relisting Cuba on the US State Sponsor of Terrorism list and restoring restrictions on financial transactions with certain military and government-linked Cuban entities. Trump also revoked the Executive Order which imposed visa restrictions and asset freezes on individuals in the West Bank. All property and interests in property blocked under the programme have been unblocked. In response Lord Collins of Highbury, the Parliamentary Under-Secretary for the UK Foreign Office, said the UK’s sanctions programme in the West Bank would be maintained and said the UK was concerned at the increased level of violence and fragile ceasefire in Israel and Palestine.
- Trump also restored the provisions in an Executive Order from his previous administration that had been repealed by Biden. The order provided for visa restrictions and blocking of property of certain persons who engaged in International Criminal Court (“ICC”) efforts to investigate, arrest, detain, or prosecute US citizens or allies. At the end of January The US House of Representatives also passed a bill for the Illegitimate Court Counteraction Act, although the US Senate subsequently voted against it. The Act would have authorised the imposition of sanctions on ICC prosecutors and called for the condemnation of arrest warrants against Israeli Prime Minister Benjamin Netanyahu and other Israeli officials. The ICC decision was particularly controversial in political circles. Prior to his inauguration the Washington Working Group for the ICC wrote an open letter to the US Congress and incoming President Trump opposing the use of sanctions against the ICC. The letter warned that possible sanctions could undermine US interests, damage the credibility of other US sanctions, impact access to justice in ICC investigations, and impact US citizens who represent victims and survivors of crimes investigated by the ICC.
- In terms of new decisions Trump published an Executive Order naming international drug cartels and other organisations as terrorists. He also redesignated the Houthis in Yemen as a Foreign Terrorist Organisation. The Houthis’ designation had been revoked by Biden in February 2021. Trump’s comments over Russian sanctions have caused a stir in international media as he claimed that if Russia does not reach a deal with regard to the war in Ukraine then he will impose tariffs and sanctions on anything being sold by Russia to the US. Reuters suggested separately that the US is planning to impose sanctions on tankers carrying Russian oil sold above the $60 per barrel oil price cap. Trump has also ordered a review of US export controls to eliminate loopholes.
- After the Colombian government refused to accept two US military deportation flights, President Trump announced the proposal of new measures against Colombia including 25% tariffs on all goods coming into the US from Colombia, as well as a travel ban and the revocation of visas from Colombian Government officials. A day after Trump’s threat, Colombian President Gustavo Petro agreed to allow US military flights carrying Colombians deported from the US. International media has reported on the averted trade war as a warning from Trump to leaders around the globe.
Designations
- Targeting Russia this month, the UK and the US both designated Russian oil producers PJSC Surgutneftegas and Gazprom Neft. OFAC also listed two Russia-based maritime insurance providers and 183 vessels – mostly oil tankers belonging to Russia’s shadow fleet. The UK and US also published General Licences to accompany the designations allowing wind-down transactions and payments related to Sakhalin-2 LNG development project in Russia. Later in the month, OFAC and the Department of State sanctioned over 250 people and entities linked to Russian defence, and redesignated almost 100 Russian entities from Russia’s financial, energy, and defence sectors. The UK also sanctioned six individuals and three entities in Belarus’s defence sector in response to rigged presidential elections in Belarus and human rights violations in Belarus and Russia.
- Venezuela was a focus of the UK, US and EU in January. The UK has announced designations of 15 people associated with the Venezuelan regime including the President of the Supreme Tribunal of Justice and the Director of Criminal Investigations. OFAC announced sanctions on eight Venezuelan officials, all of whom lead key companies and agencies in Venezuela including Hector Andres Obregon Perez, the President of Venezuela’s state-owned oil company Petroleos de Venezuela SA. The EU sanctioned 15 Venezuelan nationals, including members of the National Electoral Council of Venezuela, the judiciary, and the security forces.
- Elsewhere, OFAC sanctioned the Hungarian Minister-in-charge of Prime Minister Orban’s cabinet office, as well as five individuals and one entity in the Balkans who are alleged to have facilitated Republika Sprska’s President Milorad Dodik and his family. The US also designated eight individuals alleged to have organised the commemoration of Republika Srpska Day, in contravention of the Dayton Peace Agreement. In Sudan, OFAC designated two Sudanese individuals and seven entities for supporting and organising Sudan’s Rapid Support Forces, as well as the leader of the Sudanese Armed Forces. OFAC also targeted two individuals and four entities for using remote IT workers to generate revenue for the DPRK Government. The US Department of Homeland Security also added 37 entities to the Uyghur Forced Labor Prevention Act Entity List in China.
- Under their respective counter-terrorism regimes the UK Government designated right-wing group Blood and Honour for promoting and funding terrorism, and the US sanctioned terrorist organisation the Terrorgram Collective and three associated people. OFAC also designated the Yemen Kuwait Bank for Trade and Investment YSC for links to the Houthis. Meanwhile, two China-linked companies were targeted by the US for supporting malicious cyber groups and the EU sanctioned three officers of the General Staff of the Armed Forces of the Russian Federation Unit 29155 under its cyber sanctions regime for orchestrating cyber-attacks against Estonian government ministries.
Enforcement
- OFAC issued two penalties totalling $2.1 million in January. The first was a penalty of $1.1 million to Miami-based real estate company Family International Realty LLC and its owner Roman Sinyavsky, for 73 apparent violations of Russia sanctions between 2018 to 2023. In the second, technology company Haas Automation Inc agreed a $1 million settlement with OFAC for 21 apparent violations of US sanctions related to Russia’s defence and energy sectors, including shipping machine parts to Russian and Chinese defence companies between 2019 and 2022.
- The US Department of Justice also announced the indictment of five individuals for a scheme to generate funds for DPRK through remote IT work with US companies between April 2018 and August 2024. The defendants then laundered the revenue through a Chinese bank account.
- In the UK, the High Court of England and Wales granted Google LLC and Google Ireland Limited’s applications for anti-enforcement and anti-suit injunctions against several Russian entities, which had been designated by the UK, EU, and US. At the end of the month the High Court allowed payments to Russian bank National Bank Trust, after finding it was not ultimately controlled by Vladimir Putin or Elvira Nabiullina, the governor of the Russian Central Bank. The UK Supreme Court and the UK Court of Appeal also rejected two challenges made by individuals designated on the UK’s Russia sanctions list. Separately OFSI reported that it currently has 318 investigations open into potential breaches of the UK’s Russia sanctions.
- The General Court of the EU rejected the de-listing applications of three individuals listed under the EU’s sanctions against Russia. The court also rejected the de-listing application of Russian telecoms company Megafon, which was included in a list of 96 entities alleged to support Russia’s military and industrial complex. At the end of January the EU General Court dismissed the designation challenge of the daughter of the former Tunisian President, who was listed under the EU’s Tunisian sanctions programme for involvement in the misappropriation of Tunisian public funds. The court found that the individual’s association with her father and connection to legal proceedings over misappropriated assets justified the designation.
Other Updates to Sanctions Programmes
- The UK announced a new sanctions regime targeting irregular migration and organised immigration crime. The programme is intended to halt profiteering from human trafficking. UK legislation also came into force allowing the country to send revenue from sanctioned Russian assets to assist Ukraine. This came into effect the same month the European Commission sent the first €3 billion of assistance to Ukraine. The loan from the EU will total €18.1 billion and will be repaid by Ukraine with profits on frozen Russian Central Bank assets held in the EU.
- The EU renewed its sanctions regimes against Venezuela, Tunisia, Hamas and the Palestinian Islamic Jihad, and Russia. The European Commission added its intention to ban imports of Russian primary aluminium as part of its EU’s 16th sanctions package against Russia. The EU Commission also proposed tariffs on all agricultural imports from Russia and Belarus that are not already subject to increased tariffs. Kaja Kallas, Vice President of the European Commission, confirmed rumours the EU has agreed a “roadmap” to easing Syria sanctions. At the end of January, the EU renewed its EU Terrorist Asset Freezing List, which now lists 14 individuals, and 22 groups and entities.
- The UN Security Council updated its sanctions regime on Libya. Among other things the arms embargo no longer applies to certain technical assistance or training given to Libyan security forces and to certain military aircraft or naval vessels in Libya’s territory. The update also permits the frozen assets of the Libyan Investment Authority to be invested in low-risk time deposits for the benefit of the Libyan people.
- Whilst Biden’s last orders as President were largely revoked by Trump immediately, namely those involving Cuba and the West Bank, some have been kept in place. The US continued its sanctions on Afghanistan for a further 12 months and Biden signed two amended executive orders, one widening the scope of sanctions targeting the Western Balkans to include those attempting to engage in sanctioned activity and the other to reflect the fact that certain “recent actions” by the Turkish Government in Syria ceased in 2019. Biden also issued a new executive order expanding the criteria under which a person can be sanctioned for cyberattacks. The Bureau of Industry and Security introduced a new regulatory framework updating US export controls for advanced computing chips and AI models, and announced a rule prohibiting certain transactions involving the sale or import of components with a “sufficient nexus” to Russia or China, as well as a rule imposing targeted export controls on biotech. The US Department of Defense released an updated now-134 company long list of Chinese organisations allegedly involved with the Chinese military.
