February was an unusually quiet month in the sanctions space. Whilst designations under the Trump Administration got underway with a focus on the transportation of Iranian oil and petroleum products, the UK marked the third anniversary of Russia’s invasion of Ukraine with a series of designations. The EU was more aligned with the UK, and adopted its 16th package of sanctions against Russia.
President Trump issued the anticipated executive order imposing sanctions on the International Criminal Court (“ICC”). The designation of British lawyer Karim Khan was the first under the order.
EU courts were the most active this month, with the Netherlands leading enforcement measures against individuals accused of sanctions violations. As part of an ongoing Spanish operation for the enforcement of EU sanctions against Russia, the Spanish Tax Agency arrested five individuals for exporting chemicals to Russia. Elsewhere, Dominican Republic authorities seized a Venezuelan government aircraft at the request of the US government early in the month.
Designations
- OFAC made its first designations under the new Trump Administration in early February with the listing of six individuals, nine entities and three vessels that comprise an oil network operating on behalf of the Iranian military. The network allegedly facilitates shipments of Iranian crude oil to China. This came as Trump signed a memorandum promising to impose pressure on the Iranian government through further sanctions and enforcement mechanisms. Throughout the month OFAC focused on Iran, later designating 30 people, entities and vessels for brokering the sale and transportation of Iranian petroleum products. It also designated six Hong Kong-based companies for procuring unmanned aerial vehicle components for US-sanctioned Iranian companies. The US Department of State also designated eight entities for selling and transporting Iranian petroleum.
- Separately, OFAC designated two people and two entities under its sanctions regime targeting the Democratic Republic of Congo, including James Kabarebe, Rwanda’s Minister of State for Regional Integration. The US Department of State designated eight Mexican and Venezuelan drug cartels as foreign terrorist organisations. The US Bureau of Industry and Security (“BIS”) renewed the temporary denial of export privileges for Russian airline Azur Air for operating controlled aircraft on flights in Russia without the necessary licences. The BIS also issued the temporary denial of export privileges of Kirill Gordei, a Belarusian citizen and the President of a freight forwarding service, and six companies that allegedly facilitated shipments of US goods to Russia in violation of US export controls.
- The UK continued designating individuals and entities under its Russian sanctions programmes. Early in the month OFSI joined the US and Australia in targeting Zservers, a Russian ransomware entity, and its administrators. Marking the third anniversary of the Russian invasion of Ukraine, the UK designated 34 people, 33 entities and 40 vessels under its Russian sanctions regime, including the North Korean defence minister and other senior officials. The UK also designated three people and two entities connected to the Russian government who featured on Alexei Navalny’s anti-corruption list.
- The Ukrainian government sanctioned five people in February, including its former President and opposition politician Petro Poroshenko. The SBU said the sanctions were imposed due to threats to the national security, territorial integrity and sovereignty of Ukraine.
Regulations Amendments
- The EU adopted its 16th Russia sanctions package, which includes inter alia restrictions on primary aluminium imports from Russia to the EU, the designation of 48 individuals, 35 entities, and 74 shadow fleet vessels, as well as restrictions on the sales of video game consoles and flight simulators. The package came into force on 24th February 2025.
- President Trump issued the anticipated executive order imposing sanctions on the International Criminal Court (“ICC”) in response to the ICC engaging in actions against the US and Israel. Sanctions target those who have engaged in an effort by the ICC to investigate, arrest, detain, and prosecute a person without consent of that person’s country. The first person to be designated under the executive order was Karim Khan, a British lawyer and ICC prosecutor.
- Three legislative bills were introduced in the US congress in February. If passed, congress would be required to review whether certain members of Hong Kong’s judiciary should be sanctioned for human rights violations; to review sanctions controls against Chinese individuals and entities involved in the production, sale, financing, and transportation of synthetic opioids; and to review the termination of US petroleum trade with Venezuela until the July 2024 election results are respected.
- The US Department of State announced the re-imposition of the Cuba Restricted List, which limits transactions with certain military and government-linked Cuban entities. It concurrently published a list of 237 entities across several sectors to be added to the list. The original list issued by President Trump in 2017 was rescinded by President Biden in January 2025. The US also expanded its Cuba visa restriction policy to include current or former Cuban government officials and others that the Department of State deems responsible for Cuba’s labour export programme.
- Other amendments to measures in the US included Trump’s announcement that he would cancel the Venezuela-related general licence signed by President Biden in November 2022, which allowed Chevron Corporation to resume extraction operations in Venezuela. Separately, OFAC granted the Serbian Oil Industry (“NIS”) a licence suspending sanctions against it for 30 days to allow it to continue operating whilst organising its ownership structure. It is currently owned by sanctioned Russian oil company Gazprom Neft. The US also disbanded the KleptoCapture Task Force, which was set up in March 2022 to enforce sanctions against Russia. Resources currently going to KleptoCapture will be redirected to fighting transnational criminal organisations and cartels.
- The easing of sanctions against Syria was a common theme in the UK and EU following the fall of Assad’s dictatorship in December 2024. The UK Government issued a humanitarian exemption under the Syrian programme and claimed it was looking to amend its regulations targeting the country. Having agreed a roadmap for easing sanctions against Syria last month, in February the EU Council suspended sanctions on Syria’s energy and transport sectors. Designations related to chemical weapons, drugs, dual-use goods, and the import and export of Syrian cultural heritage goods have remained in place. The EU separately renewed sanctions against Zimbabwe and its EU terrorist asset freezing list, also extending humanitarian exemptions applicable to the list and to sanctions targeting ISIL and Al Qaida.
- Alongside a statement by the UK Foreign Office on the situation in Eastern DRC and Rwanda’s involvement in the conflict, the UK removed Rwanda as a permitted destination on four military export licences. The Foreign Office also suggested the possibility of imposing new sanctions on Rwanda for its involvement in conflict.
Enforcement
- Dominican Republic authorities seized a Venezuelan government aircraft at the request of the US government in early February. The aircraft was allegedly used by high-ranking officials from President Nicolás Maduro’s administration and US-sanctioned Venezuelan state-owned oil company Petroleos de Venezuela SA. The Department of Justice also announced the indictments of Kyrgyz arms dealer Sergei Zharnovnikov for exporting weapons from the US to Russia without licences, and of Flighttime Enterprises, an American subsidiary of a Russian aircraft parts supplier, and three of its employees for the illegal export of aircraft parts to Russia. Alabama-based Ray Hunt was sentenced to five years in prison for violating trade sanctions by conspiring to export US-origin goods to Iran through his company Vega Tools LLC. Separately, the US District Court for Columbia dismissed the delisting challenge of Burmese individual Theint Win Htet.
- In the EU, Dutch authorities were the most active. The Netherlands’ tax crime investigation service arrested an individual for exporting approximately $24 million worth of computer motherboards and graphics cards to Russian customers via Hong Kong, the UAE and Cyprus, in breach of EU sanctions. A woman was also sentenced to 90 days imprisonment for transferring money to her a brother, an active member of ISIS. A banker whose services the woman used to send the money has also been arrested. The District Court of Amsterdam confirmed a settlement of €120,000 between an unnamed company and Dutch prosecutors for exporting machinery to Crimea in 2016 and 2017 in breach of EU sanctions on Russia.
- Elsewhere in the EU, the Spanish Tax Agency arrested five individuals in Barcelona and Valencia for exporting chemicals to Russia. The arrests were part of Operation Probirka, targeting the export of chemicals used in manufacturing explosives and chemical weapons. The operation involved front companies and intermediaries in Kyrgyzstan and Armenia. In Lithuania, customs officials raided companies suspected of transporting vehicles to Russia and Belarus in violation of EU sanctions. Eighteen vehicles were seized and four people detained on suspicion of violations. In Germany, the Public Prosecutor’s Office is investigating Roman Abramovich on suspicion of failing to disclose four vehicles and a villa in the country in breach of Germany’s Foreign Trade And Payments Act.
- UK prosecutors charged sanctioned individual Aozma Sultana for breaching UK Counter-Terrorism Sanctions Regulations for financially supporting Gaza Now, a news agency that promotes Hamas and Palestinian Islamic Jihad. She was also accused of failing to provide the UK government with information about her finances after being sanctioned in March 2024. Separately, the UK High Court rejected the delisting application of Dana Astra, a property company sanctioned under its Belarusian regime.
