Whilst March was a relatively quiet month for Russian designations, there was significant discourse in global politics surrounding future sanctions and tariffs. Amid calls by Russia for the easing of sanctions in exchange for a naval ceasefire on the Black Sea, the US Department of State and OFAC are reportedly reviewing Russian sanctions that could be lifted to facilitate the end of the war in Ukraine. US Secretary of State Marco Rubio said the US would evaluate the conditions placed on the ceasefire, although President Trump added that if a ceasefire deal is not reached, the US will introduce secondary tariffs of up to 50% on all oil coming out of Russia. The EU and UK have maintained that sanctions will remain in place or increase until the unconditional withdrawal of Russian troops from Ukraine.
The US is also intensifying economic and diplomatic pressure on Venezuela and its President Nicolás Maduro. Trump announced the imposition of 25% tariffs on all imports from any country that buys oil from Venezuela, as well as the revocation of western oil companies’ licenses which enabled them to conduct business with Venezuela’s state oil company, PDVSA. Elsewhere, the US has focused its efforts on the delivery of Iranian oil to China.
Indicative of a global trend in the easing of restrictions against Syria, the UK removed 24 entities, including the Central Bank and state oil company from its Syrian sanctions list. The European Parliament also adopted a resolution calling for the easing of sanctions in Syria to aid its reconstruction efforts. There has been no update to US sanctions against Syria since aJanuary General License authorising certain transactions related to energy and personal remittances.
Designations
- The US Department of State re-designated the Yemen-based Houthis as a Foreign Terrorist Organisation, having revoked the designation during the Biden administration. The designation was followed by amendments to six general licenses and the listing of seven high-ranking members of the Houthis for smuggling arms into Houthi-controlled areas of Yemen and negotiating weapons procurements from Russia. OFAC also designated a Houthi-affiliated operative and his company for recruiting Yemeni civilians to fight on behalf of Russia in Ukraine.
- OFAC designated Iran’s oil minister Mohsen Paknejad for his role in overseeing the export of billions of dollars’ worth of Iranian oil. Over the month OFAC further designated several entities, one person and eight vessels in multiple jurisdictions for involvement in shipping Iranian oil to China. The Department of State concurrently sanctioned three entities and three vessels that allegedly facilitate ship-to-ship transfers of Iranian crude oil sent to China, as well as a Chinese oil terminal for buying and storing Iranian oil. The US placed further pressure on Iran by declining to renew a waiver that had allowed Iraq to buy electricity from Iran, and by designating three Iranian Ministry of Intelligence and Security officials for their role in the abduction, detention and probable death of former FBI agent Robert Levinson.
- Focusing on China, the US Department of State introduced new visa restrictions on current or former foreign government officials responsible for the forced return of Uyghurs and members of other ethnic groups to China. Visa restrictions were also imposed on Chinese officials who restrict the access of foreigners to Tibet. The State Department sanctioned six officials alleged to have threatened Hong Kong’s autonomy, whilst OFAC designated Shanghai-based cybercriminal Zhou Shuai and his company. The US Department of Justice concurrently charged 12 contract hackers and law enforcement officers in China, including Zhou Shuai, for cyber-attacking campaigns against US networks, and the Department of State announced a $2 million reward for information leading to the arrest of Zhou Shuai and his partner Yin Keching.
- Other designations made by the US in March include Behrouz Parsarad, the head of online dark-net marketplace Nemesis, for facilitating the sale of $30 million worth of drugs; and Jumilca Sandivel Hernandez Perez, a leader of Guatemala-based transnational criminal organisation the Lopez Human Smuggling Organisation; as well as former President of Argentina Cristina Elisabet Fernandez de Kirchner, and former Minister of Planning of Argentina Julio Miguel de Vido for their involvement in “significant corruption” during their time in office. Under the US counter-terrorism sanctions programme, OFAC sanctioned five people and three companies involved in a network supporting Hizballah’s financing team, as well as six people and seven entities involved in a money laundering network supporting the Sinaloa Cartel.
- The UK removed 24 entities across several sectors from its Syrian sanctions list. They include the Central Bank of Syria and the Syrian Petroleum Company. The Parliamentary Under-Secretary of State for Foreign Affairs later referenced the removal of asset freezes as indicative of the UK’s easing of Syrian sanctions and its support of Syria’s economic recovery and political transition. Designations by the UK were sparse in March, with just four individuals in Sri Lanka targeted for human rights abuses. The UK also reported breaches of counter-terrorism sanctions committed by three charities which failed to provide OFSI with requested information.
- The EU designated nine people and one entity under its sanctions regime against the Democratic Republic of Congo, including the leaders of non-governmental armed group M23. It also sanctioned 25 people and 7 entities under its Belarus sanctions regime, as well as the Al Azaim Media Foundation, the media branch of Islamic State’s Khorasan Province.
Regulations Amendments
- After the US Government’s decision to cancel Chevron’s licence to operate in Venezuela, OFAC issued a general license authorising the wind down of transactions related to Chevron’s joint ventures in Venezuela. On 30th March the Financial Times reported that the US was revoking licences allowing western oil companies to do business in Venezuela. The operations of trading company Global Oil Terminals will have to wind down by May, whilst Italian oil major Eni is no longer allowed to be repaid for the gas it produces in Venezuela through oil supplies given to it by PDVSA. At the end of March President Trump also announced the possibility of introducing 25% tariffs on all goods imported into the US from any country that directly or indirectly imports Venezuelan oil.
- The Department of State and OFAC are reportedly reviewing possible sanctions that could be eased in the effort to end the war in Ukraine. The Kremlin has claimed that a naval ceasefire with Ukraine could take place if certain western economic sanctions targeting Russia are lifted. In response the EU Commission stated that EU sanctions will remain in place until the unconditional withdrawal of Russian troops from Ukraine and UK Prime Minister Keir Starmer advocated for the strengthening of sanctions against Russia. US Secretary of State Marco Rubio said the US would evaluate the conditions placed on the ceasefire. President Trump added that if a ceasefire deal is not reached, the US will introduce secondary tariffs up to 50% on all oil coming out of Russia. Earlier in the month Trump said he was considering large-scale banking sanctions and tariffs on Russia whilst US Treasury spokesman Scott Bessent stated that the US Government plans to use sanctions aggressively. Nevertheless, the US reportedly vetoed a Canadian proposal for a G7 collaborative targeting of Russia’s shadow-fleet of oil tankers. OFAC has also granted a 30-day extension to a sanctions waiver allowing Serbian oil and gas company, Serbian Oil Industry, to continue operating whilst finding a solution to its ownership structure. It is currently owned by sanctioned Gazprom Neft.
- In late February the EU extended sanctions relating to the misappropriation of Ukrainian State funds and human rights violations in Ukraine. On 14th March the EU announced the extension of its Russian sanctions regime, currently targeting 2,400 individuals and entities, despite the fact the Hungarian government had reportedly threatened to block the renewal unless Russian oligarch Mikhail Fridman’s designation was removed. Fridman has remained on the EU’s designation list. The UN has also extended sanctions against Al-Shabaab in Somalia until December 2025.
- The European parliament adopted resolutions relating to sanctions targeting Russia, Syria, Sudan, Haiti, Central African Republic (“CAR”), and Azerbaijan. These included the introduction of limitations on Russian and Belarusian citizens entering the EU, expanded trade sanctions, and a statute countering the impact of US sanctions on the International Criminal Court. Among other changes, resolutions also included the adoption of sanctions on individuals responsible for human rights violations in Sudan and Azerbaijan, as well as extensions to EU sanctions against Haiti and CAR to include a more expansive arms embargo. Conversely, the European Parliament adopted a resolution calling for the easing of sanctions in Syria to aid reconstruction efforts.
- March saw the amendments to several UK General Licenses under the Russian sanctions regime, including one which extends the scope of legal advisory exemptions and one which allows UK nationals to purchase petrol from Gazpromneft petrol stations in Kyrgyzstan and Tajikistan. The UK also amended its sanctions regulations to introduce an urgent designation procedure, enabling the Secretary of State to sanction a person without the same reasonable grounds required under the standard procedure. MPs in the UK parliament also discussed the potential for sanctions against India for alleged human rights abuses in the region of Kashmir and Jammu.
Enforcement
- The US Department of Justice has filed a civil forfeiture complaint against an aircraft, which was smuggled from the US for use by Venezuelan President Nicolás Maduro. Another civil forfeiture complaint was filed with the US District Court of the District of Columbia for $47 million in proceeds from the sale of Iranian oil. A US district judge also granted the Department of Justice’s application to strike out Russian businessman Eduard Khudainatov’s claim that he is the beneficial owner of the Amadea yacht, which is allegedly owned by sanctioned Russian oligarch Suleiman Kerimov.
- US citizen David Bohmerwald pleaded guilty to attempted export control violations, for attempting to export technology with military applications from a US-based electronics company to China without the requisite license. A US indictment has also been unsealed charging Mohammad Jawaid Aziz with violating US export controls by obtaining US goods for restricted entities in Pakistan that were associated with the country’s UAV, nuclear and missile programmes.
- US, Germany and Finland took coordinated action to target Garantex, a cryptocurrency exchange sanctioned by OFAC, which had been accused of evading and violating US sanctions. The action included the indictments of Garantex’s owners for money laundering and sanctions violations, as well as the seizures of website domains and servers supporting Garantex’s operations.
- There were several arrests across Europe on charges of sanctions violations. Russian citizen Ivan Anchevsky was extradited to Estonia from Italy to face charges regarding breaches of the EU’s sanctions against Russia, whilst Latvian prosecutors have been requested by the country’s security services to initiate criminal proceedings against four people for violating EU sanctions against Russia. The individuals allegedly supplied internet satellite kits to the Russian army for use in Ukraine.
- In Germany, the customs investigations offices executed 24 search warrants and seized €14.7 million in assets as part of an investigation into sanctions breaches, and separately arrested a Belarusian woman who allegedly exported 192 vehicles worth a total of €21 million to Russia. In the country’s regional courts, in Hamburg the trial of two ex-Siemens executives accused of violating Russian sanctions by exporting gas turbines to Crimea is ongoing. The Regional Court of Frankfurt dismissed charges against Farkhad Teymur-Ogly Akhmedov who had been accused of failing to notify German authorities of the ownership of a yacht and artwork whilst subject to the EU’s Russia sanctions.
- The first ever UK criminal prosecution for sanctions breaches began on 18th March in London. The case centres on Dmitrii Ovsiannikov, the Governor of Sevastopol, who was indicted for circumventing sanctions in February and March 2023. Ovsiannikov’s wife and brother have also been accused of aiding the circumvention, although all three deny the charges. The UK High Court has also refused Standard Chartered’s application to strike out in respect of claims brought against the bank in a case arising out of non-compliance with US Iran sanctions. The UK government separately issued a press release for a settlement offer worth £374,000 issued to an unnamed company in October 2024. The settlement related to the unlicensed export of dual-use goods.
- The EU General Court rejected the applications for annulment of sanctions against Russian businessman Alexander Ponomarenko, and Belarusian companies Dana Astra and Belarusian Steel Works. The EU Court of Justice also rejected an appeal against the EU General Court’s dismissal of the delisting applications of former Russian Deputy Prime Minister Igor Shuvalov and the designated terrorist group the Kurdistan Workers’ Party (“PKK”). In the US, the US District Court for the District of Colombia rejected the judicial review of OFAC’s decision to refuse to delist Alain Goetz, who allegedly supported armed groups in the Democratic Republic of Congo by trading in gold from regions they controlled.
