Mr. Sanctions
mrsanctions.bsky.social
Mr. Sanctions
@mrsanctions.bsky.social
First, it was Mr. Watchlist... now, after a short sabbatical, it's Mr. Sanctions. News and analysis from the world of global economic sanctions - and hopefully a little entertaining to read! https://www.mrsanctions.com
OFSI Arbitration Costs General Licenses gets 7 new FAQs

7 FAQs added regarding OFSI General Licence INT/2025/5787748 On 23 December, 7 FAQs were added to OFSI's FAQ page. FAQs Q177-Q183 were added to answer questions about the remit and reporting of the Arbitration Costs General Licence. Here is…
OFSI Arbitration Costs General Licenses gets 7 new FAQs
7 FAQs added regarding OFSI General Licence INT/2025/5787748 On 23 December, 7 FAQs were added to OFSI's FAQ page. FAQs Q177-Q183 were added to answer questions about the remit and reporting of the Arbitration Costs General Licence. Here is the new FAQ section: General Licence INT/2025/5787748 177. When should arbitrators and/or arbitration associations use the General Licence? In cases where they are receiving, directing or using funds from, or on behalf of, a designated person (DP) to pay for the costs of an arbitration.
mrsanctions.com
December 23, 2025 at 5:06 PM
Is this blog NSFW now?

I am probably hitting up a pop culture reference many of you are too old to remember, but I'm taking Gemini's advice and adding a category for posts about the functional challenges of screening and screening systems, as well as some commentary on how sanctions information is…
Is this blog NSFW now?
I am probably hitting up a pop culture reference many of you are too old to remember, but I'm taking Gemini's advice and adding a category for posts about the functional challenges of screening and screening systems, as well as some commentary on how sanctions information is organized (and how it could be improved). I've decided to name it "Behind the Screen Door", an homage to the notorious film of a similar name starring the former Ivory Soap Girl, …
mrsanctions.com
December 23, 2025 at 4:23 PM
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…
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:
mrsanctions.com
December 23, 2025 at 4:11 PM
ECJU wants your paperwork… now

Open Licence Annual Returns for 2025 Exporters holding certain Open General Licences (OGLs) will have received automatic requests from SPIRE to complete their annual returns for 2025. Before you submit your return, check the following: • Select the correct reporting…
ECJU wants your paperwork… now
Open Licence Annual Returns for 2025 Exporters holding certain Open General Licences (OGLs) will have received automatic requests from SPIRE to complete their annual returns for 2025. Before you submit your return, check the following: • Select the correct reporting period (01-JAN-25 to 31-DEC-25)• Usage count must be entered accurately.• Surrender any licences no longer in use after submitting returns.
mrsanctions.com
December 23, 2025 at 3:52 PM
A reminder about the “one UK Sanctions List to rule them all” – plus some added value

Moving to a single list for UK sanctions designations - 28 January 2026The OFSI Consolidated List of Asset Freeze Targets is closing. From 09:00 GMT on Wednesday 28 January 2026 the UK Sanctions List will be the…
A reminder about the “one UK Sanctions List to rule them all” – plus some added value
Moving to a single list for UK sanctions designations - 28 January 2026The OFSI Consolidated List of Asset Freeze Targets is closing. From 09:00 GMT on Wednesday 28 January 2026 the UK Sanctions List will be the only source for all UK sanctions designations. There will be no changes to the structure of the current UK Sanctions List. You should use this period before January 2026 to prepare any systems for the formal closure of the OFSI Consolidated List.
mrsanctions.com
December 23, 2025 at 2:26 PM
Industry Event Calendar set up

I've gone out looking for sanctions, export control and general financial crime conferences that already had set dates and times. Ditto for webinars - although these tend to be things that come over the transom. I've included events on general topics like training…
Industry Event Calendar set up
I've gone out looking for sanctions, export control and general financial crime conferences that already had set dates and times. Ditto for webinars - although these tend to be things that come over the transom. I've included events on general topics like training and reputational risk. What I have left out are purely AML or anti-bribery and corruption topics - like SAR writing or CDD/EDD.
mrsanctions.com
December 23, 2025 at 12:06 AM
December 19, 2025: OFAC adds Maduro family & associates to SDN List, plus updated GL and FAQ

Based on the OFAC Notice and related press releases for December 19, 2025: Venezuela-related Designations; Issuance of Venezuela-related General License; Publication of Amended Venezuela-related Frequently…
December 19, 2025: OFAC adds Maduro family & associates to SDN List, plus updated GL and FAQ
Based on the OFAC Notice and related press releases for December 19, 2025: Venezuela-related Designations; Issuance of Venezuela-related General License; Publication of Amended Venezuela-related Frequently Asked Question Treasury Press Release: Treasury Targets Family Members and Associates of Maduro Regime Additions: VENEZUELA-EO13850 Executive Order 13850 CARRETERO NAPOLITANO, Roberto, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) (Linked To: CARRETERO NAPOLITANO, Ramon).
mrsanctions.com
December 19, 2025 at 8:18 PM
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…
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)
mrsanctions.com
December 19, 2025 at 6:49 PM
OFSI amends General Licence INT/2025/7628424

Turns out the General Licence (GL) shows you when things were updated, but not what was amended. As per the email sent by OFSI, the "good stuff" is in the Publication Notice: Publication_Notice_Document_-_INT-2025-7628424Download So, going forward, I'll…
OFSI amends General Licence INT/2025/7628424
Turns out the General Licence (GL) shows you when things were updated, but not what was amended. As per the email sent by OFSI, the "good stuff" is in the Publication Notice: Publication_Notice_Document_-_INT-2025-7628424Download So, going forward, I'll give you the link to the GL, but show you the Publication Notice.
mrsanctions.com
December 19, 2025 at 4:58 PM
Upcoming Industry Events (while my calendar is kaput)

Google has disabled my Mr. Sanctions account, which locks me out of the calendar. In the meantime, here's info on a few upcoming events that recently hit my inbox (titles all link to registration pages, unless otherwise noted): Beyond the Bill…
Upcoming Industry Events (while my calendar is kaput)
Google has disabled my Mr. Sanctions account, which locks me out of the calendar. In the meantime, here's info on a few upcoming events that recently hit my inbox (titles all link to registration pages, unless otherwise noted): Beyond the Bill of Lading: Operationalizing Import Transshipment Detection for Proactive Compliance Event Type: Webinar Date/Time: January 8, 2026, 10 AM EST…
mrsanctions.com
December 19, 2025 at 4:53 PM
Burning Question: Whither Mr. Sanctions?

As you may know, this is a "hobby" for me: it's fun to put together, playing with the AI tools is actually useful long-term at work, and forcing myself to keep on top of the news releases keeps me sharp. And it is just me: when I am on vacation, unless I've…
Burning Question: Whither Mr. Sanctions?
As you may know, this is a "hobby" for me: it's fun to put together, playing with the AI tools is actually useful long-term at work, and forcing myself to keep on top of the news releases keeps me sharp. And it is just me: when I am on vacation, unless I've prepared some thought pieces to post, we'll go dark (the royal We...
mrsanctions.com
December 19, 2025 at 2:08 PM
What did Exodus Movement agree to do with its compliance program?

Based on the OFAC enforcement release and settlement agreement regarding Exodus Movement, Inc., here is a summary of the Compliance Commitments (often found in Section 2 or labeled as a specific point in the agreement terms):…
What did Exodus Movement agree to do with its compliance program?
Based on the OFAC enforcement release and settlement agreement regarding Exodus Movement, Inc., here is a summary of the Compliance Commitments (often found in Section 2 or labeled as a specific point in the agreement terms): Sanctions Compliance Program: Exodus agrees to maintain a comprehensive sanctions compliance program for at least five years. Management Commitment: The company will ensure senior management support and the provision of adequate resources to the compliance function.
mrsanctions.com
December 19, 2025 at 12:35 AM
December 16, 2025: OFAC Settles with Exodus Movement

What Happened Exodus Movement, Inc. (“Exodus”), a U.S. company that makes software wallets for digital assets, has agreed to pay $3,103,360 to settle potential violations of U.S. sanctions against Iran. Between October 2017 and January 2019,…
December 16, 2025: OFAC Settles with Exodus Movement
What Happened Exodus Movement, Inc. (“Exodus”), a U.S. company that makes software wallets for digital assets, has agreed to pay $3,103,360 to settle potential violations of U.S. sanctions against Iran. Between October 2017 and January 2019, Exodus allowed users in Iran to use its software to manage and trade digital currency. While Exodus didn't process the trades itself (it used third-party partners), it earned fees from the transactions.
mrsanctions.com
December 19, 2025 at 12:27 AM
OFAC Amends two Russia-related FAQs

As per the OFAC Notice: Issuance of Amended Russia-related Frequently Asked Questions Release Date 12/18/2025 Recent Actions Body OFAC is issuing two amended Russia-related Frequently Asked Questions, FAQ 1224 and 1225. The FAQs: 1224. What negotiations does…
OFAC Amends two Russia-related FAQs
As per the OFAC Notice: Issuance of Amended Russia-related Frequently Asked Questions Release Date 12/18/2025 Recent Actions Body OFAC is issuing two amended Russia-related Frequently Asked Questions, FAQ 1224 and 1225. The FAQs: 1224. What negotiations does Russia-related General License 131A authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?
mrsanctions.com
December 18, 2025 at 11:49 PM
December 18, 2025: OFAC issues Iran-related and ICC-releated GLs

From the OFAC Notice today: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing International Criminal Court-related General License 11, "Authorizing the Wind Down of Transactions Involving Certain…
December 18, 2025: OFAC issues Iran-related and ICC-releated GLs
From the OFAC Notice today: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing International Criminal Court-related General License 11, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on December 18, 2025;" and Iran-related General License S, "Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on December 18, 2025." and here is the ICC-related one: icc_gl11Download and the Iran-related one: iran_glsDownload
mrsanctions.com
December 18, 2025 at 7:47 PM
December 18, 2025: OFAC adds to Iran, ICC sanctions, removes from Russia sanctions & an FSE designation removal

From today's Notice, the following additions and delistings were made: Iran-related Designations; International Criminal Court-related Designations; Russia-related Designations Removals;…
December 18, 2025: OFAC adds to Iran, ICC sanctions, removes from Russia sanctions & an FSE designation removal
From today's Notice, the following additions and delistings were made: Iran-related Designations; International Criminal Court-related Designations; Russia-related Designations Removals; Foreign Sanctions Evaders Determination Removal; Issuance of Iran-related and International Criminal Court-related General Licenses Treasury Press Release: Treasury Increases Pressure on Iran's Sanctions-Evading Shadow Fleet State Press Release: Sanctioning ICC Judges Directly Engaged in the Illegitimate Targeting of Israel Additions:
mrsanctions.com
December 18, 2025 at 7:44 PM
OSFI adds Wind-Down General Licence for Russian Oil firms

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…
OSFI adds Wind-Down General Licence for Russian Oil firms
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: GL_Document_-_Russian_Oil_Companies_Dec_2025Download
mrsanctions.com
December 18, 2025 at 7:27 PM
December 18, 2025: OFSI adds 2 dozen to Russia sanctions

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…
December 18, 2025: OFSI adds 2 dozen to Russia sanctions
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.
mrsanctions.com
December 18, 2025 at 7:22 PM
December 18, 2025: Notice to Exporters 2025/34 – Russian fertilizer-related general trade license updated

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…
December 18, 2025: Notice to Exporters 2025/34 – Russian fertilizer-related general trade license updated
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.
mrsanctions.com
December 18, 2025 at 7:11 PM
December 17, 2025: OFAC Updates Two Russia-related General Licenses, and related FAQs

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…
December 17, 2025: OFAC Updates Two Russia-related General Licenses, and related FAQs
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…
mrsanctions.com
December 18, 2025 at 7:06 PM
December 17, 2025: OFAC Designations

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…
December 17, 2025: OFAC Designations
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: Transnational Criminal Organizations Sanctions Regulations…
mrsanctions.com
December 18, 2025 at 4:47 PM
December 17, 2025: OFSI updates two General Licences and adds a FAQ

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…
December 17, 2025: OFSI updates two General Licences and adds a FAQ
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…
mrsanctions.com
December 18, 2025 at 4:47 PM
Another way to skin the cat: Canada reminds businesses of the recent Iranian designations

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…
Another way to skin the cat: Canada reminds businesses of the recent Iranian designations
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.
mrsanctions.com
December 18, 2025 at 3:37 PM
UN Security Council Resolution on Al-Shabaab

Security Council Resolution 2806: n2535045Download
UN Security Council Resolution on Al-Shabaab
Security Council Resolution 2806: n2535045Download
mrsanctions.com
December 18, 2025 at 3:29 PM
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.…
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.
mrsanctions.com
December 18, 2025 at 2:46 PM