I. REGULATORY UPDATES

1. Dec 10, 2025 – Russia: amended General License (GL) 131A to support Lukoil International GmbH divestment and stabilization activities.

OFAC issued amended Russia-related GL 131A to authorize certain otherwise prohibited transactions with Lukoil International GmbH (LIG) and entities in which LIG owns, directly or indirectly, a 50 percent or greater interest. In practical terms, the authorization is framed to keep non-Russian operations running safely and orderly while a divestment or wind-down is pursued, and it is time-limited. The companion guidance makes clear that OFAC views this as an “operational continuity / exit lane” tool – not a blanket permission to transact – and that parties should expect to need separate authorization for any actual sale / transfer of the relevant interests if the contemplated deal goes beyond what is “ordinarily incident and necessary” to the authorized activities.

2. Dec 18, 2025 – Russia: amended FAQs 1224 and 1225 to spell out how OFAC expects divestments to be structured under GL 131A (and how GL 128B fits).

OFAC’s updated FAQ 1225 explains the relationship between GL 128B (covering a narrower slice of LIG’s retail auto service station activity outside Russia) and GL 131A (a broader authorization aimed at enabling Lukoil to divest assets outside Russia), including examples of “ordinary course” transactions that OFAC views as within the authorizations (e.g., fuel supply, lease and insurance payments, maintenance, payroll, IT, taxes/fees, legal services, and performance of pre-existing agreements). FAQ 1224 is especially compliance-significant for deal teams: it states that GL 131A permits negotiations and entering into contingent contracts for the sale of LIG and covered subsidiaries, but it does not authorize consummation of the sale absent further authorization; and it flags the features OFAC expects a proposed transaction to include (including fully severing ties to Lukoil, handling value owed to Lukoil in a way consistent with blocking requirements, and avoiding structures that provide a “windfall” to the blocked party). The same guidance signals OFAC may revoke the authorization if parties do not act in good faith and encourages early engagement where a transaction is complex.

3. Dec 15, 2025 – Belarus: new General License (GL) 13 for specific potash-related counterparties (without unblocking).

OFAC issued Belarus GL 13 to authorize transactions otherwise prohibited by the Belarus Sanctions Regulations involving Joint Stock Company Belarusian Potash Company, Agrorozkvit LLC, Belaruskali OAO, and any entity in which one or more of those persons owns, directly or indirectly (individually or in the aggregate), a 50 percent or greater interest. The text is explicit that this is not an unblocking action: it does not authorize unblocking of property blocked under any part of 31 CFR chapter V, and it does not authorize transactions otherwise prohibited by the Belarus program involving blocked persons other than those expressly covered – unless separately authorized.

4. Dec 17, 2025 – Russia: GL 55E extends (and consolidates) Sakhalin-2-related services relief through June 18, 2026, with tight conditions.

Russia GL 55E authorizes, through 12:01 a.m. EDT June 18, 2026, transactions otherwise prohibited by (i) the November 21, 2022 E.O. 14071 services determination (as it relates to maritime transport of crude oil of Russian origin) when the crude oil is Sakhalin-2 “byproduct” and is solely for importation into Japan; (ii) E.O. 14024 prohibitions involving Gazprombank (and 50%+ owned entities) when the transactions are related to Sakhalin-2 (including transactions involving Sakhalin Energy LLC); and (iii) the January 10, 2025 E.O. 14071 “petroleum services” determination, again where the activity is related to Sakhalin-2. The license also draws bright red lines: it does not authorize Directive 2 (CAPTA) activity, Directive 4 (sovereign) activity, or other RuHSR-prohibited transactions involving blocked persons beyond the narrow Gazprombank-related carveout. GL 55E expressly replaces and supersedes GL 55D.

5. Dec 17, 2025 – Russia: GL 115C renews civil nuclear energy payment pathways (through June 18, 2026) while reaffirming CAPTA/sovereign “no-go” zones.

Russia GL 115C authorizes, through 12:01 a.m. EDT June 18, 2026, civil nuclear energy-related transactions otherwise prohibited by E.O. 14024 involving a listed set of major Russian financial institutions (including Gazprombank, VEB, Otkritie, Sovcombank, Sberbank, VTB, Alfa-Bank, Rosbank, Zenit, Bank Saint-Petersburg, NCC), 50%+ owned entities of those banks, and the Central Bank of the Russian Federation – provided the activity is “related to civil nuclear energy”. The license then narrows the definition and the perimeter: it ties the authorization to maintaining/supporting civil nuclear projects initiated before November 21, 2024, and it excludes (among other things) CAPTA correspondent/payable-through activity and certain sovereign-related debits on U.S. FI books. GL 115C replaces and supersedes GL 115B.

6. Dec 17–18, 2025 – Russia: OFAC updated a cluster of FAQs that materially affect payment routing, de-risking decisions, and secondary-sanctions screening.

Several updates are particularly operational. FAQ 967 reiterates how CAPTA (Directive 2) restrictions operate for US financial institutions – focusing on prohibitions around maintaining correspondent or payable-through accounts and processing certain transactions involving covered foreign financial institutions – while situating GL-based authorizations (like GL 115C) in that architecture. FAQ 978 then gets granular about mechanics: even where a transaction is authorized under certain Russia-related general licenses (including GL 115C), a US financial institution may still be unable to process it if doing so would require maintaining a prohibited correspondent relationship with a CAPTA-covered institution – so the guidance provides examples of how funds transfers may need to be routed through non-sanctioned intermediaries.

FAQ 999 compiles examples of what remains authorized for Directive 4 entities under specific general licenses (including civil nuclear- and project-specific relief), which is useful for banks building “allow/deny” logic. On secondary sanctions risk, FAQ 1117 speaks to exposure for companies engaging with the Russian metals and mining sector and frames risk in relation to what would be authorized/exempt if conducted by US persons, reinforcing the importance of mapping sectoral exposure to licensing posture rather than blanket avoidance.

II. ENFORCEMENT DEVELOPMENTS

1. Dec 16, 2025 – Digital assets / Iran: Exodus Movement settlement highlights “support services” as sanctions-relevant conduct, not just payments.

OFAC announced a $3,103,360 settlement with Exodus Movement, Inc. to resolve potential civil liability for 254 apparent violations of Iran sanctions. OFAC’s public summary frames the conduct as customer support services provided to users in Iran that, in some instances, helped those users access digital asset exchanges through Exodus’s wallet software. Importantly for fintech compliance design, OFAC characterized the matter as not voluntarily self-disclosed and deemed 12 of the apparent violations egregious – an indication that OFAC is scrutinizing not only transactional “flows” but also enabling services (including guidance, troubleshooting, and platform support) when provided to comprehensively sanctioned jurisdictions.

2. Dec 9, 2025 – Trust/fiduciary services / Russia: settlement underscores that “professional role” does not dilute blocking and services prohibitions.

OFAC announced a $1,092,000 settlement with an individual for 122 apparent violations of Russia sanctions. OFAC’s summary states that from April 2018 to June 2022 the individual served as fiduciary of a US-based family trust of a sanctioned Russian oligarch and, in that role, dealt in blocked property and provided prohibited services to the oligarch. OFAC characterized the conduct as non-egregious and not voluntarily self-disclosed but noted substantial cooperation as a factor reflected in the outcome. The case is a reminder for outside counsel and service providers that “fiduciary necessity” is not itself a license: once a beneficial owner is blocked, routine trust administration can become prohibited services unless specifically authorized.

III. OTHER UPDATES: SDNs.

1. Dec 19, 2025 – Venezuela: OFAC added multiple individuals under E.O. 13850 (Venezuela), expanding the sanctions perimeter around regime-linked networks.

In conjunction with GL 5T and the amended FAQ, OFAC updated the SDN List to add multiple individuals designated under the Venezuela E.O. 13850 authorities. The additions include Roberto Carretero Napolitano and Vicente Luis Carretero Napolitano (Panama), as well as several Venezuela-linked individuals including Eloisa Flores de Malpica, Damaris del Carmen Hurtado Perez, Iriamni Malpica Flores, Erica Patricia Malpica Hurtado, and Carlos Evelio Malpica Torrealba. For screening teams, these entries matter because they are rich in identifiers (DOB/POB/nationality/ID numbers) and because the designation authority signals heightened exposure for transactions involving Venezuela-linked politically connected or state-adjacent networks, even where the immediate counterparty is outside Venezuela.

2. Dec 18, 2025 – Russia: removals and other list maintenance require “unblock logic,” not just list refresh.

The same OFAC action package reflects removals of certain Russia-related SDN entries and the removal of a determination from the Foreign Sanctions Evaders List. While de-listings can reduce blocking risk, compliance teams should treat them as operational events: systems need to release false positives, but legal/operations teams must also confirm whether any assets were previously blocked and whether unblocking is now appropriate under U.S. law and internal controls (including ensuring no other sanctions basis continues to apply).