The Sanctions Update, compiled by attorneys from Steptoe's award-winning International Regulatory Compliance team and the Stepwise: Risk Outlook editorial team, publishes every Monday. Guided by the expertise of Steptoe's industry-leading IRC team, the Sanctions Update compiles and contextualizes weekly developments in international regulatory enforcement and compliance, as well as offers insights on geopolitical context, business impacts, and forthcoming risks.
Subscribe to the Stepwise Risk Outlook here. To receive only the Sanctions Update edition (published most Mondays), select "Stepwise Risk Outlook: Sanctions Update." For more detailed analysis on related issues, see Steptoe's International Compliance Blog. For information on industry-specific monitoring or bespoke services, please contact the team here.
The Lede
Trump Administration's Powerful New Trade Tool: Secondary Tariffs
On March 24, President Trump signed an executive order declaring that any country buying oil or gas from Venezuela would risk a 25% percent tariff on all exports to the US. Trump initiated the trade remedy to support US policy that seeks to isolate and punish the regime of Nicolás Maduro in Venezuela for ongoing destabilizing actions. Calling these "secondary tariffs," President Trump has created a novel trade tool, using existing presidential authorities to penalize a country's entire economy, unlike sanctions that target specific individuals or entities. Further, secondary tariffs could significantly amplify the impact of American trade policies—compelling third-party compliance with American national security priorities under threat of broad trade impacts. Secondary tariffs risk becoming a preferred economic instrument of power for President Trump and future US presidents, barring legal checks on executive power.
President Trump used the executive authority under the International Emergency Economic Powers Act (IEEPA) to broaden existing sanctions on Venezuela that designated the Maduro regime as an unusual and extraordinary threat to US national security, including the threat of third-party trade action against countries that economically support the regime by purchasing Venezuelan oil and gas. The executive order identified the Maduro regime's destabilizing actions as supporting transnational criminal organization Tren de Aragua (a US-designated Foreign Terrorist Organization), enabling the gang to establish a foothold in the US and prey upon American citizens, as well as undermining democracy in Venezuela, destabilizing the Western Hemisphere through the forced migration of millions of Venezuelans, public corruption and deepening the humanitarian and public health crisis in Venezuela.
Historically, tariffs have not been imposed using emergency powers, but rather trade enforcement laws, such as Section 301 of the Trade Act of 1974 (for unfair trading practices by foreign governments) or Section 232 of the Trade Expansion Act of 1962 (for trade practices posing a threat to national security). President Trump broke new ground on February 1, when he used IEEPA to impose tariffs on Canada, China, and Mexico, citing the extraordinary threat from illegal immigration and drug trafficking. Congress enacted IEEPA in 1977 to give the president the power to act promptly to protect US national security. This delegation grants the president broad powers, essentially enabling him to impose or lift sanctions—and now tariffs—at will, avoiding due process delays that other trade laws impose, such as investigations for fact-finding, public comment, or Congressional approvals. Tariffs imposed under IEEPA allow President Trump to move at speed, a key signature thus far of his administration, to counter national security threats that he alone can determine.
President Trump's use of IEEPA authorities to impose tariffs may yet be challenged in US courts as unconstitutional. In the meantime, however, foreign countries buying Venezuelan oil and gas risk becoming targets of steep tariffs, layered on top of various other tariffs currently being imposed, threatened, or postponed by the White House. The Trump administration is betting that countries will mitigate these risks by buying their oil elsewhere, even if they have to pay more. Should President Trump assess the secondary tariff policy is working, he is likely to expand its use, with Iranian oil exports a likely next target, or even Russian oil exports, should Russian President Putin drag his feet on a comprehensive ceasefire agreement with Ukraine.
US Developments
Trump Imposes "Secondary" Tariffs on Importers of Venezuelan Oil
President Trump issued an Executive Order (EO) authorizing the imposition of a 25 percent tariff on goods imported into the US from any country that imports Venezuelan-origin crude oil or petroleum products, whether directly from Venezuela or via third parties. As of April 2, 2025, the Secretary of State is authorized to determine which countries the tariff will be imposed upon. The Secretary of Commerce is authorized to undertake a variety of additional measures to implement the EO, including the promulgation of regulations. The tariffs would be imposed in addition to any other previously existing tariff measures.
The EO is issued under the International Emergency Economic Powers Act (IEEPA), which Trump previously used to impose tariffs on other countries, including Canada, Mexico, and China. As we previously covered, IEEPA is the primary statute that underpins US sanctions programs; before Trump's second term, it was never used to impose tariffs. The new tariffs are particularly notable because they operate similarly to secondary sanctions. That is, the tariffs are not placed directly on Venezuela, but on countries that import crude oil or petroleum products from Venezuela. The application of these "secondary" tariffs under IEEPA is novel. The Trump administration will likely be evaluating whether these secondary tariffs are an effective tool for the administration's foreign policy and trade goals and, if so, it may promulgate similar measures against other countries going forward. Notably, Trump recently raised the prospect of 25 to 50 percent secondary tariffs on countries purchasing Russian oil if Trump concludes that Russian President Vladimir Putin is at fault for failing to reach an agreement on the war in Ukraine. Similarly, Trump said he would consider secondary tariffs on Iran if it did not agree to a nuclear deal with the US.
Trump cited multiple reasons for the tariffs, including Venezuelan President Nicolás Maduro's alleged undermining of democratic institutions, economic mismanagement, and, most importantly, support for Tren de Aragua (TdA), which the Trump administration designated as a Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT) earlier this year. Trump also cited Venezuela's resistance to accepting deportation flights from the US of suspected TdA members as an additional factor.
Shortly before the tariff announcement, the Office of Foreign Assets Control (OFAC) issued Venezuela General License 41B, "Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation's Joint Ventures in Venezuela." Among other things, General License 41B extended the term of the Chevron license until May 27, 2025.
US Engages with Syria on Sanctions Relief
The US has reportedly given Syria a "list of conditions" that, if met, would trigger partial sanctions relief for the current Syrian government. According to sources familiar with the matter, the conditions require that the Syrian government:
- destroys any remaining chemical weapons stores;
- cooperates on counterterrorism efforts;
- guarantees that foreign fighters will not assume senior government roles; and
- appoints a liaison to help locate a missing American journalist, Austin Tice.
President Trump has previously stated that he does not want to get involved in Syria, a point that was reinforced by the Department of Defense's reported plans to withdraw troops from the country. However, members of Congress and advocacy groups are increasingly calling on the Trump administration to provide sanctions relief, and the administration now appears willing to engage with the Syrian regime on the matter. It remains to be seen whether Syria will accept the Trump administration's reported proposal, and if it does, what sanctions relief would be provided.
State Department Imposes Visa Restrictions on Former President of Argentina
The State Department announced that it was imposing visa restrictions Cristina Elisabet Fernandez de Kirchner, the former president of Argentina, and Julio Miguel De Vido, the former Minister of Planning of Argentina, for their alleged involvement in significant corruption during their time in office. As a result, the designees and their family members are prohibited from entering the United States. The measures are authorized under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act of 2024, which permits the Secretary of State to designate individuals based on credible information of involvement in significant corruption or a gross violation of human rights. In February 2024, Secretary of State Marco Rubio was one of eight senators who sent a letter to President Biden calling for the designation of Kirchner and others.
OFAC Designates Hizballah Sanctions Evasion Network
OFAC designated five individuals and three companies allegedly involved in a Lebanon-based sanctions evasion network supporting Hizballah, a Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SGDT). In particular, the designees are allegedly part of a network of commercial enterprises owned or controlled by Hizballah that facilitate and mask oil sales of Iran's Islamic Revolutionary Guard Corps – Qods Force. The State Department also announced that it is offering a reward of up to $10 million for information leading to the disruption of the financial mechanisms of Hizballah. These actions build on President Trump's National Security Presidential Memorandum (NSPM-2), which specifically calls for the implementation of a "robust and continual sanctions enforcement campaign with respect to Iran that denies the regime and its terror proxies access to revenue." The Trump administration is likely to continue aggressively pursuing sanctions against individuals and entities who support Hizballah, Hamas, Ansarallah (commonly known as the "Houthis"), and any other known or emergent proxy organization affiliated with Iran.
Treasury Sanctions Iranian Officers Involved in Probable Death of FBI Agent
The Department of the Treasury's Office of Foreign Assets Control (OFAC) imposed sanctions on three Iranian Ministry of Intelligence and Security (MOIS) officials allegedly involved in the probable death of former FBI Agent Robert Levinson. The designations were made pursuant to Executive Order (EO) 14078, "Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home." The Trump administration previously sanctioned MOIS officials for their alleged involvement in Levinson's abduction, detention, and probable death on December 14, 2020.
BIS Targets Chinese Technology Firms, Adds to Entity List
The Bureau of Industry and Security (BIS) announced the addition of 80 entities across multiple jurisdictions, including China, the United Arab Emirates (UAE), South Africa, Iran, and Taiwan, to the Entity List. As a result, all of the entities are subject to additional license requirements for the export, re-export, or transfer (in-country) of certain items subject to the EAR.
The End-User Review Committee (ERC) added most of the entities for alleged acquisition or attempted acquisition of US-origin items in support of China's military or pursuit of advanced technologies. In particular, some entities were targeted for their involvement in developing technologies such as AI, quantum computing, hypersonics, and integrated circuits for China-based end-users with significant ties to the country's military-industrial complex. A smaller number of entities were identified due to their alleged connections to Iran's unmanned aerial vehicle (UAV) programs, Pakistan's nuclear activities, or the Test Flying Academy of South Africa (TFASA), which was already on the Entity List for training Chinese military pilots using Western and NATO sources.
This is BIS's first major action under the Trump administration. The announcement follows reports that Commerce was weighing three rules that would tighten Biden-era controls on the export of sensitive technologies to China, including amendments to existing export rules for US-made chips for AI, further limitations on certain Chinese AI apps and model weights, and new restrictions on so-called "remote access."
UK Developments
UK High Court Allows £1.5 billion Standard Chartered Sanctions Lawsuit to Proceed
On March 25, 2025, the High Court allowed a £1.5 billion investor lawsuit against Standard Chartered to proceed, focusing on allegations that the bank misled investors about its Iran sanctions compliance between 2007 and 2019. The ruling highlights the increasing litigation risks businesses face over sanctions-related disclosures, reinforcing the need for transparency and robust compliance controls. The case follows Standard Chartered's 2019 agreement to pay $1.1 billion to US and UK regulators for sanctions violations, with investors claiming the breaches were more extensive than admitted. A key legal issue is whether investors who did not directly read the bank's disclosures can still claim reliance. The Court rejected the bank's attempt to dismiss the case, finding the legal questions warranted a full trial, which is scheduled for October 2026.
EU Developments
EU Commission Launches EU Sanctions Helpdesk
On 25 March 2025, the EU Commission released a new EU sanctions helpdesk. This tool is exclusively aimed at helping small and medium-sized enterprises (SMEs) comply with the over 40 sanctions regimes that the EU has in place. All sanctions, or restrictive measures as they are officially called, enacted by the EU or by the UN and applied by the EU will be covered, whether these are geographical (e.g., restrictive measures against Russia) or thematic (e.g., cyber-attacks sanctions or human rights sanctions). The helpdesk will compile all sanctions-related information, country-specific guidance, events, tips, lessons learned, and more. It will also provide personalized support to European SMEs performing sanctions due diligence checks. This service is free of charge.
EU Council Imposes Additional Sanctions on Belarus for Undermining Democracy and Human Rights
The EU Council has imposed new restrictive measures on 25 individuals and 7 entities in Belarus for actions undermining democracy, human rights abuses, and military cooperation with Russia in its war against Ukraine. The sanctions target key figures, including members of the Central Election Commission, which organized the 2025 presidential elections that were widely criticized as neither free nor fair and resulted in the Lukashenko regime's seventh term. Additionally, the measures target judges who issued politically motivated sentences against dissidents and members of the President Property Management Directorate, which generates revenue for the Lukashenko regime. Notable entities, such as Ridotto LLC and companies in the military-industrial complex, were also sanctioned. Alexander Lukashenko, the long-standing president of Belarus, is accused of electoral manipulation, repressing dissent, and imposing restrictions on the media and civil society. The sanctions include asset freezes and travel bans, bringing the total to 310 individuals and 46 entities under EU sanctions.
EU Council Updates Sanctions Against Haiti, the Central African Republic and the Terrorism Thematic Sanctions
The EU Council has updated various security-related restrictive measures following a series of updates at the UN level. Changes concerning the Central African Republic (CAR) include lifting the arms embargo on the Government of CAR and establishing an arms embargo on armed groups and associated individuals operating in CAR. The lifting of the embargo on the CAR is attributed to the country's steady progress in political and peace processes, as well as the need to equip the government with resources to combat armed groups and restore peace and security in the country.
Changes made to the Haiti sanctions involve modifying the arms embargo—which was previously applicable only to small arms, light weapons, and ammunition—to now cover all arms and related materials. It also specifies that actions threatening the peace, stability, and security of Haiti now include the illicit exploitation and trade of natural resources. The changes come amid persistent conflict between Haiti's government and gangs in Port-au-Prince and a global effort to curb the supply of arms to violent gangs there.
Regarding the terrorism thematic sanctions, the Council has added Mohamed Ibrahim al-Shafi'i Al-Salem, the leader of an ISIL-affiliated group operating in Burkina Faso, Niger, and Mali, as well as the group Katiba Macina, an Al-Qaeda affiliate active in the Sahel in central Mali, Niger, and Burkina Faso, to the list of sanctions persons.
EU Commission Updates FAQs Clarifying 14th Sanctions Package Provision
The 14th package of Russian sanctions introduced a ban on reloading services for transshipment of Russian Liquified Natural Gas to third countries. This provision was set to start applying from 26 March 2025 onwards. As this provision is now applicable, the European Commission has updated its sanctions FAQs on Article 3r of Council Regulation 833/2014 which instates the ban, providing key clarifications. These include scenarios where Russian LNG is mixed with LNG of non-Russian origin, the period during which an authorization can be granted and details on the authorization assessment made by the National Competent Authorities.
EU Rejects Russian Demand for Sanctions Relief in Ceasefire Agreement
The EU has reportedly firmly rejected Russia's demand to lift sanctions on the Russian Agricultural Bank (Rosselkhozbank) and other financial organizations involved in agricultural trade as part of a partial ceasefire deal. This decision follows the US announcement of a partial ceasefire agreement with Russia and Ukraine, aimed at protecting energy infrastructure and ensuring safe navigation in the Black Sea. Russia's demands include reconnecting Rosselkhozbank and other financial institutions to the SWIFT banking system—a secure and fast system for transferring money. As part of the 6th sanctions package, the EU had removed Rosselkhozbank from SWIFT. Although the US claims that the sanctions allegedly restrict Russia's food and fertilizer exports to third countries, the EU maintains that its sanctions do not target agricultural trade, as only tariffs are imposed. The EU insists that sanctions will remain in place until Russia unconditionally withdraws its troops from Ukraine.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
