Updates to Sanctions and SDN List Inclusions in 2025
In 2025, the United States and its allies significantly expanded sanctions lists, including the SDN (Specially Designated Nationals) List, to increase pressure on Russia and its partners. The focus is on the energy, financial, and defense sectors, as well as sanctions circumvention. The Office of Foreign Assets Control (OFAC) publishes updates at www.treasury.gov/ofac
Official Sources for Monitoring Sanctions
OFAC: Primary source for SDN List and U.S. sanctions information. The list is available in PDF, XML, and other formats, searchable via Sanctions List Search
Energy Sector: OFAC added PAO Gazprom Neft, PAO Surgutneftegaz, and subsidiaries like OOO Gazprom Neft Shelf, AO Gazpromneft-Moskovsky NPZ, AO Gazpromneft-Aero, OOO Gazpromneft-Vostok, TOO Gazprom Neft-Kazakhstan, Gazprom Neft International SA, AO Surgutneftegazbank, OOO Kaliningradnefteprodukt, OOO PO Kirishinefteorgsintez, OOO Lengiproneftehim, and OOO Pskovnefteprodukt to the SDN List. Also included were Portovaya and Kriogaz Vysotsk LNG terminals and the Vostok Oil project. Basis: energy sector activities. Source: OFAC Press Release, January 10, 2025
Oilfield Services: Over 30 suppliers, including AO Gazprom Shelfproekt, AO Tehnologii OFS, AO Investgeoservis, OOO Naftagaz-Burenie, OOO RN-Burenie, and OOO Taymyrburervis.
Insurance Companies: SPAO Ingosstrakh and AO AlfaStrakhovanie.
Maritime Sector: PAO Sovcomflot-linked companies (Fornax Ship Management FZCO, Stream Ship Management) and over 183 "shadow fleet" vessels.
Executives: 13 energy company leaders and Ministry of Energy officials.
January 15, 2025:
Financial Sector and Sanctions Evasion: Companies involved in payment schemes for sanctioned goods, including OOO Gerbarium Office Management, AO Atlant Torg, OOO Sigma Partners, AO Tranzaksii i Raschety, AO Arktur, Paylink Limited, and Gerbarium’s CEO Andrey Prikhodko, were added. Basis: creating cross-border payment platforms with banks like Sberbank, Alfa-Bank, Sovcombank, T-Bank, and Bank Tochka. Source: OFAC Press Release, January 15, 2025
Sanctions Duplication: 84 companies previously sanctioned under Executive Order 14024 (2021) were re-added under Executive Order 13662 (2014), complicating potential delisting due to Congressional backing. These include PAO Gazprom Neft, PAO Surgutneftegaz, VTB, and Novikombank.
2. Inclusion of Foreign Companies
China: Nine companies, including Zhoushan Wison (supporting Arctic LNG 2), for electronics supplies and energy projects. Source: OFAC, January 10, 2025
Cyberattacks: Hacker Yin Kecheng was added to the SDN List on January 17, 2025, for breaching OFAC systems in December 2024, accessing non-classified data, including potential sanctions targets. Source: OFAC Press Release, January 17, 2025
3. General Licenses
OFAC issued licenses allowing limited transactions with SDN persons, such as for transaction completion or vessel safety. An energy sector license permits operations with banks (Sberbank, VTB, Alfa-Bank, Sovcombank) until 2028 for specific cases, like uranium imports without alternatives. Source: OFAC General Licenses, 2025
Reasons for SDN List Inclusion
Key Sector Activities: Energy (oil and gas extraction, transport, refining), finance, defense, dual-use technologies.
Sanctions Evasion: Involvement in "shadow fleet" or payment platforms for sanctioned goods.
50% Rule: Companies owned 50% or more by SDN persons are automatically sanctioned.
Secondary Sanctions: Foreign companies risk SDN listing for "material" support to SDN persons, such as equipment or financial transactions. Source: OFAC Sanctions Overview
Consequences of SDN List Inclusion
Asset Freeze: All SDN assets in U.S. jurisdiction are frozen.
Transaction Bans: U.S. persons are prohibited from engaging in transactions with SDN persons, including goods, services, funds, investments, or property dealings.
International Impact: Limits access to dollar transactions and global financial systems. Non-U.S. companies avoid SDN persons to evade secondary sanctions.
Legal Consequences: Administrative and criminal liability for sanctions violations, with potential extradition to the U.S. under international agreements. Source: OFAC FAQs
SDN List Delisting Process
Administrative Process: Submit a petition to the OFAC Director with justification.
Judicial Process: Appeal OFAC denials in U.S. courts. In 2009 and 2011, courts ruled OFAC actions against KindHearts and Al Haramain unconstitutional due to lack of notification and appeal rights. The process is complex and requires legal support. Source: OFAC FAQs
Other Sanctions Lists
CAPTA List: Restricts access to U.S. correspondent accounts (e.g., Sberbank before SDN listing).
SSI List: Sectoral sanctions for Russian energy, finance, and defense companies.
UN List: Updated March 11, 2025, includes 684 individuals and 193 entities, but does not directly overlap with the SDN List. Source: UN Security Council
For precise verification, consult sanctions-specialized law firms like Bukh Global or Denuo. Source: OFAC
Russian Context
Russia adapts to sanctions through trade with China, India, Turkey, and the UAE, but the SDN List creates significant challenges for international operations, particularly in dollar transactions. Source: OFAC, 2025
Conclusion
The 2025 SDN List updates highlight the U.S.’s strategy to intensify sanctions pressure on Russia and its partners. The inclusion of companies from Russia, China, Turkey, and other countries reflects the global nature of sanctions. To verify company status, use Sanctions List Search and follow U.S. Treasury updates.