A new report from LexisNexis Risk Solutions suggests sanctions activity has moderated since a flurry caused by Russia’s 2022 invasion of Ukraine. The Sanctions Pulse analyzes data from the United Nations (UN), European Union (EU), Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI).
Only 1,397 targets were added in the first six months of 2025, compared to between 2,050 and 3,854 in the same period between 2022-2024. Aside from the UN, sanctions are still often deployed. The UN has cut its sanctions frequency by 55%, contributing to a 40% net decrease compared to H1 2024. OFAC designations dropped by two-thirds.
Russia accounted for the largest designations in H1 2025. On Jan. 10, the Treasury Department listed 410 sanctions against Russia and Venezuela, with another 168 added against Russia only five days later. Russia was also dinged with 353 for chemical weapons use on May 20, and a combined 320 sanctions on two different occasions. Russia’s shadow fleet, which seeks to keep Russian oil flowing to fund its war, is a popular sanctions target.
Syria accounts for the most delistings, with at least 564 actions. Russia and Venezuela saw 15 and 14 removed, respectively.
OFAC has recorded moderate activity during the Trump Administration’s first half-year. Popular targets include drug cartels, Iran and cybercriminals.
Across the pond, OFSI is also targeting Russia’s shadow fleet, along with two Russian oil producers. The latter was a joint action with the United States that occurred on January 10.
Human rights were another OFSI focus. Targets here included Guatemalans, Georgians, Moldavans and two Israeli cabinet ministers. Much of its activity was coordinated with other countries.
Looking ahead, LexisNexis Risk Solutions expects a continued focus on Russia.
“Expected measures include further targeting the Russian energy sector and shadow fleets, as well as increased willingness to leverage anti-circumvention mechanisms against countries providing prohibited goods to Russia,” the report predicts.
The rise in cyberattacks could lead to increased action against large fraud-based organizations. Human traffickers should also look over their shoulders. The EU should also be busier.
