DLA Piper's Sanctions Matrix quarterly update: June 2025

Our quarterly Sanctions Matrix, June 2025 edition is now available.

The Matrix summarises all UK, EU, US and Canada sanctions currently in force and is updated on a quarterly basis.

Key updates in the June 2025 edition include:

• Significant Syria sanctions relief: Each of the US, Canada, the UK and the EU has taken significant action to ease sanctions targeting Syria. These easing measures have taken different legal forms and vary in scope from jurisdiction to jurisdiction. Broadly, however, their stated aim is to support humanitarian and reconstruction efforts following the change of the Syrian regime. As detailed in this edition of the Matrix, as of May 2025, the EU has revoked all economic sanctions on Syria not based on security grounds, while the UK has implemented significant amendments to support Syria's transition to stability and reconstruction, lifting prohibitions on banking, insurance, energy investment and various trade measures. The US and Canada have issued a General License and General Permit respectively to allow a wide range of otherwise prohibited activities and transactions. To reflect these developments, the '“colour coding” for Syria has been changed in this edition, reflecting that, in practice, Syria is no longer “subject to comprehensive US sanctions”. However, the new “colour coding” remains at an escalated level – the same level as Russia and Belarus – to reflect that a wide range of sanctions targeting Syria do remain in place, the measures in some cases are temporary and the situation is dynamic.

• Additional Russia sanctions imposed by the UK, EU and Canada: The EU has introduced two new packages of Russia sanctions since the last edition of the Matrix, expanding restrictions in a range of areas including: Trade in aluminium, dual-use items and other industrial goods with military relevance; the energy sector (including crude oil and petroleum, energy products and measures targeting the “shadow fleet”); infrastructure (including a transaction ban on airports and ports); and broadcast rights. The EU has also added significantly to the list of asset freeze targets and expanded the grounds for designation and for the imposition of other restrictive measures. The UK has also introduced several new packages of Russia sanctions since the last edition of the Matrix, although these are less broad in scope as those imposed by the EU, and mainly comprise additions to the asset freeze list and restrictions on the transfer of certain sectoral software and technology into Russia. Canada also introduced a new package of Russia sanctions since the last edition of the Matrix, expanding restrictions on exports of fuels and chemicals with potential military applications, as well as restrictions on imports of coal, metals, and a broad range of “revenue generating goods” from Russia. Several additions to the list of designated persons were made as well. As of 30 June 2025, when this edition of the Matrix went to press, the US has not imposed similarly broad new sanctions targeting Russia (although there have been more minor changes to this regime as detailed in the Matrix).

A snapshot of the Sanctions Matrix and the issues covered can be downloaded above. Please get in touch with any of the authors to receive the full-length Sanctions Matrix, June 2025, which summarises UK, EU, US and Canada sanctions in 40 jurisdictions, or to arrange an introductory chat.