Comply Sphere Sanctions Insights – September 2025

Compliance in 60 Seconds

🌍 Global Sanctions Roundup

United Kingdom

• August 20, 2025 – UK imposes sanctions on several individuals and entities in Kyrgyzstan and Russia. The measures target a $9.3B crypto network associated with the A7A5 stablecoin used for Russian transactions. (Reuters)

• July 31, 2025 – OFSI fines Markom Management Ltd £300,000 for breaching EU Russian sanctions, highlighting the importance of thorough screening and internal controls. (GOV.UK)

United States (OFAC)

• August 25, 2025 – OFAC publishes a final rule removing the Syrian Sanctions Regulations from the Code of Federal Regulations. Certain restrictions remain for specific individuals and entities. (OFAC)

📌 Regional Spotlight – Crypto & Kyrgyz Entities

The UK’s sanctions against Kyrgyz-based crypto networks signal increasing scrutiny of digital assets in sanctions evasion. Compliance teams must:

• Include crypto screening in payment and KYC processes

• Review third-party exposure to jurisdictions under sanctions

• Monitor UK and EU enforcement trends

Enforcement & Penalties

• The £300K penalty against Markom Management Ltd serves as a strong reminder: UK sanctions law strictly prohibits providing payments even indirect to designated persons. Companies should ensure robust internal approvals and screening checks GOV.UK

Lesson Learned: Ensure robust internal approvals and real-time sanctions screening.

🛠️ Practical Compliance Tip of the Month

Checklist for Crypto-Related Transactions:

1. Flag transactions linked to emerging stablecoins.

2. Monitor counterparties in jurisdictions known for sanctions evasion.

3. Regularly review and update internal controls to align with UK, EU, and OFAC sanctions.

🎯 Thematic Deep Dive – Crypto in Sanctions Enforcement

Why this matters: The UK’s focus on Kyrgyz-based crypto infrastructure, particularly stablecoins like A7A5, highlights how digital assets are becoming tools for circumventing sanctions. Their freeze underscores:

The UK’s action against A7A5 stablecoin networks illustrates:

• How digital assets are now a tool for sanctions circumvention

• The need for compliance programs to track crypto flows and cross-border payments

• Why regulators are taking a proactive approach to fintech risk

❓ Sanctions Myth Buster

Myth: Crypto transactions are exempt from traditional sanctions screening.

Truth: Stablecoins and other digital assets can be used to evade sanctions, and regulators are actively penalising these flows.

🔮 Looking Ahead

• Monitor potential follow-up UK or EU actions targeting crypto networks.

• Update internal processes for changes to OFAC Syria regulations.

• Reinforce sanctions awareness and training for all employees handling payments or cross-border transactions..

Need help navigating these evolving sanctions landscapes, especially around cryptocurrency risk, Iran scenario planning, or bespoke screening workflows? Contact ComplySphere for tailored advisory, compliance toolkits, or a walkthrough of your process readiness.

Key takeaway: Compliance teams should ensure crypto-related transactions are screened, monitor changing U.S. policy toward Syria, and reinforce internal sanctions controls to avoid costly penalties

• The UK sanctions several Russian crypto networks and Kyrgyz entities linked to the A7A5 stablecoin.

• OFAC removes the Syrian Sanctions Regulations.

• OFSI fines Markom Management Ltd £300K for breaching EU Russian sanctions.