Export Controls & Sanctions: 2025 Year-End Review

As 2025 comes to an end, one theme defines the global compliance landscape: volatility. Over the past twelve months, sanctions and export control regimes have shifted quickly as the second Trump administration reshaped several policies inherited from the Biden years while launching new initiatives focused on Syria, Iran, and transnational cartels.

The United States and its allies continue to grapple with Russia's war in Ukraine and Iran's regional activities, but 2025 also saw the dramatic termination of the long-standing Syria sanctions program, a short-lived but sweeping BIS “Affiliates Rule” that was then suspended, and a new framework for treating cartels as terrorist organizations.