We are flagging a recent example of continued coordination on sanctions between the United States, United Kingdom, and Australia focused on cybercrime.
On November 19, 2025, the United States, United Kingdom, and Australia jointly imposed sanctions on Russia-based bulletproof hosting (“BPH”) service providers Media Land and ML Cloud and 2 of their key personnel after determining they had supported ransomware operations and other cybercrimes. The US OFAC announcement is here, the UK Government announcement is here (with the OFSI sanctions notice here), and the Australian Government announcement is here.
The authorities determined that these BPH service providers supplied access to specialized servers and other computer infrastructure designed to evade detection and defy law enforcement efforts to disrupt malicious cyber activities. The United States and United Kingdom also imposed sanctions on Hypercore Ltd., which they determined to be a front company of Aeza Group LLC, a BPH service provider sanctioned by the United States earlier this year.
As a result of this trilateral action:
- US: These parties have been added to the Specially Designated Nationals and Blocked Persons List maintained by the Office of Foreign Assets Control (“OFAC“) in the US Department of the Treasury. All property and interests in property of the SDNs that are in the United States or in the possession or control of US Persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more SDNs are also blocked. US Persons are generally prohibited from dealing with these SDNs, directly or indirectly.
- UK: The parties have been added to both the Consolidated List of Financial Sanctions Targets maintained by the Office of Financial Sanctions Implementation (“OFSI”) and the UK Sanctions List maintained by the Foreign, Commonwealth and Development Office. (Note that the Consolidated List is set to be retired on January 28, 2026, with the UK Sanctions List being the only source for UK sanctions designations going forward.) These parties are subject to an asset freeze, meaning it is prohibited to deal with funds or economic resources owned, held or controlled by them or to make funds or economic resources directly or indirectly available to them.
- Australia: The parties have been added to the consolidated list of designated entities maintained by the Australian Sanctions Office. It is a criminal offence to provide assets to these parties, or to use or deal with their assets, with penalties of up to 10 years imprisonment and/or heavy fines.
This latest joint action indicates continued international coordination on sanctions. We have a deep bench of sanctions expertise in all three of these countries – please reach out if you have any questions.
The authors acknowledge the assistance of Ryan Orange in the preparation of this blog post.
