Consider this class that Howard Spieler (he’s the president of the NY ACSS chapter) is running at Rutgers:
I’m excited to share that I’ve been given the opportunity to teach a new graduate course this fall at Rutgers University – School of Criminal Justice, and I’d love your help spreading the word. Because the course was added after registration opened, many students may not know it exists yet, so if you’re a current hashtag#Rutgers MA/ hashtag#CriminalJustice student, or know one, please share this post or pass it along.
The course is 27:202:652 – Issues in Criminology: Investigating & Prosecuting Sanctions, Money Laundering, & Transnational Crime. It looks at hashtag#financialcrime enforcement from the perspective of the hashtag#prosecutors, federal agents, and hashtag#regulators who build these cases, not the compliance view most programs teach (including myself at Montclair State University).
We’ll also be joined by guest practitioners with firsthand experience in federal law enforcement, criminal prosecution, hashtag#cartelfinancing and the intelligence community, sessions I think will be genuinely memorable for the students in the room.
Thank you for your support! I am very excited for this.
This alert is jointly issued by the U.S. Department of State and Federal Bureau of Investigation; Japan’s Ministry of Foreign Affairs, National Cybersecurity Office, National Police Agency, Ministry of Finance, and Ministry of Economy, Trade and Industry; the Republic of Korea’s Ministry of Foreign Affairs and National Police Agency; Australia’s Department of Foreign Affairs and Trade; Global Affairs Canada and the Royal Canadian Mounted Police; France’s Ministry for Europe and Foreign Affairs; Germany’s Federal Foreign Office; Italy’s Ministry of Foreign Affairs and International Cooperation; the Netherlands’ Ministry of Foreign Affairs; New Zealand’s Ministry of Foreign Affairs and Trade; and the United Kingdom’s Foreign, Commonwealth and Development Office and Office of Financial Sanctions Implementation.
North Korea relies upon a network of skilled Information Technology (IT) workers, deployed within and outside of North Korea, to obtain false identities and remotely earn income to fund North Korea’s unlawful nuclear weapons and ballistic missile programs.
North Korean IT workers impersonate nationals of other countries to obtain work and income through online platforms operated by private companies for employment, procurement, and contracting of services. These workers seek out contracts with the intent of remitting their salaries to their parent North Korean agencies. They also pose an insider threat to companies and are involved in data exfiltration, cryptocurrency theft, and theft of sensitive information. North Korean IT workers employ increasingly sophisticated methods, including the integration of AI, to obfuscate their identities and expand their activities globally.
Our countries have repeatedly issued information to warn the international community and private sector of the threat posed by North Korean IT workers. Japan, the United States, and the Republic of Korea issued a “Joint Statement on North Korean IT Workers” in August 2025, and the Multilateral Sanctions Monitoring Team (MSMT) released its second report on North Korea’s violation and evasion of UN sanctions through cyber and IT worker activities in October 2025. The United States, Japan, Republic of Korea, United Kingdom, Australia, and Canada have all issued advisories regarding the risk North Korean IT workers pose to private companies, governments, and individual citizens. We continue to actively monitor and counter the North Korean IT worker threat.
According to UN Security Council Resolution 2397, all UN Member States must repatriate to North Korea all North Korean nationals earning income in that Member State’s jurisdiction, subject to limited exceptions. Additionally, contracting with North Korean IT workers and paying them for services rendered may also violate the domestic laws of many countries, including Japan, the United States, and the Republic of Korea, and may result in legal consequences or financial penalties.
The Financial Action Task Force (FATF) identifies North Korea as a high-risk jurisdiction subject to a call for action (blacklist). The FATF continuously reiterates the need to implement robust targeted financial sanctions consistent with relevant UN Security Council resolutions and calls on all jurisdictions to apply countermeasures to protect their financial systems from North Korean money laundering, terrorist financing, and proliferation financing risks. Yet, North Korea has increased connectivity with the international financial system through diversified revenue generation activities, including IT worker schemes. As spotlighted in the FATF’s Complex Proliferation Financing (PF) and Sanctions Evasion typologies report, North Korea frequently uses IT worker schemes to generate revenue that supports its weapons of mass destruction program.
We urge all countries, companies, and other entities to deepen their understanding of North Korean IT worker schemes and implement measures to counter the tactics listed below. Companies operating online platforms should continue to strengthen their countermeasures, such as enhancing identity verification procedures (strict review of identification documents, requirement of in-person interviews, etc.) and detecting suspicious accounts (introduction of systems that notify anomalous information entries, etc.). The following information is provided by states participating in this alert.
Modus Operandi Used by North Korean IT Workers
Many North Korean IT workers register for accounts on online platforms by falsifying their nationality or identity. Typical methods used include forging identification documents and impersonating another person. North Korean IT workers use images of identification documents provided by third parties—such as proxies residing in third countries—to register accounts, while the actual work is conducted by the North Korean IT workers themselves.
North Korean IT workers are increasingly likely to use third-party proxies to facilitate the creation of online accounts, participate in job interviews, and even establish in-person contact to create a false sense of trust and obtain work contracts.
North Korean IT workers often attempt to avoid being paid by direct deposit and may request payment via money transfer services or cryptocurrency. In many cases, North Korean IT workers provide employers a third party’s bank account as the recipient for payments, request that the third party transfer the funds to a designated foreign account, and provide a part of the payment to the third party as a fee for use of their bank account.
North Korean IT workers often possess high-level skills in IT-related work and are seeking work in wider areas—such as the development of web pages, mobile applications, software, and blockchain applications—through online platforms and other channels. In some cases, they also get work contracts directly from companies or individuals.
While many North Korean IT workers reside in North Korea, China, and Russia, as well as Southeast Asian and African countries, they may conceal the fact that they are working from abroad using third-party proxies, VPNs, remote desktop software, and similar tools.
North Korean IT workers are known to use third-party proxies as facilitators overseas, such as in the United States, to run “laptop farms” which receive company-provided laptop computers for North Korean IT workers to remotely access, obfuscating their true location.
In addition to obtaining IT-related work, North Korean IT workers may obtain foreign currency by engaging in fraudulent foreign exchange trading using automated trading systems they themselves developed.
Furthermore, accounts associated with North Korean IT workers often exhibit the characteristics below. If multiple characteristics apply to a job applicant, there is a possibility that a North Korean IT worker is fraudulently seeking work.
For companies operating online platforms:
Frequent changes to registered information (such as account name, contact details, and bank account information for receiving salaries).
The account holder’s name does not match the name on the registered payment account.
Multiple accounts have been created using the same identification document.
Identification documents used for identity verification appear forged or altered using image editing software.
Multiple accounts are accessed from the same IP address.
A single account is accessed from multiple IP addresses within a short period of time.
The account remains logged in for an unusually long period of time.
The cumulative work hours or related metrics are unnaturally high.
An account user posts false reviews for itself, likely to improve the account’s rating.
For those hiring or procuring services:
The account’s profile contains errors or uses unnatural expressions that appear to be the result of inaccurate machine translation, indicating a lack of proficiency in the language of the country they claim to be from. (However, North Koreans may use translation services or large language models to produce convincing profiles and communications in second languages.)
Discrepancies appear in video conference meetings, including photo ID mismatches or video feeds that appear to be manipulated or artificially generated.
Refuses to participate in video conference meetings.
Offers to work at rates lower than the general market rate.
Shows signs that the account is being operated by multiple people. North Korean IT workers often operate in teams, and the individual whom a hiring or procuring official interacts with may change depending on the time of day.
The United Nations Security Council Subsidiary Organs Branch (the Secretariat) conveys updates to the Committees’ lists and to the United Nations Security Council Consolidated List, to States, regional and sub-regional organizations, and private entities/individuals by email after updates are made to the Lists. At this time, not all documents are available in all languages.
The updates mentioned in the subject above were made on 30 July 2026.
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Security Council Sanctions Committee Established Pursuant to Resolution 1988 (2011) Amends Five Names on Its Sanctions List
On 30 July 2026, the Security Council Committee established pursuant to resolution 1988 (2011) enacted the amendments specified with strikethrough and/or underline in the entries below on its 1988 List of individuals and entities subject to the assets freeze, travel ban and arms embargo set out in paragraph 1 of Security Council resolution 2816 (2026), and adopted under Chapter VII of the Charter of the United Nations.
A. Individuals
TAi.044 Name: 1: HAMDULLAH 2: NOMANI 3: na 4: na Name (original script): حمد الله نعمانى Title: Maulavi Designation: a) Minister of Higher Education under the Taliban regime (1996-2001)b) Mayor of Kabul City under the Taliban regime (1996-2001) DOB: a) Approximately 1968 b) 28 Aug. 1965 POB: a)Sipayaw village, Andar District, Ghazni Province, Afghanistan b) Ghazni, Afghanistan Good quality a.k.a.: HAMDULLAH NUMANI Low quality a.k.a.: naNationality: Afghanistan Passport no: Afghanistan number D0010694, issued on 7 Apr. 2026, issued in Kabul, Afghanistan, expires 7 Apr. 2031 (Name in Latin script: HAMDULLAH NUMANI) National identification no: na Address: na Kabul, Afghanistan Listed on: 23 Feb. 2001 ( amended on 3 Sep. 2003, 21 Sep. 2007, 3 Oct. 2008, 29 Nov. 2011, 28 Apr. 2026, 30 Jul. 2026) Other information: Member of the Taliban Supreme Council. Believed to be in Afghanistan/Pakistan border area. Height 174 cm. Review pursuant to Security Council resolution 1822 (2008) was concluded on 23 Jul. 2010. Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals#2006-25939.
TAi.082 Name: 1: ABDUL-HAQ 2: WASSIQ 3: na 4: na Name (original script): عبد الحق وثيق Title: Maulavi Designation: Deputy Minister of Security (Intelligence) under the Taliban regime (1996-2001) DOB: a) 1971 b) Approximately 1975 c) 20 Sep. 1968 POB: a)Gharib village, Khogyani District, Ghazni Province, Afghanistan b) Ghazni, Afghanistan Good quality a.k.a.: a) Abdul-Haq Wasseqb) Abdul Haq Wasiq c) ABDULHAQ WASEEQ Low quality a.k.a.: na Nationality: Afghanistan Passport no: a)Afghanistan number D0009755, issued on 23 Oct. 2021, expires 23 Oct. 2026 (Name in Latin script: Abdulhaq Waseeq) b) Afghanistan number D0010689, issued on 29 Mar. 2026, expires 29 Mar. 2031 (Name in Latin script: Abdulhaq Waseeq, name in original script: عبد الحق وثيق) National identification no: na Address: Afghanistan Listed on: 31 Jan. 2001 ( amended on 3 Sep. 2003, 21 Sep. 2007, 3 Oct. 2008, 29 Nov. 2011, 31 Dec. 2013, 11 Feb. 2014, 7 Sep. 2016, 10 Mar. 2026, 28 Apr. 2026, 30 Jul. 2026) Other information: Height 168 cm. Review pursuant to Security Council resolution 1822 (2008) was concluded on 27 Jul. 2010. Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals#2006-25979.
TAi.110 Name: 1: NOOR MOHAMMAD 2: SAQIB 3: na 4: na Name (original script): نور محمد ثاقب Title: na Designation: Chief Justice of Supreme Court under the Taliban regime (1996-2001) DOB: a) Approximately 1958 b) 18 Sep. 1963 c) 19 Oct. 1962 POB: a) Bagrami District, Kabul Province, Afghanistan b) Tarakhel area, Deh Sabz District, Kabul Province, Afghanistan c) Kabul, AfghanistanGood quality a.k.a.: NOOR MOHAMMED SAQEB (name in original script: نور محمد ثاقب) Low quality a.k.a.: na Nationality: Afghanistan Passport no: a)Afghanistan number D0009914, issued on 10 May 2022, issued in Afghanistan, expires 10 May 2027 (Name in Latin script: Noor Mohammed Saqeb; name original script: نورمحمد ثاقب) b) Afghanistan number P09305451, issued on 29 April 2025, issued in Kabul, Afghanistan, expires 29 Apr. 2030, (DOB 19 Oct. 1962 180 cm Name in Latin script: Noor Mohammed Saqeb; name original script: نورمحمد ثاقب) National identification no: na 544311Address: Kabul, Afghanistan Listed on: 25 Jan. 2001 ( amended on 3 Sep. 2003, 21 Sep. 2007, 29 Nov. 2011, 10 Mar. 2026, 28 Apr. 2026, 30 Jul. 2026) Other information: Member of Taliban Supreme Council and Head of Taliban Religious Committee. Belongs to Ahmadzai tribe. Height 175 cm or 180 cm.Review pursuant to Security Council resolution 1822 (2008) was concluded on 23 Jul. 2010. Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals#2006-26129.
TAi.144 Name: 1: SIRAJUDDIN 2: JALLALOUDINE 3: HAQQANI 4: na Name (original script): سراج الدين جلال الدين حقانى Title: na Designation: Na’ib Amir (Deputy Commander) (1996-2001) DOB: a) Between 1977 and 1978 (Approximately) b) 30 Dec. 1981 POB: a) Danda, Miramshah, North Waziristan, Pakistan b) Khost province, Afghanistan c) Neka district, Paktika province, Afghanistan d) Srana village, Garda Saray district, Paktia province, Afghanistan e) Paktia, Afghanistan Good quality a.k.a.: a) Siraj Haqqanib) Serajuddin Haqani c) Siraj Haqani d) Saraj Haqani e) ABDUL SATAR ABDULLAH Low quality a.k.a.: Khalifa Nationality: Afghanistan Passport no: a) Afghanistan number P00032260, issued on 30 Jun. 2022, issued in Kabul, Afghanistan, expires 30 Jun. 2032 (Name in Latin script: Abdul Satar Abdullah) b) Afghanistan number D0010367, issued on 18 May 2024, issued in Kabul, Afghanistan, expires 18 May 2029 (Name in Latin script: Sirajuddin Haqqani) c) Afghanistan number P05076602, issued on 5 May 2026, expires 5 May 2036 National identification no: na Address: Kabul, Afghanistan Listed on: 13 Sep. 2007 ( amended on 22 Apr. 2013, 10 Mar. 2026, 28 Apr. 2026, 30 Jul. 2026) Other information: Heading the Haqqani Network (TAe.012) as of late 2012. Son of Jalaluddin Haqqani (TAi.040). Belongs to Sultan Khel section, Zadran tribe of Garda Saray of Paktia province, Afghanistan. Height 187 cm or 180cm.Review pursuant to Security Council resolution 1822 (2008) was concluded on 27 Jul. 2010. Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals#2007-44300.
TAi.147 Name: 1: GUL 2: AGHA 3: ISHAKZAI 4: na Name (original script): كُل آغا اسحاقزی Title: na Designation: na DOB: a) Approximately 1972 b) 27 Jul. 1976 POB: Band-e Temur, Maiwand District, Kandahar Province, Afghanistan Good quality a.k.a.: a) Mullah Gul Agha b) Mullah Gul Agha Akhund c) HIDAYATULLAH BADRI d) HEDAYATULLAH HEDAYAT e) HEDAYATULLAH BADRI (name in original script: هدایت الله بدري) Low quality a.k.a.: a) Hidayatullah b) Haji Hidayatullah c) HayadatullahNationality: Afghanistan Passport no: a) Afghanistan number D0010408, issued on 26 Aug. 2024, issued in Kabul, Afghanistan (Name in Latin script: Hedayatullah Badri; name in original script: هدایت الله بدري; expires 26 Aug. 2029) b) Afghanistan number P03318995, issued on 29 Jul. 2020 (Name in Latin script: Hedayatullah Hedayat, expires 29 Jul. 2025) c) Afghanistan number D0010006, issued on 28 Sep. 2022, issued in Kabul, Afghanistan (expires 28 Sep. 2027) National identification no: naAddress: Ibni-Sina Watt, Kabul, Afghanistan Listed on: 20 Jul. 2010 ( amended on 29 Nov. 2011, 31 Dec. 2013, 10 Mar. 2026, 13 Apr. 2026, 30 Jul. 2026 ) Other information: Head of Taliban Financial Commission as at mid-2013. Associated with Mullah Mohammed Omar (TAi.004). Served as Omar’s principal finance officer and one of his closest advisors. Belongs to Ishaqzai tribe. Height: 156 cm. Photo available for inclusion in the INTERPOL-UN Security Council Special Notice. INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals.
The 1988 Sanctions List is updated regularly on the basis of relevant information provided by Member States and international and regional organizations. An updated List is accessible on the 1988 Sanctions Committee’s website at the following URL: https://main.un.org/securitycouncil/en/sanctions/1988/materials.
On July 30, 2026, the UN Security Council Taliban Sanctions Committee amended five names on its sanctions list. For more information, consult the Press Release.
let’s go back to Scenario A: there has to be, in order to effectuate the instruction, an account relationship of some kind, doesn’t there? So why is that case different? You’ve got assets being allocated for a sanctioned party – the only difference is that, in Scenario A, it’s being taken from an existing pooled asset. Or am I missing something?
Claude responded:
You’re not missing something, and it’s a sharp catch — there genuinely is an “account relationship” and something IS being drawn from a pooled asset. But the question is whether that operational fact amounts to a legal interest for the designated person, and here payment law itself already draws the line you’re looking for, independent of sanctions law entirely.
A wire transfer isn’t one asset moving through a pipe — it’s a chain of separate obligations
Under the commercial law that actually governs funds transfers (UCC Article 4A in the US; the EU’s Settlement Finality Directive and the payment-services framework in Europe), a beneficiary acquires zero legal claim against their own bank until that bank “accepts” the payment order — the beneficiary’s bank is only obliged to pay the beneficiary once it accepts the order, and acceptance itself is defined narrowly: the earliest of the bank paying the beneficiary, notifying them of receipt, or receiving settlement for the order. Before that moment, nothing has legally reached the beneficiary — the money belongs to the recipient, free of any strings, only once finality is reached. This isn’t a sanctions-specific fiction. It’s the ordinary rule that governs every wire transfer on earth, sanctions or not — it’s what determines, say, whose money it is if a bank fails mid-transfer, or if a payment gets mis-keyed to the wrong account.
So what is actually happening at your end when you debit Customer A?
Bank A debiting Customer A’s account and sending a payment message isn’t Bank A moving the designated person’s property — it’s Bank A discharging (or beginning to discharge) its own contractual obligation to Customer A, funded out of Bank A’s own balance sheet and correspondent liquidity. That pooled asset is Bank A’s, being drawn down pursuant to A’s instruction; the designated person is a total stranger to that relationship until their own bank actually accepts the order on their behalf. If you refuse at that point, nothing reverses because nothing left — Customer A’s account was never debited (or is simply uncredited if it briefly was), and there’s no moment where the designated person held anything that now has to be “returned.” That’s precisely why refusal doesn’t require a licence the way unwinding a completed freeze does: there’s nothing to unwind.
Why “belonging to/held/controlled by” tracks this, and why OFAC doesn’t
The EU-family test (belonging to, owned, held, or controlled by) is simply importing the ordinary payment-law vesting point rather than inventing its own. OFAC’s blocking regime is the outlier specifically because its “interest of any nature whatsoever, direct or indirect” definition is deliberately written to reach behind that ordinary vesting rule — US commercial law (the same UCC 4A) agrees with the EU-family approach that the beneficiary has no claim pre-acceptance, but OFAC’s sanctions regulations override that for blocking purposes, treating mere intended-beneficiary status as sufficient. So the divergence being described here isn’t a difference in what property law says happens to a payment in flight — both systems’ underlying commercial law agrees on that. It’s that only one of them layers a sanctions-specific rule on top that disregards it.
This also explains the countermand test from the UK “trapped payments” guidance covered previously — asking whether a designated bank still had the right to recall the funds is just asking whether finality/irrevocability had occurred yet. Same doctrinal line, applied to figure out whether the freeze duty travels with the money through a correspondent chain. And it’s why an intermediary bank in the EU-family model typically has nothing of the designated person’s to freeze mid-chain at all: under this same logic, none of the intervening correspondent legs constitute the beneficiary holding anything either, right up until the final beneficiary’s bank accepts.
One thing worth keeping separate: this settles whether the Scenario A/B line is legally real rather than cosmetic — it doesn’t reopen the policy question of whether refuse is a strong enough response on its own. Those are different questions.
The following individual has been added to OFAC’s SDN List:
OFAC Programs:
SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
IFSR Iranian Financial Sanctions Regulations, 31 CFR part 561
TANG, Xin
AKA: “TANG, Mike”
Address: China
DOB: 16 Dec 1969
Nationality: China
Gender: Male
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
National ID No.: 110105196912164113 (China)
Party Type: Individual
Linked to: MAHAN AIR
Supplemental Information: Per Treasury, Tang Xin is the managing director of Shanghai Wings International Logistics Co, having coordinated travel for Mahan Air, and is also the executive director and 50 percent owner of Shanghai Elite International Travel Co, another Mahan Air representative in China. Mahan Air, sanctioned by both the United States and the European Union, has long served as the IRGC’s airline of choice despite presenting itself as a civilian carrier, providing travel services for IRGC-Qods Force personnel and supporting Iran’s procurement and transport of UAV systems and weapons. OFAC first designated Mahan Air under E.O. 13224 in October 2011 for supporting the IRGC-Qods Force, which OFAC had designated in October 2007; the IRGC itself was designated by State under E.O. 13382 in 2007 and by OFAC under E.O. 13224 in October 2017. Tang Xin is designated for providing material or technological support to Mahan Air.
The following entities have been added to OFAC’s SDN List:
OFAC Programs:
SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
IFSR Iranian Financial Sanctions Regulations, 31 CFR part 561
AIR CARGO PRO LIMITED
AKA:
AIRCARGOPRO LTD
LIMITED LIABILITY COMPANY AIRCARGOPRO
Address: Moscow, Russia
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
Organization Established Date: 26 May 2010
Tax ID No.: 5047116112 (Russia)
Linked to: MAHAN AIR
Supplemental Information: Per Treasury, Air Cargo Pro Limited serves as Mahan Air’s general sales agent in Russia, handling sales and customer support and liaising with freight forwarders and shippers on the airline’s behalf. It is designated for materially supporting Mahan Air.
SHANGHAI ELITE INTERNATIONAL TRAVEL CO LTD (Chinese Simplified: 上海马汉国际旅行社有限公司)
AKA: SHANGHAI MAHAN INTERNATIONAL TRAVEL SERVICE COMPANY LTD
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
Organization Established Date: 24 Feb 2014
Tax ID No.: 310104087826111 (China)
Registration Number: 310104000567670 (China)
Unified Social Credit Code (USCC): 913101040878261110 (China)
Linked to: TANG, Xin
Supplemental Information: Per Treasury, Shanghai Elite International Travel Co Ltd (also doing business as Shanghai Mahan International Travel Service Company Ltd) represents Mahan Air in China. It is majority-owned and directed by Tang Xin, who holds a 50 percent stake and serves as its executive director, and is designated for being owned, controlled, or directed by him.
SHANGHAI WINGS INTERNATIONAL LOGISTICS CO (Chinese Simplified: 上海翼上国际货运有限公司)
AKA:
SHANGHAI WINGS INTERNATIONAL FREIGHT CO LTD
SHANGHAI YISHANG INTERNATIONAL FREIGHT CO LTD
Address:
Shenzhen, Guangdong, China
Room 172, Building A, No. 888, Huanhu West, 2nd Road, Lingang New Area, Pilot Free Trade Zone, Shanghai 200120, China
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
Organization Established Date: 15 Jan 2021
Trade License No.: 310142000159721 (China)
Unified Social Credit Code (USCC): 91310000MA1H3GWY6C (China)
Linked to: MAHAN AIR
Supplemental Information: Per Treasury, Shanghai Wings International Logistics Co serves as a general sales agent for Mahan Air and has coordinated the transport of electronics from China to Iran. Its managing director, Tang Xin, has also coordinated travel arrangements for Mahan Air. It is designated for materially supporting Mahan Air.
SKIEZ TRAVELS AND LOGISTICS PRIVATE LIMITED
AKA:
SKIEZ TRAVELS AND LOGISTICS PVT LTD
“SKIEZ TRAVEL”
Address:
Srinagar, Jammu and Kashmir 190001, India
A-287, Second Floor, Defence Colony, New Delhi, Delhi, India
Supplemental Information: Per Treasury, Skiez Travels and Logistics Private Limited serves as Mahan Air’s general sales agent in India. It is designated for materially supporting Mahan Air.
OFAC Program: SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
DADENEGAR STARTUP STUDIO
Address:
Fereydounkhani Street, South Dibaji, Tehran, Iran
Heravi Hossein Abad, Tehran, Iran
6743 W 75th St, Al Fallujah, Al Anbar Governate 31002, Iraq
Supplemental Information: Per State and Treasury, DadeNegar Startup Studio is an IRGC-affiliated front company that used a website to solicit the locations of American and Israeli military equipment in the Middle East in support of Iranian military targeting; in coordination with the IRGC, it received strike requests against U.S. targets in the region. It is designated for materially supporting the IRGC.
Amendments:
The following changes have been made to OFAC’s SDN List:
OFAC Programs:
NPWMD Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544
IFSR Iranian Financial Sanctions Regulations, 31 CFR part 561
DURANSOY, Cagri
Address: Turkey
DOB: 04 Aug 1985
POB: Kadikoy, Turkey
Nationality: Turkey
Additional Sanctions Information: Subject to Secondary Sanctions
By refusing or rejecting a transaction, isn’t the regulator copping out? After all, the transaction could be accomplished somewhere else – say, in China or Turkey
Claude responded:
It’s a fair gut reaction, but it conflates two different questions: “does this stop the sanctioned party from ever getting the money” and “what happens to the specific transaction sitting in front of this specific firm.” Those aren’t the same question, and once you separate them, block doesn’t actually beat reject on the first one.
The workaround problem is real, but it’s not a reject-specific problem
If a UK bank refuses to send the payment, sure, the customer can try Beijing, Istanbul, or Dubai. But if a US bank blocks the payment instead, the designated person’s next attempt at financing can just as easily route through those same channels — blocking one wire doesn’t inoculate the rest of their commercial life. This is a well documented, general limitation of unilateral and even coordinated multilateral sanctions: research on sanctions evasion has tracked how Chinese and Russian arms have continued flowing to embargoed destinations for decades through non-dollar channels that sit outside any single regime’s reach. So “they’ll just go elsewhere” is a real critique of sanctions regimes in general — it applies to block just as much as reject. Neither mechanism solves global circumvention; both only capture what happens to already be within a given firm’s grasp at a given moment.
So is releasing that specific transaction really nothing?
Not quite. A rejected payment still comes with a mandatory report to the competent authority in every jurisdiction covered so far — so even though the money moves on, the attempt gets logged: who tried to pay whom, through which counterparties, on what pretext. That’s raw material for future listings, for identifying facilitators, and for building the kind of evidentiary record these regimes’ own courts increasingly demand. It’s a much thinner form of “action” than seizing the money, and it isn’t honest to pretend otherwise — but it isn’t nothing either.
The real reason isn’t laziness, it’s legal exposure
Here’s the part that actually answers the question. The EU, UK, Switzerland, Canada, and Australia are all legal systems where courts have been genuinely aggressive about policing sanctions listings on due-process and property-rights grounds — and the cleanest illustration is that the same person, Mr. Kadi, brought parallel challenges in EU and US courts over the same asset freeze, and the EU courts ruled the listing process lacked fundamental protections while the US courts rejected the equivalent constitutional claims. If that’s how exacting these courts are about freezing a person who has actually been designated, extending that seizure power further — to a non-designated customer’s own money, based solely on their stated intent to pay someone else — would be a considerably bigger and more legally exposed step, one these systems have chosen not to take. The US, operating under IEEPA’s far more executive-deferential tradition, doesn’t face the same internal constraint, which is a large part of why it’s comfortable blocking property whose ownership hasn’t fully vested yet.
There’s a structural reason layered on top of the legal one. The US can afford to cast that wide a net because so much of world trade has no way to avoid touching dollar clearing — roughly 88 percent of foreign-exchange transactions involve the dollar, and the correspondent banking system that actually moves the money concentrates through a small number of banks in New York and London. Blocking a dollar payment captures real marginal value precisely because rerouting around the dollar is genuinely hard. A rejected euro, pound, franc, Canadian, or Australian dollar payment is comparatively easy to complete elsewhere without touching that currency’s clearing system at all, so the deterrent value of seizing a non-designated customer’s funds is lower relative to the legal and political cost of doing it — this half of the explanation is an original synthesis of the two facts above, not something any regulator has stated as its rationale.
And this isn’t a “the EU goes soft” story — the freeze side still bites, hard
Worth remembering: none of this caution applies once a resource actually belongs to the designated party. The clearest proof is sitting in Belgium right now — roughly €210 billion of Russian Central Bank reserves are frozen in Europe, most of it at the Euroclear depository, and that’s a Scenario B freeze, not a reject outcome, because those securities already belonged to the CBR the moment it was designated. And the EU’s own hesitation about going one step further — from freezing that money to actually using it for a reparations loan — is itself a live demonstration of the exact caution just described: Belgium has resisted precisely on expropriation grounds, warning other reserve holders might flee European custody, and Russia’s central bank has already sued Euroclear for roughly $230 billion over the freeze itself. That’s not a regime being casual about property rights; if anything it’s the same instinct that keeps the reject rule in place for in-flight payments, now playing out at nation-state scale.
Self-check
Kadi I/II outcomes and the EU/US divergence: confirmed across multiple sources including a direct comparison piece and the CJEU’s own case summary.
Dollar/FX and correspondent-concentration figures: from a 2026 explainer drawing on the Farrell & Newman “weaponized interdependence” literature — solid secondary sourcing, not a primary BIS/Fed data pull.
Euroclear/CBR figures (~€210bn, ~€193bn at Euroclear, Belgium’s objections, the Russian lawsuit): converging figures across CFR, CEPR, Squire Patton Boggs, and AP reporting from November 2025–January 2026 — figures move slightly by source and date, so treat the exact number as “roughly €200–210bn” rather than a fixed figure if publishing this.
The causal argument connecting legal-rights culture and dollar centrality to the reject/block design choice is original synthesis — no regulator has published that rationale in those terms.
The following entities have been added to OFAC’s SDN List:
OFAC Program: IRAN-EO13902 Executive Order 13902
BILLION NEXUS INT’L CO., LIMITED
AKA: BILLION NEXUS INT’L CO LTD
Address: Unit 60, 3rd Floor, Yau Lee Centre, 45, Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong, China
Organization Established Date: 22 Jul 2025
Identification Number: IMO 0306224
Business Registration Number: 78498463 (Hong Kong)
Supplemental Information: Billion Nexus Int’l Co., Limited, based in Hong Kong, owns and operates the crude oil tanker AL SALMI, which has moved hundreds of thousands of barrels of Iranian oil to China since 2025. It is one of eight companies designated today for operating in Iran’s petroleum sector, part of a broader campaign that has now covered more than 100 vessels linked to Iran’s shadow fleet since the start of the year.
BRANCH SAYING INTERNATIONAL TRADING CO LTD
Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
Organization Established Date: 10 Sep 2025
Identification Number: IMO 0359778
Business Registration Number: 133779 (Marshall Islands)
Supplemental Information: Branch Saying International Trading Co Ltd, based in the Marshall Islands, owns the crude oil tanker YEHOPE, which has carried hundreds of thousands of barrels of Iranian crude to China in 2026. It is designated for operating in Iran’s petroleum sector.
Address: Room D, 10th Floor, Tower A Billion Centre, 1, Wang Kwong Road, Kowloon Bay, Kowloon, Hong Kong, China
Organization Established Date: 31 Dec 2024
Identification Number: IMO 0123299
Business Registration Number: 77537070 (Hong Kong)
Supplemental Information: Confident Apex Limited, based in Hong Kong, owns and operates the crude oil tanker LILY (also known by the name “DANYA”), which has carried millions of barrels of Iranian oil since 2025. It is designated for operating in Iran’s petroleum sector.
Additional Sanctions Information: Subject to Secondary Sanctions
Organization Established Date: 2026
Organization Type: Financial and Insurance Activities
Supplemental Information: Per Treasury and State, HormuzSafe (also marketed as Hormuz Safe) is an Iranian digital insurance venture developed by Iran’s Ministry of Economy that advertises maritime services – insurance, traffic control, security, and emergency response – to vessels transiting the Strait of Hormuz. It accepts Bitcoin and other digital-asset payments as part of the regime’s efforts to route around Western sanctions, and was promoted to social media followers by previously sanctioned regime financier Babak Morteza Zanjani. Along with the Persian Gulf Marine Insurance Company, HormuzSafe brokers IRGC-approved policies covering risks – chiefly vessel seizure – that Iran itself largely manufactures, generating revenue for IRGC operations. It is designated for operating in the financial sector of the Iranian economy.
MARINOVA FREIGHT LIMITED
Address: Room 310 3/F, Stag Building, 148-150 Queen’s Road Central, Hong Kong, China
Organization Established Date: 26 Mar 2026
Identification Number: IMO 0451967
Business Registration Number: 80062070 (Hong Kong)
Supplemental Information: Marinova Freight Limited, based in Hong Kong, owns, operates, and manages the crude oil tanker NATSUMI, which has carried millions of barrels of Iranian crude to China since 2022. It is designated for operating in Iran’s petroleum sector.
NEVADA SPIRIT COMPANY LIMITED
AKA: NEVADA SPIRIT CO LTD
Address: Rm 8 15/F Witty Coml Bldg, 1A-1L Tung Choi St, Mongkok, Kowloon, Hong Kong, China
Organization Established Date: 05 May 2022
Identification Number: IMO 6326461
Business Registration Number: 74012178 (Hong Kong)
Supplemental Information: Nevada Spirit Company Limited, based in Hong Kong, owns and operates the crude oil tanker BREEZE V, which has carried millions of barrels of Iranian oil to China in 2026. It is designated for operating in Iran’s petroleum sector.
OCEAN TRANQUILITY LIMITED
Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
Organization Established Date: 18 Feb 2022
Identification Number: IMO 6357680
Business Registration Number: 113191 (Marshall Islands)
Supplemental Information: Ocean Tranquility Limited, based in the Marshall Islands, owns, operates, and manages the crude oil tanker NIRETA, which has carried hundreds of thousands of barrels of Iranian crude to China in 2026. It is designated for operating in Iran’s petroleum sector.
PERSIAN GULF MARINE INSURANCE COMPANY (Arabic: شركة تأمین الخلیج الفارسي البحري)
Address: Iran
Additional Sanctions Information: Subject to Secondary Sanctions
Organization Established Date: 2026
Organization Type: Financial and Insurance Activities
Supplemental Information: Per Treasury, the Persian Gulf Marine Insurance Company (PGMIC) was established by the Central Insurance of the Islamic Republic of Iran, the country’s primary insurance regulator. PGMIC brokers and issues policies approved by the Persian Gulf Strait Authority (PGSA), an IRGC-backed body Treasury designated on May 27, 2026 pursuant to E.O. 13224, as amended, for materially supporting the IRGC. PGMIC’s coverage addresses risks – most notably vessel seizure – that are largely of Iran’s own making, generating revenue that helps fund the regime’s terror and corruption. It is designated for operating in the financial sector of the Iranian economy.
QI HANG SHIP MANAGEMENT LIMITED (Chinese Traditional: 啟航船舶管理有限公司)
Address:
Room D, 16th Floor, China Merchants Tower, 1008, Wanghai Lu, Nanshan Qu, Shenzhen, Guangdong, China
Rm 30 3/F East Sun Indl Ctr Blk A, 16 Shing Yip St, Kwun Tong, Kowloon, Hong Kong, China
Organization Established Date: 29 Jul 2025
Identification Number: IMO 0301550
Business Registration Number: 78537348 (Hong Kong)
Supplemental Information: Qi Hang Ship Management Limited, based in China and Hong Kong, owns, operates, and manages the chemical/products tanker WELL SAIL, which has carried hundreds of thousands of barrels of Iranian petroleum products to the United Arab Emirates in 2026. It is designated for operating in Iran’s petroleum sector.
VAST MIGHTY LIMITED
Address:
12th Floor, Fu Cheong Centre 5-7, Wong Chuk Yeung Street, Fo Tan, Sha Tin, New Territories, Hong Kong, China
Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
Organization Established Date: 30 Sep 2022
Alt. Organization Established Date: 06 Jul 2023
Identification Number: IMO 0024761
Business Registration Number: 120802 (Marshall Islands)
Registration Number: 74471259 (Hong Kong)
Supplemental Information: Vast Mighty Limited, based in Hong Kong and the Marshall Islands, owns, operates, and manages the crude oil tanker CRYSTAL, which has carried millions of barrels of Iranian crude to China in 2026. It is designated for operating in Iran’s petroleum sector.
The following vessels have been added to OFAC’s SDN List:
OFAC Program: IRAN-EO13902 Executive Order 13902
AL SALMI
Vessel Type: Crude Oil Tanker
Vessel Flag: Unknown
Former Vessel Flag: Panama
Vessel Year of Build: 2005
Vessel Registration Identification: IMO 9298296
Party Type: Vessel
Linked to: BILLION NEXUS INT’L CO., LIMITED
Supplemental Information: Per Treasury, AL SALMI has transported hundreds of thousands of barrels of Iranian oil to China since 2025.
BREEZE V (8P2249)
Vessel Type: Crude Oil Tanker
Vessel Flag: Barbados
Vessel Year of Build: 2003
Vessel Registration Identification: IMO 9259355
MMSI: 314887000
Party Type: Vessel
Linked to: NEVADA SPIRIT COMPANY LIMITED
Supplemental Information: Per Treasury, BREEZE V has transported millions of barrels of Iranian oil to China in 2026.
CRYSTAL (YJRP6)
Vessel Type: Crude Oil Tanker
Vessel Flag: Vanuatu
Vessel Year of Build: 2002
Vessel Registration Identification: IMO 9223887
MMSI: 577706000
Party Type: Vessel
Linked to: VAST MIGHTY LIMITED
Supplemental Information: Per Treasury, CRYSTAL has transported millions of barrels of Iranian crude oil to China in 2026.
LILY (3EVK3)
AKA: “DANYA”
Vessel Type: Crude Oil Tanker
Vessel Flag: Mozambique
Former Vessel Flag: Panama
Vessel Year of Build: 2005
Vessel Registration Identification: IMO 9294331
MMSI: 353502000
Party Type: Vessel
Linked to: CONFIDENT APEX LIMITED
Supplemental Information: Per Treasury, LILY has transported millions of barrels of Iranian oil since 2025.
NATSUMI (8PTM)
Vessel Type: Crude Oil Tanker
Vessel Flag: Barbados
Vessel Year of Build: 2006
Vessel Registration Identification: IMO 9331244
MMSI: 314231000
Party Type: Vessel
Linked to: MARINOVA FREIGHT LIMITED
Supplemental Information: Per Treasury, NATSUMI has transported millions of barrels of Iranian crude oil to China since 2022.
NIRETA (YJRR9)
Vessel Type: Crude Oil Tanker
Vessel Flag: Vanuatu
Vessel Year of Build: 2003
Vessel Registration Identification: IMO 9237785
MMSI: 577715000
Party Type: Vessel
Linked to: OCEAN TRANQUILITY LIMITED
Supplemental Information: Per Treasury, NIRETA has transported hundreds of thousands of barrels of Iranian crude oil to China in 2026.
WELL SAIL (V7A4071)
Vessel Type: Chemical/Products Tanker
Vessel Flag: Marshall Islands
Vessel Year of Build: 2007
Vessel Registration Identification: IMO 9321938
MMSI: 538012177
Party Type: Vessel
Linked to: QI HANG SHIP MANAGEMENT LIMITED
Supplemental Information: Per Treasury, WELL SAIL has transported hundreds of thousands of barrels of Iranian petroleum products to the United Arab Emirates in 2026.
YEHOPE (8PPX)
Vessel Type: Crude Oil Tanker
Vessel Flag: Barbados
Vessel Year of Build: 2003
Vessel Registration Identification: IMO 9243320
MMSI: 314001154
Party Type: Vessel
Linked to: BRANCH SAYING INTERNATIONAL TRADING CO LTD
Supplemental Information: Per Treasury, YEHOPE has transported hundreds of thousands of barrels of Iranian crude oil to China in 2026.
ok… let’s open the aperture a bit. Explain what a compliant firm is supposed to do, for the US, UK, EU, Canada, Australia and Switzerland, in the following 2 scenarios – assuming we’re talking blocking/freezing sanctions only: Scenario A: You receive instructions to make a payment that involved a sanctioned party. Scenario B: You receive funds that involve a sanctioned party. For each scenario, also denote whether the answer is different in the case you are the beneficiary bank or an intermediary bank. Phrase this for a sanctions novice, but feel free to quote text (not full regulatory sections) – like “make economic resources available”, for example. Assume that my goal is to eventually, once I refine the response, make a “Burning Questions” post out of this
Claude responded:
This is exactly the kind of question that makes a good Burning Questions piece, because the honest answer isn’t “six jurisdictions, six rules” — it’s one rule almost everyone agrees on, and one narrow but consequential place where the US breaks from the rest.
Two moves, and two roles, defined simply
A compliant firm facing a sanctioned party has two different levers available, and confusing them is the single most common mistake:
Freeze/block: take the resource into your own custody, lock it away from everyone — including the customer who originally owned it — and report it. Nobody gets it until a regulator says otherwise.
Refuse/reject: simply decline to carry out the instruction. The money never leaves the paying customer’s account, so there’s nothing to freeze.
And two roles matter for how this plays out:
Beneficiary bank: the bank holding the account of the person or entity who’s supposed to end up with the money.
Intermediary (correspondent) bank: a bank in the middle of the chain, routing the payment onward, with no account relationship to either the sender or the ultimate recipient.
Scenario A: you receive instructions to make a payment that involves a sanctioned party
Picture a customer who isn’t sanctioned asking you to send money to someone who is.
Jurisdiction
What you do
Beneficiary vs. intermediary bank
US (OFAC)
Block. Take the funds into a blocked, interest-bearing account. Don’t send them, and don’t hand them back to the customer either.
No difference in principle — blocking applies regardless of whether it is the originating or intermediary bank in the chain. A purely blind intermediary with no account relationship to a non-listed related party gets a narrow pass on investigating what it has no way of knowing, but the moment it knows or should know a designated person is involved, it blocks too.
UK (OFSI)
Refuse. Don’t execute the payment; the customer’s own funds are untouched.
Same principle for any bank in the chain — but correspondent banks caught mid-chain have created a genuine practical headache here (see below).
EU
Refuse — going ahead would mean making economic resources available to the designated person, which every EU regulation prohibits directly or indirectly.
Same in principle for whoever in the chain is asked to move the money.
Switzerland (SECO)
Refuse, for the same reason — Swiss ordinances closely mirror the EU wording, prohibiting third parties from making economic resources available to a listed person.
Same in principle.
Canada
Refuse — completing the payment would breach the ban on making any goods available to a designated person, or providing services to their benefit.
Same in principle, though published Canadian guidance addressing intermediary banks specifically the way the US and UK have could not be located.
Australia (DFAT/ASO)
Refuse — a person commits an offence if they make assets available to a designated person or entity.
Same in principle.
The one country that flips the answer is the US, and it’s worth pausing on why. OFAC treats a designated person’s status as intended beneficiary of a payment as itself an “interest” in the funds, so the moment the firm has possession or control of the money for the purpose of sending it their way, it’s already blockable property — even though it started out as the customer’s own money and never actually reached anyone. Everyone else in this table requires the resource to actually belong to, or be held or controlled by, the designated person before the freeze duty exists — and a payment instruction that hasn’t been executed yet doesn’t meet that bar. So the divergence isn’t really about freeze versus reject as competing philosophies; it’s about how early each regime decides a sanctioned party has acquired an interest in money that hasn’t arrived yet.
Scenario B: you receive funds that involve a sanctioned party
Now flip it: money has actually arrived, or is already sitting in an account, where a designated person has a real, present interest — as the account holder, or as the completed beneficiary of an inbound transfer.
Jurisdiction
What you do
Beneficiary vs. intermediary bank
US (OFAC)
Block, and report within 10 business days.
No difference — whoever’s possession or control the funds come within, blocks, subject to the same narrow intermediary safe harbor as above.
UK (OFSI)
Freeze, and report.
The beneficiary bank freezes without question. An intermediary bank is generally fine to keep routing a payment onward provided the funds aren’t owned, held, or controlled by a designated person at the point it’s dealing with them — which gets complicated fast if a designated bank sat somewhere upstream (see below).
EU
Freeze, and report to the national competent authority. Notably, a bank is explicitly permitted to credit an incoming third-party payment into a frozen account without needing prior authorization for that specific act — the funds simply join the frozen pool once they land.
Same logic as the UK: a true intermediary that never holds the designated person’s resources has nothing to freeze; a beneficiary bank freezes on receipt.
Switzerland
Freeze, and report to SECO.
Same principle as the EU.
Canada
Freeze (functionally, by disclosing the property to the RCMP and being barred from dealing with it) — firms must report property in their possession or control that is owned or controlled by designated persons and freeze such property.
Same principle, applied to whoever holds it.
Australia
Freeze, and notify the Australian Federal Police.
Same principle for whoever is holding the asset.
This is really the headline finding: on receipt, all six jurisdictions land in the same place. The freeze duty is nearly universal once a designated person actually has a stake in the resource — the interesting divergence lives entirely in Scenario A, where the US alone extends that duty backward to cover an unexecuted instruction.
Two wrinkles worth knowing for intermediary banks specifically
US: OFAC’s own guidance draws the safe-harbor line precisely. An intermediary bank with no account relationship to a non-listed party referenced in a wire, and no actual or constructive knowledge of a blocking issue, isn’t expected to go digging — but the instant it has information suggesting blocked status, the duty to block attaches regardless of its position in the chain.
UK: because the UK (unlike the EU generally) has designated entire banks, correspondent banks kept finding themselves holding payments that had passed through a now-designated bank somewhere upstream, with no clean way to either complete or return them — the industry calls these “trapped payments.” OFSI’s analysis turned on whether the designated bank still had a right of countermand over the funds at that point in the chain: if it had already discharged its role and lost any right to pull the funds back, the funds were no longer considered owned, held, or controlled by that designated bank, so the freeze duty didn’t travel downstream with it. That general licence has since been superseded by later amendments, so it’s an illustration of the reasoning rather than current operative guidance — worth pulling OFSI’s live Russia guidance before citing the mechanism itself.
EU: Regulation 36/2012 Article 14 template and the Council’s July 2024 Best Practices document, both previously verified.
UK: OFSI’s general guidance and reporting pages (gov.uk, ofsi.blog.gov.uk) plus the Trapped Payments general licence publication notice — flagged above as superseded, useful for the reasoning, not for current citation.
Canada: Global Affairs Canada’s own “Dealings prohibition and asset freeze” and disclosure pages — solid primary sourcing, but nothing found specific to intermediary-bank treatment; that’s a gap in published guidance, not a claim made by extension.
Australia: DFAT/Australian Sanctions Office guidance notes, all primary and current (2024–2025 dated).
Switzerland: sourced mainly through a Swiss press account describing the ordinance language rather than a direct ordinance or SECO FAQ pull — worth swapping in the exact ordinance article, and worth checking whether SECO’s FAQs address this reject/freeze point directly before publishing.
The “when does an interest attach” framing that ties the whole piece together is an original synthesis of the sourced material above, not a line any one source states outright.
On July 27, 2026, OFAC published its second round of list “modernization” housekeeping in as many months, this time touching the SDN List, the Sectoral Sanctions Identifications (SSI) List, and the Non-SDN Palestinian Legislative Council (NS-PLC) List. There are no new SDN designations in this update — it is entirely deletions, amendments, and one net-new addition (a consolidated Ismail Haniyah entry, discussed below). The accompanying Treasury press release is “Second Round of Sanctions Removals, Updates in Modernization Initiative.”
The throughline for the whole update is one OFAC has been chipping away at for a while: retiring the old convention of listing every known alias as its own free-standing, fully-detailed SDN entry, in favor of a single record with an AKA field. OFAC’s own framing: it has “consolidated 18 duplicate list entries in which a distinct target appears on OFAC’s sanctions lists multiple times.” The persons and property behind the deleted entries remain sanctioned; only the redundant entries are removed. The same dynamic shows up three times over in this update, at three different scales:
18 duplicate entries formally consolidated across the SDN, SSI, and NS-PLC Lists (chart below);
286 SDN deletions, a meaningful share of which are old-style per-alias duplicate listings for designees who remain sanctioned under a different, still-active entry;
19 SSI deletions that are simply old aliases of the 4 entities added to the SSI List in this same update; and
3 NS-PLC deletions that collapse into the 1 new, consolidated Ismail Haniyah entry.
Duplicate List Entry Consolidation
OFAC’s own chart, reproduced below: for each row, the “Deleted UID” entry was removed as a duplicate and the “Retained UID” entry is the one that survives (and, in four cases, was itself upgraded to a modern-format entry — see the SSI section below).
#
Name of Sanctioned Target Being Altered
Deleted UID
Retained UID
1
JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY ZAVOD IMENI PLANDINA
37526
47488
2
CSOFT DEVELOPMENT
48745
45766
3
JOINT STOCK COMPANY POLEMA
49463
49247
4
SPECIAL SYSTEMS PHOTONICS LIMITED LIABILITY COMPANY
Rows 15–18 are worth flagging up front: those four “retained” UIDs are the same four entities OFAC simultaneously re-added to the SSI List in modern, fully-detailed format (Cyrillic names, current addresses, tax IDs, directive determinations) — see the SSI section below. Rows 13–14 are a small, self-contained case: two different old-style deleted UIDs for the same person (ATIA, Hachim K.) both point to one retained UID.
Specially Designated Nationals List Updates
No additions. Two categories of change: 286 deletions and 37 amendments.
Deletions (286)
Every deleted entry carried exactly one program tag; the breakdown below is a complete count. As the consolidation chart above illustrates, a meaningful share of these are old-style, per-alias duplicate entries for designees who remain sanctioned under a separate, still-active SDN entry — deletion here does not mean the underlying person or entity is off the list, only that this particular free-standing record for one of their known names is gone. Two clusters stand out for a closer look if you work Iraq2 or counter-terrorism screening: the 42 IRAQ2 deletions are almost entirely Gulf War/Iraqi-sanctions-era shell and trading companies (many UK- and offshore-registered), and the SDGT/SOMALIA/SDNTK clusters below include long alias chains for a handful of underlying al-Shabaab, Sinaloa/Arellano Félix-era, and Golden Triangle-era designees.
[GLOMAG] — Executive Order 13818 (Global Magnitsky)
1
[IRAN-EO13846] — Executive Order 13846
1
Total
286
Full name list by tag:
[SDNTK] — 119 entries
Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598
“CHAYO”
“CHINO ANTRAX”
“CHOCLOS”
“EL CHAYO”
“EL DULCE”
“EL INDIO”
“EL MAS LOCO”
“EL MELLADO”
“EL MORENO”
“INGLATERRA”
“KIKE”
“LA CHIVA”
“LA COMADRE”
“LOCO”
“ORION”
“PAEZ Nachillo”
“PAEZ, Nacho”
“SAMUEL FLORES FLORES”
“TINO”
ADEMULERO, Babestan Oluwole
ADT PETROSERVICIOS
AFGHAN, Shear
AFGHAN, Sher
AFGHAN, Shir
ARECHIGA GAMBOA, Jose Rodrigo
ARELLANO FELIX, Ramon Eduardo
AZIZ, Mohammad
BABESTAN, Abeni O.
BABESTAN, Wole A.
CASTREJON PENA, Victor Nazario
CHAN, Changtrakul
CHANG, Chi Fu
CHANG, Ping Yun
CHANG, Shi-Fu
CHANG, Xifu
CHANGTRAKUL, Chan
COLORADO CESSA, Francisco Antonio
COMACHO RODRIGUES, Gilberto
FLORES BORREGO, Samuel
GALINDO MELLADO, Cruz
GARCIA ARBOLEDA, Edward
GIL, Josef
GILBERT, Joseph
GILBOA, Joseph
GILBOA, Joseph Papzian
GILBOA, Yosef
GONZALEZ GARZA, Rolando
GONZALEZ PIZANA JR., Rogelio
GONZALEZ PIZANA, Rogelio Kak, Jr.
HAMEIAH, Jamel
HAMEIAH, Jamil
HAMEIAH, Mamil
HAMEIEH, Jamil
HAMEIH, Jamill
HAMER, Jamil
HAMIAEH, Jamil
HAMIAH, Jamiel
HAMIE, Jamil
HAMIE, Jamil Abdulkarim
HAMIE, Jamile
HAMIEAH, Jamiel
HAMIEAH, Jamil
HAMIEH, Jamal
HAMIEH, Jamiel
HAMIEH, Jamil
HAMIEH, Mamil
HAMIEL, Jamil
HAMIEYE, Jamil
HAMIEYYEH, Jamil
HAMIL, Jamil
HAMIYA, Abdul Jamil
HAMIYE, Jamil
HAMIYYAH, Jamil
HAMIYYEH, Jamil
HAMYH, Jamil
HEATH, Noel Timothy
HERNANDEZ BARRON, Raul
HIGUERA GUERRERO, Ismael
INVERSIONES C.P.C.L. Y CIA. S. EN C.S.
KARIM, Jamil Abdul
KHAN, Abdullah
KHAN, Ali
KHAN, Nafir Ali
KHAN, Nasir Ali
KHAN, Nazir Ali
KHAN, Nisan Ali
KHAN, Nisar Ali
KHUN SA
KHUN, Saeng
LA TIENDA DE MINGO
MELLADO CRUZ, Galdino
MELLADO CRUZ, Galindo
MESA PAEZ, Aristides Manuel
MORENO GONZALEZ, Nazario
MORENO MADRIGAL, Nazario
MORENO, Chayo
MORENO, Jose
NASIR, Ali Khan
NASIR, Khan Ali
NAZIM, Abou
NEZAM, Abu
NIZAM, Abou
OGUNGBUYI, Abeni O.
OGUNGBUYI, Oluwole A.
OGUNGBUYI, Wally
OGUNGBUYI, Wole A.
PADIERNA PENA, Luis Orlando
PAEZ SOTO, Ramon Ignacio
PIZANA GONZALEZ, Rogelio
PLANCARTE SOLIS, Enrique
SHOFESO, Olatude I.
SHOFESO, Olatunde Irewole
SHOFESO, Olatutu Temitope
TORRES MENDEZ, Ramon
VALENZUELA VERDUGO, Jorge Mario
ZAMBA, Noel Heath
ZAMBO, Noel Heath
ZEVALLOS GONZALES, Ricardo
ZEVALLOS GONZALES, Winston Ricardo
[SDGT] — 52 entries
Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
“ABDALLA”
“ABDULLAH”
“ABU CHOLDER”
“ABU KHAOULA”
“ABU SOLAIMAN”
“ABU SOLAYMAN”
“AFADEY”
“AL-FATEH, Abu Hamzah”
“AL-INDONESI, Abu Walid”
“AL-INDUNISI, Abu-Walid”
“AL-LIBI, Shaykh Mahmud”
“AL-MALIZI, Abu Sayyaf”
“APONG SOLAIMAN”
“APUNG”
“MUHAMMAD, Muhammad”
“MUSSE”
“NUHR”
“SMAIL”
“SUDANI, Abdala”
ABD AL-RAHMAN, Atiyah
AL-LIBI, ‘Atiyah ‘Abd al-Rahman
AL-SHATIWI, Jamal
AL-SHITAYWI, Jamal Ibrahim Muhammad
AL-SHITIWI, Jamal
AL-SHTIWI, Jamal
AL-TURKI, Hassan
AL-TURKI, Hassan Abdullah Hersi
ATTO, Abdullah
BUR, Abdullah
DAWOUD, Muhammad
FAIZ, Mohammad Yusuf Karim
FAIZ, Mohammed Karim Yusop
FAIZ, Mohammed Yusop Karin
FAIZ, Mohd Karim Yusop
ISSA, Issa Osman
JEDI, Muhamad Wanndy Mohamad
JEDI, Muhamad Wanndy Muhamad
JEDI, Muhamad Wanndy bin Muhamad
JEDI, Muhammad Wanndy Bin Mohamed
MUZZAMIL, Mohammad Daoud
NUR, Mammam
NUR, Mohammad
NUR, Mohammed
NURA, Mohammed
NURU, Mallam Ahmed
SAIFUDDIN, Muhmmad
SALI JR., Jainal Antel
TUFAIL, Mohammed
TUFAIL, S.M.
TUFAIL, Sheik Mohammed
WANNDY, Muhamad
ZERFAOUI, Ahmad
[IRAQ2] — 42 entries
Executive Order 13315; Executive Order 13350
Note: “ATIA, Hachim K.” appears twice below — two separate old UIDs (8349 and 8350, per the consolidation chart above) for the same person, both retiring to retained UID 8348.
A.T.E. INTERNATIONAL LTD.
A.W.A. ENGINEERING LIMITED
ADMINCHECK LIMITED
ADVANCED ELECTRONICS DEVELOPMENT
AL PETRA COMPANY FOR GOODS TRANSPORT LTD
ARAB PETROLEUM ENGINEERING COMPANY LTD
ARCHI CENTRE I.C.E. LIMITED
ARCHICONSULT LIMITED
ASSOCIATED ENGINEERS
ATIA, Hachim K.
ATIA, Hachim K.
ATLAS AIR CONDITIONING COMPANY LIMITED
ATLAS EQUIPMENT COMPANY LIMITED
BAROON SHIPPING COMPANY LIMITED
ENDSHIRE EXPORT MARKETING
FALCON SYSTEMS
H & H METALFORM GMBH
H AND H METALFORM GMBH
I.P.C. INTERNATIONAL LIMITED
I.P.C. MARKETING LIMITED
INVESTACAST PRECISION CASTINGS
IRAQI ALLIED SERVICES LIMITED
IRAQI FREIGHT SERVICES LIMITED
IRAQI TRADE CENTER
JARACO S.A.
KEENCLOUD LIMITED
MEED INTERNATIONAL LIMITED
ORIENT SHIPPING LIMITED
PANDORA SHIPPING CO. S.A.
PETRA NAVIGATION & INTERNATIONAL TRADING CO. LTD.
PETRA NAVIGATION AND INTERNATIONAL TRADING CO. LTD.
RAJBROOK LIMITED
REYNOLDS AND WILSON
RWR INTERNATIONAL COMMODITIES
SOKTAR
T N K FABRICS LIMITED
T.E.G. LIMITED
TRADACO S.A.
TRADING & MARITIME INVESTMENTS
TRADING AND MARITIME INVESTMENTS
U.I. INTERNATIONAL
WHALE SHIPPING LTD.
[SOMALIA] — 22 entries
Somalia Sanctions Regulations, 31 C.F.R. part 551
“GODANE”
“GODANI”
“HASSAN, Sheikh”
“MUKHTAR, Shaykh”
“ZUBEYR, Abu”
ABU ZUBEYR, Muktar Abdirahman
ABUZUBAIR, Muktar Abdulrahim
ALI, Sheikh Hassan Dahir Aweys
AW MOHAMMED, Ahmed Abdi
AW-MOHAMED, Ahmed Abdi
AW-MOHAMUD, Ahmed Abdi
AWES, Hassan Dahir
AWES, Shaykh Hassan Dahir
AWEYES, Hassen Dahir
AWEYS, Ahmed Dahir
AWEYS, Hassan Dahir
AWEYS, Sheikh
AWEYS, Sheikh Hassan Dahir
DAHIR, Aweys Hassan
IBRAHIM, Mohammed Hassan
OAIS, Hassan Tahir
UWAYS, Hassan Tahir
[SDNT] — 13 entries
Narcotics Trafficking Sanctions Regulations, 31 C.F.R. part 536
“LUCAS”
“MECHAS”
“THE CHESS PLAYER”
AGRICOLA GANADERA HENAO GONZALEZ Y CIA. S.C.S.
ARIZONA S.A.
COMPANIA AGROINVERSORA HENAGRO LTDA.
DESARROLLOS COMERCIALES E INDUSTRIALES HENAO GONZALEZ Y CIA. S.C.S.
GONZALEZ BENITEZ, Olga Patricia
M.T.T. LTDA.
MAQUINARIA TECNICA Y TIERRAS LTDA.
ORGANIZACION EMPRESARIAL A DE J HENAO M E HIJOS Y CIA. S.C.S.
RENDON RAMIREZ, Jose Aldemar
RODRIGUEZ OREJUELA, Gilberto Jose
[RUSSIA-EO14024] — 13 entries
Executive Order 14024
CSOFT DEVELOPMENT
JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY FACTORY NAMED AFTER P. I. PLANDINA
JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY ZAVOD IMENI PLANDINA
JOINT STOCK COMPANY POLEMA
JOINT STOCK COMPANY SHIPREPAIRING CENTER ZVYOZDOCHKA
JOINT-STOCK COMPANY SHIP REPAIR CENTER ZVEZDOCHKA
JOINT-STOCK COMPANY TSS ZVEZDOCHKA
JSC ARZAMASSKY PRIBOROSTROITELNY ZAVOD NAMED AFTER PLANDIN
JSC CENTER SUDOREMONTA ZVEZDOCHKA (Cyrillic: АО ЦЕНТР СУДОРЕМОНТА ЗВЕЗДОЧКА)
SC ZVYOZDOCHKA
SHIPREPAIRING CENTER ZVYOZDOCHKA
SPECIAL SYSTEMS PHOTONICS LLC
USTINOV
[NPWMD] — 8 entries
Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544
KOREA KURYONGGANG TRADING CORPORATION
KOREA KUWOLSAN TRADING CORPORATION
KOREA RYENHAP 2 TRADING CORPORATION
KOREA TANGUN TRADING CORPORATION
RYUNG SENG TRADING CORPORATION
RYUNGSENG TRADING CORPORATION
RYUNGSONG TRADING CORPORATION
SECOND ACADEMY OF NATURAL SCIENCES FOREIGN AFFAIRS BUREAU
[LIBYA2] — 7 entries
Libyan Sanctions, 31 C.F.R. part 570
AL-ZULAYTINI, Abd-Al-Hafid Mahmud
ZLEITNI, Abdel-Hafez
ZLITNI, Abdelhafidh
ZLITNI, Abdul Hafid
ZLITNI, Abdul Hafiz
ZLITNI, Abdulhafid
ZLITNI, Abdulhafid Mahmoud
[DARFUR] — 6 entries
Sudan Stabilization Sanctions Regulations, 31 C.F.R. part 546
IBRAHIM, Khalil
MOHAMED, Khalil Ibrahim
SHANT, Adam Yacub
SHARIF, Adam Yacub
TAHA, Khalil Ibrahim Mohamed Achar Foudail
YACOUB, Adam
[TCO] — 2 entries
Transnational Criminal Organizations Sanctions Regulations, 31 C.F.R. part 590; Executive Order 13581
KIYOTA, Jiro
SIN, Byon-Gyu
[GLOMAG] — 1 entry
Executive Order 13818 (Global Magnitsky)
RIVAS REYES, Roberto Jose
[IRAN-EO13846] — 1 entry
Executive Order 13846
TASCA
Amendments (37)
These are before/after edits to existing SDN entries rather than deletions. Most add previously-unlisted AKAs, gender, nationality, or an identifier (a C.U.R.P. number shows up repeatedly across the Mexican narcotics-kingpin entries, for instance). A handful add a new program tag to an entry that was already listed under a different authority — worth a second look if you screen against a single tag rather than the full record. And a few, flagged individually below, are pure reformatting: an old free-text alias restyled into OFAC’s current “Surname, Given name” convention, not a newly-discovered identity.
#
Name
Program tag(s) after
What changed
1
AKTSIONERNOE OBSCHESTVO ARZAMASSKIY PRIBOROSTROITELNYI ZAVOD IMENI P I PLANDINA
[RUSSIA-EO14024]
added AKA(s): JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY FACTORY NAMED AFTER P. I. PLANDINA; JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY ZAVOD IMENI PLANDINA; JSC ARZAMASSKY PRIBOROSTROITELNY ZAVOD NAMED AFTER PLANDIN; org. established date added
2
AL-TURKI, Hassan Abdullah Hersi
[SDGT], [SOMALIA]
added tag SDGT; gender added; AKA restyled from a hyphen line-break artifact (“AL- TURKI”) to “AL-TURKI” — not a new spelling
gender added; C.U.R.P. identifier added; nationality field added/updated
28
OAO SHIP REPAIR CENTER ‘ZVEZDOCHKA’
[UKRAINE-EO13685], [RUSSIA-EO14024]
added tag(s) RUSSIA-EO14024; added AKA(s): JOINT STOCK COMPANY SHIPREPAIRING CENTER ZVYOZDOCHKA; JSC CENTER SUDOREMONTA ZVEZDOCHKA (Cyrillic: АО ЦЕНТР СУДОРЕМОНТА ЗВЕЗДОЧКА); Cyrillic name added; org. established date added
gender added; nationality field added/updated; freestanding “THET NAING WIN” retired now that the primary listing itself is properly split into surname/given-name fields
36
USTINOV
[UKRAINE-EO13661], [RUSSIA-EO14024]
added tag(s) RUSSIA-EO14024; Cyrillic name added; nationality field added/updated
Sectoral Sanctions Identifications (SSI) List Updates
Four entities added, in modern format — and these are exactly the four “retained UID” rows 15–18 from the consolidation chart above, now carrying Cyrillic names, current addresses, tax and registration identifiers, and an explicit EO 13662 directive determination (Directive 1 or Directive 3):
JOINT STOCK COMPANY UNITED ENGINE CORPORATION (Cyrillic: АКЦИОНЕРНОЕ ОБЩЕСТВО ОБЪЕДИНЕННАЯ ДВИГАТЕЛЕСТРОИТЕЛЬНАЯ КОРПОРАЦИЯ), a.k.a. “AO ODK,” Moscow; Directive 3 determination; Tax ID 7731644035 (Russia); Registration Number 1107746081717 (Russia); [UKRAINE-EO13662] [RUSSIA-EO14024]; Linked To: STATE CORPORATION ROSTEC.
LIMITED LIABILITY COMPANY KORUS CONSULTING CIS, St. Petersburg; Directive 1 determination; Tax ID 7801392271 (Russia); Registration Number 1057812752502 (Russia); [UKRAINE-EO13662] [RUSSIA-EO14024]; Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA.
OTKRYTOE AKTSIONERNOE OBSHCHESTVO VNESHNEEKONOMICHESKOE OBEDINENIE TEKHNOPROMEKSPORT, a.k.a. “JSC TPE,” Moscow; Directive 3 determination; Registration ID 1067746244026 (Russia); Tax ID 7705713236 (Russia); [UKRAINE-EO13662] [UKRAINE-EO13685]; Linked To: STATE CORPORATION ROSTEC.
SOVREMENNYE TEKHNOLOGII LIMITED LIABILITY COMPANY, Moscow; Directive 1 determination; Tax ID 7708229993 (Russia); Registration Number 1037708040468 (Russia); [UKRAINE-EO13662] [RUSSIA-EO14024]; Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA.
Nineteen deletions, all tagged [UKRAINE-EO13662] — every one of these is an old-style, single-alias entry for one of the four entities just added above:
LLC SOVREMENNYE TECHNOLOGII
MODERN TECHNOLOGIES LIMITED LIABILITY COMPANY
SOVREMENNYE TEKHNOLOGII, OOO
OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU SOVREMENNYE TEKHNOLOGII
KORUS CONSULTING CIS LIMITED LIABILITY COMPANY
LLL KORUS CONSULTING CIS
KORUS KONSALTING SNG, OOO
OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU KORUS KONSALTING SNG
OTKRYTOE AKTSIONERNOE OBSHCHESTVO UPRAVLYAYUSHCHAYA KOMPANIYA OBEDINENNAYA DVIGATELESTROITELNAYA KORPORATSIYA
Non-SDN Palestinian Legislative Council (NS-PLC) List Updates
One addition — a consolidated entry for HANIYAH, Ismail Abdul Salah (a.k.a. HANIEH, Ismail; a.k.a. HANIYA, Ismael; a.k.a. HANIYA, Ismail; a.k.a. HANIYAH, Ismael; a.k.a. HANIYEH, Ismail Abdel Salam Ahmed; a.k.a. HANIYEH, Ismayil; a.k.a. HANIYYAH, Ismail), DOB 1962, POB Shati refugee camp, Gaza Strip, tagged [SDGT] [NS-PLC]. Three deletions immediately follow: the old-style single/dual-alias entries “HANIYA, Ismail Abdul Salah,” “HANIYA, Ismail,” and “HANIYYA, Ismaeel” — all now folded into the one consolidated record above (row 11 in the chart, retained UID 23627).
I knew you were going to add a caveat… it – the second I entered the question, I realized I didn’t include the exceptions, like the NS-PLC list, etc. Comparatively, those are edge cases… you could have said “I assume you’re talking about the blocking programs, right?” and be done with it
Claude responded:
Fair, and that’s the better version of it. When the exception is a real edge case rather than something that would change the answer for most actual transactions, a one-line assumption beats a taxonomy of carve-outs. Something like “assuming SDN/full-blocking designations, not narrower lists like SSI or NS-PLC” does the job without turning a comparative answer into a survey of list types.
Going forward, the default will be that: spell out the exception in full only when it’s plausibly the actual fact pattern, flag the assumption otherwise.
My next prompt:
or if i ask for a more comprehensive survey of options, OK?
Claude responded:
Of course — that’s the trigger for the full breakdown. Default to the one-line assumption; if you ask for the comprehensive survey, you get the whole list with the reasoning behind each carve-out.
