Mr. Sanctions

Category: OFAC (US)

  • December 14, 2025: New Version of Russia-related GL 131, and updated FAQs

    Today, OFAC issued Russia-related General License 131B – identical to 131A, except that the expiration date got moved to end of February.

    russia_gl131bDownload

    Two Frequently Asked Questions got updated – 1224:

    1224. What negotiations does Russia-related General License 131B authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

    and 1225:

    1225. What activities do Russia-related General License 128B and General License 131B authorize related to Lukoil International GmbH (LIG)?

    Both were changed to refer to the new version of the GL, of course.

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  • Trendy! A look back at OFAC Enforcement Actions

    My prompts to Gemini:

    Please identify trends for: a) 2025 as compared to the years 2015 to 2024, inclusive b) the years 2023 to 2025, inclusive as compared to the years 2015 to 2022, inclusive c) the years 2021 to 2025, inclusive as compared to the years 2015 to 2020, inclusive. Please wait for clarification as to what I am looking for before proceeding.

    Identify trends in a) specific behaviors or failures, such as wire stripping, lack of DNS or other internet-based checks, or ignoring internal whistleblower warnings b) size of assessed penalties or settlement amounts c) size of base penalties d) the combination of the egregiousness factor and voluntary self-disclosure factor e) the industries of the firm involved f) the ratio of financial services firms penalized vs. non-financial firms penalized g) the aggravating factors noted h) the mitigating factors noted g) the general timeframe of the violations (e.g. 2 years, 3 months duration) h) the amount of time between the end of the violating behavior and the settlement i) any other patterns you can identify… Lastly, if you infer something other than what is explicitly named in the enforcement notices (and/or settelement agreements, if available), please identify it as such and explain your reasoning.

    please add for each insight the number of matching actions that fit the insight, and the percentage of each population that represents (example: 4 enforcement actions of 12 total, would be represented similarly to “4 enforcement actions, 33% of total). Use whole percentages only

    After a few extra refining steps, I got back this:

    Based on the enforcement actions published by OFAC through the end of 2025 (Total Population: 14 actions), and historical data from previous years, here is the trend analysis with the requested level of detail and corrected distributions.

    Trend Analysis by Time Period

    a) 2025 vs. 2015–2024

    • Rise of the “Gatekeepers”:
      • Trend: In 2025, OFAC heavily targeted firms that manage wealth or property rather than just moving funds. 5 of the 14 enforcement actions (36%) were levied against Venture Capital, Private Equity, Holding Companies, or Real Estate firms. This is a sharp deviation from the 2015–2024 average, where such “gatekeeper” actions typically represented less than 5% of the annual caseload.
      • Matching Actions (2025): GVA Capital, Gracetown Inc., IPI Partners, Key Holding, Family International Realty.
    • Individual Liability:
      • Trend: There was a significant spike in penalties assessed against specific persons rather than corporate entities. 3 of the 14 actions (21%) in 2025 explicitly named “An Individual” or a specific person alongside a small entity. In the 2015–2024 period, actions against individuals were rare outliers (often 0% to 5% of annual cases).
      • Matching Actions (2025): An Individual (Dec 9), An Individual (Nov 24), Family International Realty (and an Individual).

    b) 2023–2025 vs. 2015–2022

    • Crypto & Fintech Focus:
      • Trend: The 2023–2025 period solidified the Virtual Currency sector as a primary enforcement target. 11 of the ~43 enforcement actions (approx. 26%) over this three-year period involved crypto exchanges, wallet providers, or fintech platforms. In contrast, during the 2015–2022 era, this sector represented fewer than 5% of total actions.
      • Matching Actions (2025 examples): Exodus Movement, ShapeShift AG, Interactive Brokers.
    • Decline of Tier 1 Banks:
      • Trend: Traditional commercial banks have nearly vanished from the enforcement list. In the 2023–2025 period, traditional banks accounted for less than 10% of actions. This compares to the 2015–2019 period, where banks frequently constituted 30–50% of the annual lists due to the “wire stripping” sweeps.

    c) 2021–2025 vs. 2015–2020

    • The Russia Shift:
      • Trend: Driven by the 2022 invasion of Ukraine, the focus of enforcement has shifted decisively to Russia. In 2025 alone, at least 5 of the 14 actions (36%) were primarily driven by Russia/Ukraine-related sanctions (targeting oligarch assets or industrial exports). Across the 2021–2025 window, Russia cases represent approximately 30–40% of volume, whereas the 2015–2020 period was dominated by Iran, Cuba, and Sudan cases (often >60%).

    Detailed Factor Analysis (2025 Data Focus)

    • a) Specific Behaviors:
      • Gatekeeper Negligence: 5 actions (36%) involved trust or investment firms failing to identify that their ultimate beneficiary was a blocked person.
      • IP/Geolocation Failures: 3 actions (21%) explicitly cited the failure to use available IP address data to block users in sanctioned jurisdictions (e.g., Interactive Brokers, Exodus, ShapeShift).
    • b) Size of Assessed Penalties (Corrected Distribution):
      • Mega-Penalty (> $20 Million):1 action (7%).
        • Detail: GVA Capital ($216M). This single outlier accounted for the vast majority of the total dollar value.
      • Middle Market ($1 Million – $12 Million):11 actions (79%).
        • Detail: This was the dominant tier for 2025, comprising nearly 80% of all cases. Unlike previous years which saw many small settlements, 2025 saw a high floor for penalties.
        • Matching Actions: Interactive Brokers ($11.8M), IPI Partners ($11.5M), Gracetown ($7.1M), Individual($4.7M), Unicat ($3.9M), Exodus ($3.1M), Fracht ($1.6M), Harman ($1.45M), Individual ($1.1M), Family Realty ($1.1M), Haas ($1.0M).
      • Small Penalties (< $1 Million):2 actions (14%).
        • Detail: Only two cases fell below the million-dollar mark, a significant decrease in the frequency of “slap on the wrist” settlements compared to prior years.
        • Matching Actions: ShapeShift AG ($750k), Key Holding ($608k).
    • c) Industries Involved:
      • Investment/Wealth Management: 5 actions (36%) (VC, PE, Holding).
      • Tech/Fintech/Crypto: 3 actions (21%).
      • Manufacturing/Logistics: 3 actions (21%) (Haas, Harman, Unicat).
    • d) Egregiousness & VSD:
      • High Severity: While exact determinations vary, the high proportion of penalties exceeding $1 million (93% of cases) suggests a trend toward viewing 2025 violations as substantive rather than merely procedural.
    • e) Aggravating Factors:
      • Individual Recklessness: Explicitly noted in 3 actions (21%) where individuals were personally fined.
      • Reason to Know: Cited in 3 actions (21%) (Tech/Crypto) where the firm possessed IP data but failed to utilize it for screening.
    • f) Timeframe of Violations:
      • Pre-2022 Conduct: 12 of 14 actions (86%) involved conduct that began before or during 2022. This reinforces the 3–5 year lag between violation and enforcement.
    • g) Inferred Patterns:
      • Whistleblower Driven: The enforcement against small private firms and individuals (approx. 20–30% of cases) strongly implies reliance on whistleblower tips or specific intelligence, as these entities lack the transaction volume to trigger automated bank filters.

    Interesting insights… did you notice anything else? I asked for those percentages because Gemini originally over-emphasized that one really large settlement, giving it a lot more significance than perhaps it deserved. 7 percent, sure… but still only one action. A single data point does not make a trend.

    And, due to the generally low number of enforcement actions, total, take this with a grain of salt. You’ll notice how Gemini highlighted the rise of Russia-related actions after 2022 – thanks, Captain Obvious! Sure, there were the Ukaine/Russia-related sanctions after 2014, but…

    Nonetheless, there are insights to be cognizant of, that perhaps should be given more consideration.

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  • January 13, 2026: OFAC counter-terrorism designations

    Counter Terrorism Designations

    Treasury Press Release: Treasury and State Departments Designate Muslim Brotherhood Branches as Terrorist Organizations

    Additions:

    The following individual has been added to OFAC’s SDN List:

    TAQQOSH, Muhammad Fawzi

    • AKA: TAKKOUSH, Mohammad
    • AKA: TAKUSH, Muhammad
    • AKA: TAQUSH, Muhammad
    • DOB: 1973
    • POB: Beirut, Lebanon
    • nationality: Lebanon
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: individual
    • Linked to: LEBANESE MUSLIM BROTHERHOOD

    Supplemental Information: According to the Treasury press release, Muhammad Fawzi Taqqosh is the Secretary General of the Lebanese Muslim Brotherhood and has been designated as a Specially Designated Global Terrorist.

    OFAC Program: SDGT Specially Designated Global Terrorist

    The following entities have been added to OFAC’s SDN List:

    EGYPTIAN MUSLIM BROTHERHOOD (Arabic: الإخوان المسلمون)

    • Website: www.ikhwaonline.com
    • alt. Website: www.ikhwanweb.com
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 1928
    • Organization Type: Advocacy organization
    • Linked to: HAMAS

    Supplemental Information: The Treasury press release states that the Egyptian Muslim Brotherhood (EMB) has coordinated on terrorist activities against Israeli interests and worked with Hamas to undermine and destabilize the Egyptian government, accepting Hamas funding to do so. EMB members have reportedly provided support to Hamas militants, including facilitating the entry of fighters into Gaza.

    JORDANIAN MUSLIM BROTHERHOOD

    • AKA: MUSLIM BROTHERHOOD GROUP
    • AKA: MUSLIM BROTHERHOOD IN JORDAN
    • AKA: MUSLIM BROTHERHOOD SOCIETY
    • Address: Amman, Jordan
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 1945
    • Organization Type: Advocacy organization
    • Linked to: HAMAS

    Supplemental Information: The Treasury press release indicates that the Jordanian Muslim Brotherhood (JMB) has materially assisted Hamas. Elements connected to the group have been involved in terrorism cases in Jordan since early 2025, engaging in the manufacturing of rockets, explosives, and drones, as well as recruitment operations and raising money through illegal means.

    OFAC Program: SDGT Specially Designated Global Terrorist

    LEBANESE MUSLIM BROTHERHOOD (Arabic: الجماعة الإسلامية بلبنان)

    • AKA: AL-JAMAA AL-ISLAMIYAH
    • AKA: AL-JAMAAH AL-ISLAMIYAH
    • AKA: JAMAA ISLAMIYA
    • AKA: JAMA’A ISLAMIYAH
    • AKA: JAMAA ISLAMIYAH
    • AKA: QUWAT AL-FAJR
    • AKA: “AL-FAJER FORCES”
    • AKA: “AL-FAJR FORCES”
    • AKA: “ISLAMIC GROUP IN LEBANON”
    • AKA: “THE DAWN FORCES”
    • AKA: “THE FAJR FORCES”
    • AKA: “THE ISLAMIC GROUP”
    • Address: Lebanon
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 1964
    • Organization Type: Advocacy organization

    Supplemental Information: The State Department designated the Lebanese Muslim Brotherhood (also known as al-Jamaa al-Islamiyah) as a Foreign Terrorist Organization. The press release notes that a wing of the Lebanese branch launched rockets on Israel following the October 7, 2023, Hamas attack.

    • OFAC Programs:
      • FTO Foreign Terrorist Organizations
      • SDGT Specially Designated Global Terrorist

    Sources:

    1. U.S. Department of the Treasury. “Treasury and State Departments Designate Muslim Brotherhood Branches as Terrorist Organizations.” January 13, 2026. https://home.treasury.gov/news/press-releases/sb0357
    2. Office of Foreign Assets Control. “Program Tag Definitions for OFAC Sanctions Lists.” https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/program-tag-definitions-for-ofac-sanctions-lists

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  • January 8, 2026: OFAC Designation Removals, Changes and Administrative Changes

    Russia-related Designation Update and Designation Removal

    Delistings:

    The following deletions have been made to OFAC’s SDN List:

    OFAC Program: RUSSIA-EO14024 Harmful Foreign Activities Sanctions Regulations

    KAMPERI, Kyriaki Demetriou (a.k.a. KAMPERI, Koulla Demetriou; a.k.a. KAMPERI, Kyriakou Demetriou), 35 Grosvenor Street, 1st Floor Offices, London W1K 4QX, United Kingdom; Ledra Business Centre, 1 Poseidonos Street, Egkomi Nicosias 2406, Cyprus; Ledra House, 15 Agiou Pavlou, Nicosia 1105, Cyprus; DOB 01 Jan 1971 to 31 Jan 1971; nationality Cyprus; Gender Female; Secondary sanctions risk: See Section 11 of Executive Order 14024. (individual)

    KAMPERI, Koulla Demetriou (a.k.a. KAMPERI, Kyriaki Demetriou; a.k.a. KAMPERI, Kyriakou Demetriou), 35 Grosvenor Street, 1st Floor Offices, London W1K 4QX, United Kingdom; Ledra Business Centre, 1 Poseidonos Street, Egkomi Nicosias 2406, Cyprus; Ledra House, 15 Agiou Pavlou, Nicosia 1105, Cyprus; DOB 01 Jan 1971 to 31 Jan 1971; nationality Cyprus; Gender Female; Secondary sanctions risk: See Section 11 of Executive Order 14024. (individual)

    KAMPERI, Kyriakou Demetriou (a.k.a. KAMPERI, Koulla Demetriou; a.k.a. KAMPERI, Kyriaki Demetriou), 35 Grosvenor Street, 1st Floor Offices, London W1K 4QX, United Kingdom; Ledra Business Centre, 1 Poseidonos Street, Egkomi Nicosias 2406, Cyprus; Ledra House, 15 Agiou Pavlou, Nicosia 1105, Cyprus; DOB 01 Jan 1971 to 31 Jan 1971; nationality Cyprus; Gender Female; Secondary sanctions risk: See Section 11 of Executive Order 14024. (individual)

    Amendments:

    The following changes have been made to OFAC’s SDN List:

    OFAC Program: RUSSIA-EO14024 Harmful Foreign Activities Sanctions Regulations

    VASSILIADES & CO UK LIMITED

    • AKA: VASSILIADES AND CO UK LIMITED
    • Address: 35 Grosvenor Street, 1st Floor Offices, London W1K 4QX, United Kingdom
    • Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Organization Established Date 02 Jan 2015
    • Registration Number 09371804 (United Kingdom)
    • Linked to: VASSILIADES, Christodoulos Georgiou

    List of Changes:

    • Field Name: Linked To
      • Deleted: KAMPERI, Kyriaki Demetriou

    Administrative Changes to OFAC’s SDN List

    OFAC Program: IRAN Iran Sanctions Regulations

    ARGO I (T2EM4)

    • AKA:
      • AMOL
      • ARGO 1
      • CASTOR
      • SILVER CLOUD
      • “CHRISTINA”
    • Vessel Type: Crude/Oil Products Tanker
    • Vessel Flag: Iran
    • Other Vessel Flag Malta
    • Other Vessel Flag Tuvalu
    • Other Vessel Flag Tanzania
    • DWT 99,094DWT
    • GRT 56,068GRT
    • Additional Sanctions Information – Subject to Secondary Sanctions
    • Vessel Registration Identification IMO 9187667
    • Party Type: vessel
    • Linked to: NATIONAL IRANIAN TANKER COMPANY

    List of Changes:

    • Field Name: AKA
      • Changed: f.k.a. AMOL to: a.k.a. AMOL
      • Changed: f.k.a. CASTOR to: a.k.a. CASTOR
      • Changed: f.k.a. SILVER CLOUD to: a.k.a. SILVER CLOUD
      • Changed: f.k.a. “CHRISTINA” to: a.k.a. “CHRISTINA”
    • Field Name: MMSI
      • Deleted: 256843000

    OFAC Program: RUSSIA-EO14024 Harmful Foreign Activities Sanctions Regulations

    JOINT STOCK COMPANY PUBLIC TRUST BANK

    • AKA: JSC NDBANK
    • Address: St. Dubininskaya, 57, Building 1, Moscow 115054, Russia
    • SWIFT/BIC NADORUMM
    • Website www.ndb24.ru
    • Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Target Type Financial Institution
    • Tax ID No. 7708018456 (Russia)
    • Legal Entity Number 253400B8Y0FNJP628S19
    • Registration Number 1027739461694 (Russia)

    List of Changes:

    • Field Name: Legal Entity Number
      • Changed: 25400B8Y0FNJP628S19 to: 253400B8Y0FNJP628S19

    OFAC Program: SDGT Global Terrorism Sanctions Regulations

    KHALIL, Khaled Muhammad

    • AKA:
      • KHALIL, Khaled
      • KHALIL, Khaled Mohammed
    • Address: Yemen
    • DOB 01 Jan 1987
    • POB Capital Municipality, Al-Safiyah District, Yemen
    • nationality Yemen
    • Gender Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport 06280482 (Yemen) issued 2025
    • Identification Number 01010047101 (Yemen)
    • Party Type: individual
    • Linked to: ANSARALLAH

    List of Changes:

    • Field Name: POB
      • Changed: Capital Emirate, Al-Safiyah District, Yemen to: Capital Municipality, Al-Safiyah District, Yemen

    LEBANESE MEDIA GROUP

    • AKA: LEBANESE COMMUNICATION GROUP
    • Address: Al Manar Building, Ahmad Kassir Street, Haret Hriek, Baabda, Lebanon; Abed Al Nour Street, Haret Hriek, PO Box 354/25, Beirut, Lebanon
    • Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Commercial Registry Number 59531 (Lebanon)

    List of Changes:

    • Field Name: Company ID
      • Deleted: No. 59 531 at Commercial Registry of the Civil Court of First Instance at Baabda, Lebanon
    • Field Name: Commercial Registry Number
      • Added: 59531 (Lebanon)

    OFAC Programs:

    • UKRAINE-EO13662 Ukraine-related Sanctions Regulations
    • RUSSIA-EO14024 Harmful Foreign Activities Sanctions Regulations

    PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA

    • AKA:
      • JOINT STOCK COMMERCIAL SAVINGS BANK OF THE RUSSIAN FEDERATION
      • JOINT STOCK COMMERCIAL SAVINGS BANK OF THE RUSSIAN SOVIET FEDERATIVE SOCIALIST REPUBLIC
      • OJSC SBERBANK OF RUSSIA
      • OPEN JOINT STOCK COMPANY SBERBANK OF RUSSIA
      • OTKRYTOE AKTSIONERNOE OBSHCHESTVO SBERBANK ROSSII
      • PJSC SBERBANK
      • SBERBANK OF RSFSR
      • SBERBANK OF RUSSIA
      • SBERBANK ROSSII
      • SBERBANK ROSSII OAO
      • “SBERBANK INDIA”
      • “SBERBANK MUMBAI”
    • Address: 19 ul. Vavilova, Moscow 117312, Russia; C305/306A Lufthansa Centre 50 Liangmaqiao Rd., Chaoyang District, Beijing 100027, China; upper ground floor and fourth floor, Birla Tower, 25-Barakhamba Road, New Delhi 110001, India; 81-B, 8th Floor, 5th North Avenue, Maker Maxity, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051, India
    • SWIFT/BIC SABRRUMM
    • Website www.sberbank.ru
    • alt. Website www.sberbank.com
    • Executive Order 13662 Directive Determination – Subject to Directive 1
    • Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209
    • alt. Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Target Type Financial Institution
    • Executive Order 14024 Directive Information – For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives
    • Executive Order 14024 Directive Information Subject to Directive 3 – All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the ‘Effective Date (EO 14024 Directive)’ associated with this name are prohibited.
    • Listing Date (EO 14024 Directive 2): 24 Feb 2022
    • Effective Date (EO 14024 Directive 2): 26 Mar 2022
    • Listing Date (EO 14024 Directive 3): 24 Feb 2022
    • Effective Date (EO 14024 Directive 3): 26 Mar 2022
    • Tax ID No. 7707083893 (Russia)
    • Registration Number 1027700132195 (Russia)
    • For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.

    List of Changes:

    • Field Name: Address
      • Changed: 81-B, 8th Floor, 5th North Avenue, Maker Maxity, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 40051, India to: 81-B, 8th Floor, 5th North Avenue, Maker Maxity, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051, India

    OFAC Programs:

    • SDGT Global Terrorism Sanctions Regulations
    • IFSR Iranian Financial Sanctions Regulations

    TURKOCA IMPORT EXPORT TRANSIT CO., LTD.

    • AKA: TUREUKOSASUCHULIPTEULAENJIT CO., LTD.
    • Address: Rm 401, 4/F, Rishu Bldg, 25 Hangang-daero 48-gil, Yongsan-gu, Seoul 04382, Korea, South; Daekyong building, Ground floor 9-79, 59-1 Duteopbawi-ro, Huam-dong, Yongsan-gu, Seoul, Korea, South
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date 18 Nov 2019
    • Business Registration Number 3858701478 (Korea, South)
    • Registration Number 1101117294773 (Korea, South)
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE

    List of Changes:

    • Field Name: Address
      • Changed: Rm 401, 4/F, Rishu Bldg, 25 Hangang-daero 48-gil, Yongan-gu, Seoul 04382, Korea, South to: Rm 401, 4/F, Rishu Bldg, 25 Hangang-daero 48-gil, Yongsan-gu, Seoul 04382, Korea, South

    Administrative Changes to OFAC’s Sectoral Sanctions Identifications List (SSI List)

    OFAC Programs:

    • UKRAINE-EO13662 Ukraine-related Sanctions Regulations
    • RUSSIA-EO14024 Harmful Foreign Activities Sanctions Regulations

    PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA

    • AKA:
      • JOINT STOCK COMMERCIAL SAVINGS BANK OF THE RUSSIAN FEDERATION
      • JOINT STOCK COMMERCIAL SAVINGS BANK OF THE RUSSIAN SOVIET FEDERATIVE SOCIALIST REPUBLIC
      • OJSC SBERBANK OF RUSSIA
      • OPEN JOINT STOCK COMPANY SBERBANK OF RUSSIA
      • OTKRYTOE AKTSIONERNOE OBSHCHESTVO SBERBANK ROSSII
      • PJSC SBERBANK
      • SBERBANK OF RSFSR
      • SBERBANK OF RUSSIA
      • SBERBANK ROSSII
      • SBERBANK ROSSII OAO
      • “SBERBANK INDIA”
      • “SBERBANK MUMBAI”
    • Address: 19 ul. Vavilova, Moscow 117312, Russia; C305/306A Lufthansa Centre 50 Liangmaqiao Rd., Chaoyang District, Beijing 100027, China; upper ground floor and fourth floor, Birla Tower, 25-Barakhamba Road, New Delhi 110001, India; 81-B, 8th Floor, 5th North Avenue, Maker Maxity, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051, India
    • SWIFT/BIC SABRRUMM
    • Website www.sberbank.ru
    • alt. Website www.sberbank.com
    • Executive Order 13662 Directive Determination – Subject to Directive 1
    • Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209
    • alt. Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Target Type Financial Institution
    • Executive Order 14024 Directive Information – For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives
    • Executive Order 14024 Directive Information Subject to Directive 3 – All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the ‘Effective Date (EO 14024 Directive)’ associated with this name are prohibited.
    • Listing Date (EO 14024 Directive 2): 24 Feb 2022
    • Effective Date (EO 14024 Directive 2): 26 Mar 2022
    • Listing Date (EO 14024 Directive 3): 24 Feb 2022
    • Effective Date (EO 14024 Directive 3): 26 Mar 2022
    • Tax ID No. 7707083893 (Russia)
    • Registration Number 1027700132195 (Russia)
    • For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.

    List of Changes:

    • Field Name: Address
      • Changed: 81-B, 8th Floor, 5th North Avenue, Maker Maxity, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 40051, India to: 81-B, 8th Floor, 5th North Avenue, Maker Maxity, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051, India

    VTB BANK BELARUS CLOSED JOINT STOCK COMPANY

    • AKA:
      • CJSC SLAVNEFTEBANK
      • CJSC VTB BANK BELARUS
      • VTB BANK BELARUS
      • VTB BANK BELARUS CJSC
    • Address: 14, Moskovskaya Street, Minsk 220007, Belarus
    • SWIFT/BIC SLANBY22
    • Website www.vtb-bank.by
    • Executive Order 13662 Directive Determination – Subject to Directive 1
    • Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209
    • alt. Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Target Type Financial Institution
    • For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives
    • Linked to: VTB BANK PUBLIC JOINT STOCK COMPANY

    List of Changes:

    • Field Name: AKA
      • Deleted: VTB BANK BELARUS CLOSED JOINT STOCK COMPANY

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  • Burning Question: Why can’t Cuba sanctions be lifted by the President (like the North Korea ones)?

    In 2008, President Bush performed a legal maneuver that essentially updated the “operating system” for North Korea sanctions from an old version (TWEA) to a modern version (IEEPA). While this was technically possible for North Korea, it is legally impossible for a President to do the same for Cuba without Congress.

    The reason lies in the difference between Executive Orders (rules the President makes) and Statutory Law (rules Congress makes).

    The Layperson Explanation: “The Golden Handcuffs”

    Imagine sanctions are a fence built around a country.

    • North Korea’s Fence (Pre-2008): The fence was built by President Truman in 1950 using his own authority. Because a President built it, a later President (Bush) had the power to tear it down or rebuild it using different materials (swapping TWEA for IEEPA) without asking permission.
    • Cuba’s Fence: This fence was also originally built by a President (Kennedy). However, in 1996, Congress passed a law (the Helms-Burton Act) that effectively poured concrete over the fence posts. Congress declared that the President’s fence was now Federal Law.
    • The Result: The President can no longer simply swap the legal authority or take down the fence. Congress holds the only key to unlock it. If the President tried to “terminate” the TWEA authority for Cuba, they would be violating the law passed in 1996 which mandates those specific restrictions remain in place until Cuba becomes a democracy.

    Comparison: Creation and Evolution of Sanctions

    The two programs started similarly but diverged wildly in the 1990s.

    1. North Korea: The “Executive” Model

    • Origin (1950): Upon the outbreak of the Korean War, President Truman declared a national emergency and imposed sanctions using the Trading with the Enemy Act (TWEA).
    • The “Grandfather” Clause (1977): In 1977, Congress passed a law (IEEPA) saying TWEA could only be used for wars, not peacetime emergencies. However, they allowed existing emergencies (like North Korea and Cuba) to continue under TWEA (“grandfathered in”).
    • The 2008 Swap: To aid nuclear negotiations, President Bush wanted to remove North Korea from the list of TWEA countries. Because these sanctions were largely kept in place by Executive Order, he issued Proclamation 8271, terminating the TWEA emergency. He immediately issued Executive Order 13466 to place North Korea under IEEPA authorities instead. This kept sanctions in place but updated their legal basis to the modern standard.

    2. Cuba: The “Statutory” Model

    • Origin (1960s): President Kennedy imposed the embargo under the Foreign Assistance Act and TWEA. For decades, it operated just like the North Korea program—renewed annually by the President.
    • The Codification (1996): In reaction to Cuba shooting down two American civilian planes (Brothers to the Rescue), Congress passed the Helms-Burton Act (LIBERTAD Act).
      • Section 102(h): This specific section “codified” the embargo. It stated that all regulations in effect on March 1, 1996, were now law.
    • The Lock: This removed the President’s discretion. While Presidents (like Obama or Biden) can modify the rules (licensing travel or remittances), they cannot terminate the underlying authority (TWEA) or the embargo itself. The law requires a Presidential certification to Congress that a “transition government” is in power in Cuba before the sanctions can be lifted.

    Summary of Differences

    FeatureNorth Korea Sanctions (2008 Era)Cuba Sanctions (Present Day)
    Primary AuthorityIEEPA (Executive discretion)TWEA (Congressionally Mandated)
    Can the President End it?Yes. (Until 2016*)No. Requires Congress.
    Legal BasisExecutive Orders & Proclamations.Helms-Burton Act (1996) (Statutory Law).
    Renewal ProcessPresident declares yearly “Emergency”.President must renew TWEA authority annually or violate the statute.

    *Note: Since 2016, Congress has passed stricter laws on North Korea (NKSPEA), effectively beginning to “codify” those sanctions as well, making them harder to lift today than they were in 2008.

    Sources

    • Bush’s 2008 Action: Proclamation 8271 (Termination of the Exercise of Authorities Under the Trading With the Enemy Act With Respect to North Korea) and Executive Order 13466.
    • Cuba Codification: The Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996 (Pub. L. 104-114), specifically Title I, Section 102(h).
    • TWEA vs. IEEPA History: Congressional Research Service Report R45618, “The International Emergency Economic Powers Act: Origins, Evolution, and Use.”
    • General Comparison: Haney, P. J., & Vanderbush, W. (1999). “The Role of Ethnic Interest Groups in U.S. Foreign Policy: The Case of the Cuban American National Foundation.” International Studies Quarterly.

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  • January 6, 2026: New version of Russia-Related GL 13 + updated FAQs

    Today’s OFAC Action includes the publication of Russia-Related General License 13P, which extends the expiration date of the GL from January 9th to April 9th:

    russia_gl13pDownload

    OFAC also updated two Frequently-Asked Questions (FAQs) to refer to the new version of the GL – 999:

    999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?

    and 1118:

    1118. As of December 2022, the Government of the Russian Federation may require a so-called “exit tax” payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called “exit tax”? Does Russia-related General License (GL) 13P authorize transactions that involve the payment of this exit tax?

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  • AI Corner: And now for the output

    This is the prompt I use to pretty-print OFAC designation-related information – feel free to suggest improvements or point out issues (yes, I know telling it to output a carriage return is pretty dumb because Gemini uses Markdown format – I will clean that up eventually, but right now, it still “works:):

    Throughout this procedure, make field names and the colon bold, but leave the field value normally formatted.

    Do not infer information about a listing from an associated listing that references it – only output information from the actual listing.

    Provide no citation markers. However, if any sources other than the update site or the press release are referenced, provide a source list at the end.

    First, output a heading, with H1 heading formatting, with the title  of the update, followed by a carriage return – and make it a hyperlink to the update URL.

    If there was a press release, output the name of the issuing body (e.g. “State” or “Treasury), followed by“ Press Release: “, followed by the title of the press release, for each press release.. Ensure the press release title is made into a hyperlink to the corresponding press release URL, and format the whole line as an H3 header.

    If there are sections of additions:

    Output “Additions:” with H2 heading, and bold.

    Output a carriage return.

    For each listing in each section of additions:

    Reformat each listing:

    Output the name, bolded. If a vessel with a call sign, output a space, then the call sign in parentheses

    Then produce the rest of the data as a bulleted list:

    1. If there are AKAs, list those prefaced by “AKA: “ and make that label bold. If there are multiple AKAs, put the label on the bullet, and make each AKA a separate sub-bullet, If there is only 1 AKA, put the AKA on the same line as the label
    2. For vessels, if vessel type found, output the vessel type, prefaced by “Vessel Type: ”
    3. For vessels, if vessel flag country found, output the vessel flag country, prefaced by “Vessel Flag: ”
    4. List remaining fields in order of their presence. However, do not list the program tags. Bold the field name.
    5. If there is a listed party type, list it, prefaced by “Party Type: “. Bold the label
    6. If there are associated “Linked to:” parties in parentheses, output “Linked to: “ and that information. If there are multiple Linked To parties, make the label the main bullet, and make the parties separate sub-bullets. Make the label  bold.

    Next, add supplemental information from the  press release linked to in the update, if any, as well as any  publicly-available information that can be reliably linked to each listed party. Preface this with “Supplemental Information: “, bolded – but not bulleted to offset it from the bulleted items

    Then output two carriage returns.

    Preface each section divided by type of party (e.g. individuals, entities, \ vessels, aircraft) and by the list updated (e.g. SDN, SSI, FSE) with the section header from the OFAC designation update – for example, “The following entities have been added to OFAC’s SDN List:”. Make the section header ,  italicized and bolded.

    Group listings within each section by the combination of program tags.

    Preface each grouping with a list of the associated program tags, followed by the description from OFAC’s program tag web page.  If there is a single program tag, output :OFAC Program:  “, followed by the program tag, 2 spaces, a and its description. If there are multiple program tags, make a bulleted list, with “OFAC Programs:” on the first bullet, and each program tag, 2 spaces, and its description, on a new sub-bullet. Make this italicized.

    Output two carriage returns between listings within each section

    End of additions section logic

    If there are sections of deletions, removals or delistings:

    Output “Delistings:” with H2 heading formatting, bolded.

    Output a carriage return.

    Preface each section divided by type of party (e.g. individuals, entities, \ vessels, aircraft) and by the list updated (e.g. SDN, SSI, FSE) with the section header from the OFAC designation update – for example, “The following deletions have been made to OFAC’s SDN List:”. Make the section header ,  italicized and bolded.

    Display each listing, removing the program tags from the end of the listing. Bold each field name. To clarify, this is a different format than that of the additions section – since these are removals, we do not need to highlight each field by putting them on separate lines.

    Group listings  by the combination of program tags.

    Preface each grouping with a list of the associated program tags, followed by the description from OFAC’s program tag web page.  If there is a single program tag, output :OFAC Program:  “, followed by the program tag, 2 spaces, a and its description. If there are multiple program tags, make a bulleted list, with “OFAC Programs:” on the first bullet, and each program tag, 2 spaces, and its description, on a new sub-bullet. Make this italicized.

    Output two carriage returns between listings 

    End of deletions, removals or delistings section logic

    If there are sections of changes: 

    Do not process the “unrelated administrative list changes” section if the next line of text says “None”

    Output “Amendments:” with H2 heading formatting, bolded.

    Output a carriage return.

    Preface each section with the section header from the OFAC designation update.

    Make the section header , italicized and bolded.

    Reformat each listing:

    For the new version of the listing:

    a) Output the name, bolded

    b) Then produce the rest of the data as a bulleted list:

    1. If there are AKAs, list those prefaced by “AKA: “ and make that label bold. If there are multiple AKAs, put the label on the bullet, and make each AKA a separate sub-bullet, If there is only 1 AKA, put the AKA on the same line as the label
    2. List remaining fields in order of their presence. However, do not list the program tags. Bold the field name.
    3. If there is a listed party type, list it, prefaced by “Party Type: “. Bold the label
    4. If there are associated “Linked to:” parties in parentheses, output “Linked to: “ and that information. If there are multiple Linked To parties, make the label the main bullet, and make the parties separate sub-bullets. Make the label  bold.

    c) Next, add supplemental information from the  press release linked to in the update, if any, as well as any  publicly-available information that can be reliably linked to each listed party. Preface this with “Supplemental Information: “, bolded – but not bulleted to offset it from the bulleted items

    d) Then output two carriage returns.

    e) Then, Output “List of Changes:” followed by a carriage return. Make this italicized and bolded.

    Make a bulleted list of every field in the listing that has changed:

    1. Output “Field Name: “, List the field name
    2. If there is a new value and no old value, output “Added: “ and the new value as a sub-bullet
    3. If there is an old value and no new value, output “Deleted: “ and the old value as a sub-bullet
    4. If there are new and old values, output “Changed: “, the old value, “ to: “ and the new value as a sub-bullet

    End of listing reformatting. 

    Group listings  by the combination of program tags.

    Preface each grouping with a list of the associated program tags, followed by the description from OFAC’s program tag web page.  If there is a single program tag, output :OFAC Program:  “, followed by the program tag, 2 spaces, a and its description. If there are multiple program tags, make a bulleted list, with “OFAC Programs:” on the first bullet, and each program tag, 2 spaces, and its description, on a new sub-bullet. Make this italicized.

    Insert two carriage returns between listings 

    End of changes section logic

    Finally, if there is a press chart, output “Press Chart: “, followed by the press chart .  Make the chart image a hyperlink to the press chart URL. Make the whole press chart section an H3 heading.

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  • AI Corner: What OFAC listings look like if you have to explain them to Gemini

    I’ve been working on this for a while – as a learning tool, correcting and refining is more instructive to me than getting a good result and asking for the master prompt.

    A few things to point out:

    • I haven’t run this against aircraft designations “live” yet, so this part might not be precise
    • OFAC doesn’t use any delimiters except for things that can have multiple values, so you don’t know, at a glance, when a field’s label ends and its value begins. I’ve generally steered Gemini by listing all the labels I’ve seen
    • Sometimes OFAC doesn’t break down the data at all – cargo vessel types are immediately followed by the flag state with delimiter (although I guess you could treat the whole thing as a compound data element)
    • OFAC clearly has a bias towards sanctioning entities – why else would there be party types of “aircraft”, “vessel” and “individual”, but nothing for entities?

    Anyhow, here’s the prompt – if you see some logic that will break, let me know:

    OFAC addition or deletion listings are in the following format:

    All OFAC listings finish with the following:

    1. The type of party (Individual, Vessel, Aircraft) in parentheses may be present- if not present, the listing refers to an entity. Entities can also be identified more easily if the section of the OFAC identifies the listings which follow as entities.
    2. After that. a series of OFAC program tags (defined at Information on OFAC sanctions lists program tags and their definitions.),appears, in square brackets – there will always be at least one.
    3. Next, optionally, in parentheses, the text “Linked To:” and other parties with which the listed party is associated, with multiple instances separated by semi-colons
    4. And the listing terminates with a period.

    And the first element in all listings is the primary name.

    The information between the primary name and the party type depends on the party type:

    For entities:

    1. After the primary name, in parentheses, is  an optional series of aliases, prefixed by “a.k.a.” and separated by semicolons
    2. Next, after a comma, are associated addresses, each followed by a semicolon
    3. Next are a series of fields consisting of labels (e.g. Identification Number, Registration number), possibly terminated with a colon (e.g. “Secondary sanctions risk:”), a value, and terminated by a semicolon, except for the last field
    4. The Registration Number field may have subfields such as issuing country (in parentheses) and issue date.
    5. As a reminder, the final field is not terminated by a semi-colon but is followed by the list of program tags, the optional Linked To information and the final period.

    Here is an example: 

    ARIES GLOBAL INVESTMENT LTD (a.k.a. ARIES GLOBAL INVESTMENT LIMITED), Room 2611, 26th Floor, Southeast Technology R&D Center, 438, Jincheng Lu, Xiaoshan Qu, Hangzhou, Zhejiang, China; Rm A 20/F ZJ 300, 300 LOCKHART RD, Wan Chai, Hong Kong, China; Identification Number IMO 0052971; Registration Number 76957722 (Hong Kong) issued 19 Aug 2024 [VENEZUELA-EO13850]. 

    For individuals:

    1. After the primary name, in parentheses, is either a series of aliases, prefixed by “a.k.a.” and separated by semicolons, or a vessel call sign
    2. After a comma, are associated addresses (full address, city and country or country), each followed by a semicolon
    3. Next are a series of fields consisting of labels (e.g. DOB, nationality, Gender, Secondary Sanctions Risk, Cedula, possibly terminated with a colon (e.g. Secondary sanctions risk:), a value, and terminated by a semicolon, except for the last field
    4. As a reminder, the final field is not terminated by a semi-colon but is followed by the party type in parentheses, the list of program tags, the optional Linked To information and the final period.

    Here is an example: 

    ARAYA NAVARRO, Jimena Romina (a.k.a. “ARAYA, Jimena”; a.k.a. “Rosita”), Venezuela; Colombia; DOB 05 Sep 1983; nationality Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Cedula No. 16011070 (Venezuela) (individual) [SDGT] [TCO] (Linked To: TREN DE ARAGUA). 

    For cargo vessels:

    1. After the primary name, optionally, in parentheses, a vessel call sign appears
    2. Next appears a description of the vessel, and the flagging country, with multiple instances separated by semi-colons (and subsequent ones may be preceded by “Other Vessel Flag”
    3. Next are a series of fields consisting of labels (e.g. Year of Build, Identification Number, Registration number, MMSI), possibly terminated with a colon (e.g. Secondary sanctions risk:), a value, and terminated by a semicolon, except for the last field
    4. As a reminder, the final field is not terminated by a semi-colon but is followed by the party type in parentheses, the list of program tags, the optional Linked To information and the final period.

    Here is an example: 

    VALIANT (VRXH3) Crude Oil Tanker Hong Kong flag; Other Vessel Flag China; Vessel Year of Build 2009; Vessel Registration Identification IMO 9409247; MMSI 477206500 (vessel) [VENEZUELA-EO13850] (Linked To: ARIES GLOBAL INVESTMENT LTD).

    For aircraft:

    1. After the primary name, there is a semi-colon
    2. Next are a series of fields consisting of labels (e.g. Manufacture Date, Model, Operator, Manufacturer’s Serial Number (MSN), Tail Number), possibly terminated with a colon (e.g. Secondary sanctions risk:), a value, and terminated by a semicolon, except for the last field
    3. As a reminder, the final field is not terminated by a semi-colon but is followed by the party type in parentheses, the list of program tags, the optional Linked To information and the final period.

    Here is an example: 

    EP-MJG; Aircraft Manufacture Date 2002; Aircraft Model Airbus A340-300; Aircraft Operator Mahan Air; Aircraft Manufacturer’s Serial Number (MSN) 474; Aircraft Tail Number EP-MJG; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 (aircraft) [SDGT] [IFSR] (Linked To: MAHAN AIR). 

    OFAC change listings consist of the old listing, followed by “-to-“, followed by the new listing.

    Take no action on this information until prompted further.

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  • January 2, 2026: OFAC Counter-Narcotics Designation Update

    Counter Narcotics Designation Update

    Amendments:

    The following changes have been made to OFAC’s SDN List:

    OFAC Program: ILLICIT-DRUGS-EO14059 Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade

    DIANA, Cristian

    • Address: Pordenone, Italy
    • DOB: 24 Nov 1971
    • POB: Pordenone, Italy
    • nationality: Italy
    • Gender: Male
    • Passport: YB8215970 (Italy)
    • Tax ID No.: DNICST71S24G888J (Italy)
    • Party Type: Individual
    • Linked to:
      • STILE ITALIANO S.R.L.
      • WINDROSE TACTICAL SOLUTIONS S.R.L.S.

    Supplemental Information: Cristian Diana is an Italian citizen designated for his role as a leader or official of Stile Italiano S.R.L. and Windrose Tactical Solutions S.R.L.S. According to the U.S. Treasury, he is a business associate of Gianluca Tiepolo and serves as president of the board of directors for both companies. These entities are part of a network linked to Ryan James Wedding, a transnational drug trafficker, and were used to launder drug profits and facilitate cartel operations.

    • List of Changes:
      • Field Name: Address
        • Changed: Isernia, Italy to: Pordenone, Italy
      • Field Name: DOB
        • Changed: 03 Oct 1974 to: 24 Nov 1971
      • Field Name: POB
        • Changed: Isernia, Italy to: Pordenone, Italy
      • Field Name: Passport
        • Changed: E619547 (Italy) to: YB8215970 (Italy)
      • Field Name: Tax ID No.
        • Added: DNICST71S24G888J (Italy)

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  • Iran: the sign of the devil?

    Ok, Ok… yes, it’s a controversial title… but you’re reading the post, right? And there is a reason for it, just wait….

    So, there’s been a push over quite a few years to designate quite a few Iranian entities under the OFAC counter-terrorism program. I wondered how many there were, so I asked Gemini.

    The answer: 666 (see what I did there?)

    Now, a few technical things – this was nowhere near the first total I got. I initially asked for a list of parties that had both Iran-related and counter-terrorism-related program tags – and I got back 10 rows. It took a few iterations – and instructions to identify the right tags by looking at the program tag definition page and use all the ones associated with Iran and counter terrorism. But that left me only at 32… which made no sense.

    So, I asked it where it got the data from…

    I sourced the data for the CSV file directly from the examples and information retrieved during our conversation, specifically from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) Recent Actionsupdates we processed together (from December 2025 back to December 2024) and the OFAC Program Tag Definitionspage I accessed.

    To be specific:

    1. Recent Actions Updates: The individuals like Ahmad Ghaedi, Hamidreza Heidari, and the Lashgarian family members were pulled from the February 2024 and December 2025 updates we discussed, where they were designated under both counter-terrorism (SDGT) and Iran-related authorities (IFSR/IRGC).
    2. Established Designations: Major entities like the IRGC, Basij Resistance Force, Mahan Air, and Bank Saderat are historical, well-known dual-designated entities that appear frequently in OFAC’s public enforcement data and were referenced in the “Linked To” fields of the updates we processed.
    3. Program Tag Definitions: I used the official OFAC definitions page (which I accessed in the previous step) to ensure I was capturing the correct codes (e.g., distinguishing that NPWMD is a proliferation tag often used alongside Iran tags, while SDGT and FTO are the specific counter-terrorism tags).

    The dataset I generated was a representative sample constructed from these specific sources to demonstrate the formatting and logic you requested, rather than a direct download of the entire OFAC SDN list database.

    Would you like me to show you how to download the complete and official raw data files directly from the Treasury Department’s website for comprehensive analysis?

    I asked it to go get one of the SDN List files from the OFAC website… and apparently, at my personal use level, it couldn’t do that. Ultimately, I got the file myself and uploaded it to Gemini – that got me to 666.

    Now, for the fun, non-technical piece of the puzzle: did these all fit under what we would consider “terrorists”?

    I cannot provide personal opinions or make subjective determinations about whether specific sanctions designations are “fair” or “unfair,” nor can I definitively conclude which parties meet a common definition of “terrorism” versus those that do not. The designation of entities under counter-terrorism authorities is a legal and policy determination made by the U.S. government based on classified and unclassified intelligence.

    However, I can analyze the publicly stated reasons provided by the U.S. Treasury and State Departments for these designations. This allows you to see the specific activities cited by the government that led to the application of counter-terrorism sanctions (such as SDGT or FTO tags) alongside Iran-related tags.

    Analysis of Designations: Rationale vs. Common Definitions

    The entities in your dataset (those with both Iran-related and Terrorism-related tags) generally fall into three primary categories based on OFAC’s designation criteria:

    1. Direct Terrorist Activity & Support:
      • Entities: IRGC, IRGC-Qods Force, Kata’ib Hizballah, Asa’ib Ahl al-Haq, Hizballah.
      • Stated Rationale: These groups are often designated as Foreign Terrorist Organizations (FTO) or Specially Designated Global Terrorists (SDGT). The U.S. government cites direct involvement in acts of violence, bombings, kidnappings, and military operations outside of Iran (e.g., in Syria, Iraq, Lebanon, Yemen) that target U.S. personnel or civilians.
      • Relation to Definition: These justifications align closely with standard definitions of terrorism involving politically motivated violence against non-combatants.
    2. Financial & Material Support (Facilitators):
      • Entities: Bank Saderat, Bank Mellat, Mehr Eghtesad Bank, Bonyad Taavon Basij, and various investment companies (e.g., Mehr Eghtesad Iranian Investment Company).
      • Stated Rationale: These entities are designated under counter-terrorism authorities (SDGT) not because they commit violent acts themselves, but because they provide “material support” (financial services, funding, logistics) to designated terrorist groups like the IRGC-QF or Hizballah. For example, moving funds to pay fighters or procuring technology for weapons programs.
      • Relation to Definition: While these are banks or investment firms, the “material support” provision in U.S. law allows for their designation under terrorism authorities. A layperson using a strict dictionary definition of “terrorist” (one who commits violence) might view these designations as distinct, but under U.S. sanctions law, financing terrorism is treated with equal severity.
    3. Logistical & Technological Support:
      • Entities: Mahan Air, Caspian Air, various industrial groups (Shahid Hemmat, Shahid Bakeri), and individual procurement agents (e.g., Ghaedi, Heidari).
      • Stated Rationale: Airlines are often designated for transporting personnel and weapons for the IRGC-QF to conflict zones. Industrial groups are designated for developing ballistic missiles or UAVs used by these groups.
      • Relation to Definition: Similar to financial facilitators, these entities are designated for enabling the operations of the primary terrorist groups.

    Summary of the 666 Rows

    • Total Rows: 666
    • “Unfair” Determinations: 0 (As an AI, I cannot label a legal designation as unfair).
    • “Fair” Determinations: 0 (As an AI, I cannot validate the government’s classified intelligence).

    Conclusion based on Public Record:

    Every entity in the dataset has a specific legal basis for its designation published by the U.S. Treasury.

    • Violent Groups: The core groups (IRGC, militias) are designated for direct violent activities.
    • Support Network: The majority of the 666 rows (banks, individuals, companies) are designated for providing support to those core groups.

    Yes, I know it was dumb to ask it if the designation was “fair” – but it did get me to what I wanted to know…

    But the military groups like the IRGC still confused me, so I asked it how that was different from Russia invading Ukraine:

    how are “military operations outside of Iran” considered “terrorism” rather than military operations like the Russian invasion of Ukraine?

    and the response:

    The distinction you are asking about touches on one of the most complex and debated areas of international law and U.S. foreign policy.

    In general, the U.S. government and international law distinguish between “acts of war” (conducted by state militaries) and “terrorism” (conducted by non-state actors).

    The Russian military is considered a state armed force engaged in a conventional (albeit illegal) war, while the IRGC is treated as a “hybrid” entity that uses terrorism as a primary tool of statecraft.

    Here is the detailed breakdown of how the U.S. government makes that legal and policy distinction:

    1. The “Law of War” vs. “Terrorism” Framework

    • State Militaries (Russia): Under the Geneva Conventions and U.S. law, uniformed armed forces of a sovereign state are considered “lawful combatants.” When they cross a border to fight, they are engaging in an armed conflict.
      • If they kill civilians or bomb hospitals, those are War Crimes, not “terrorism.” War crimes have their own set of laws (laws of armed conflict) and tribunals (like the ICC).
      • Why this matters: If a Russian soldier kills a Ukrainian soldier on the battlefield, it is not a crime; it is an act of war. If a terrorist kills a soldier, it is a crime (murder/terrorism) because they have no “combatant privilege.”
    • Terrorist Groups: Terrorism is typically defined in U.S. law (18 U.S. Code § 2331) as violent acts intended to coerce a civilian population or influence a government, usually committed by sub-national groups or clandestine agents.1

    2. The Exception: Why the IRGC is Designated “Terrorist”

    For decades, the standard rule was that state militaries could not be “terrorists.” However, the U.S. designated the Islamic Revolutionary Guard Corps (IRGC) as a Foreign Terrorist Organization (FTO) in 2019—the first time a state entity received this designation.2

    The U.S. justified this exception by arguing that the IRGC operates fundamentally differently from a normal military:

    • Use of Proxies: Unlike the Russian army, which deploys its own uniformed troops to hold territory, the IRGC often exports violence through non-state “proxy” groups (like Hezbollah, Kata’ib Hizballah, or the Houthis). The U.S. views the IRGC as the “handler” for these terrorist organizations.
    • Clandestine Operations: The IRGC-Qods Force specializes in covert assassinations, bombings, and kidnappings outside of defined war zones (e.g., plots in Europe, South America, or the U.S.) rather than conventional battlefield maneuvers.
    • Material Support: The designation focuses heavily on the IRGC funding, training, and equipping designated terrorist groups, making them a “terrorist facilitator” in the eyes of the law.3

    3. Why the Russian Military is Not Designated an FTO

    Despite the documented atrocities in Ukraine, the U.S. has resisted designating the Russian military as a Foreign Terrorist Organization or Russia as a “State Sponsor of Terrorism.”

    • Conventional Warfare: The invasion of Ukraine is viewed as a conventional state-on-state conflict. Even though it is an act of aggression, it fits the legal definition of “war” rather than “terrorism.”
    • Diplomatic & Legal Risks: Designating a state military (especially a nuclear superpower) as a “terrorist organization” creates massive legal complications. It would technically make any U.S. ally who interacts with the Russian military (even for de-confliction in Syria or arms control talks) liable for “providing material support to terrorism.”
    • Existing Tools: The U.S. argues it can already punish Russia effectively using “War Crimes” accusations and massive economic sanctions without needing the “Terrorism” label, which doesn’t fit the legal facts of a conventional invasion.

    Summary Table

    FeatureRussian Invasion of UkraineIRGC External Operations
    Primary ActorUniformed State MilitaryClandestine Operatives & Non-State Proxies
    Legal FrameworkLaw of Armed Conflict (Geneva Conventions)Counter-Terrorism Laws
    Status of Violence“Act of War” / “Aggression”“Terrorism”
    Crimes CommittedWar Crimes / Crimes Against HumanityTerrorist Acts / Material Support for Terror
    U.S. DesignationSanctioned for “Harmful Foreign Activities”Foreign Terrorist Organization (FTO)

    In short: Russia is treated as a “rogue state” fighting a dirty war, while the IRGC is treated as a “terrorist syndicate” hiding inside a state government.

    Despite my expertise in this field, I am still very much a layperson when it comes to the legal & political end of all this stuff. I hope you find these answers interesting and enlightening.

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