Mr. Sanctions

Category: OFAC (US)

  • July 17, 2026: OFAC issues new Venezuela Frequently Asked Question

    It’s FAQ 1263:

    1263. Does General License (GL) 60 require that payments to the Government of Venezuela be made into the Foreign Government Deposit Funds Account (FGDF)?

    Answer

    No. GL 60 authorizes all transactions related to earthquake relief efforts in Venezuela under the Venezuela Sanctions Regulations, which includes payment of taxes, tolls, and fees to the Government of Venezuela connected with such relief efforts. Payments related to earthquake relief that are authorized by GL 60 do not need to be paid into the FGDF.

    However, the requirements under other Venezuela-related GLs, such as GLs 46C, 48B, 49A, 50B, 51B, 52A, and 54A, remain in place. Payments for activities outside of the scope of GL 60 but authorized under other Venezuela-related GLs that contain the FGDF payment requirement must continue to be paid into the FGDF and may not be recharacterized as earthquake relief or otherwise modified for the purpose of avoiding payment into the FGDF.

    Date Released

    July 17, 2026

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  • This Old Blog: Corrections and enhancements

    If you read through LinkedIn or Bluesky auto-posting, you will not have noticed 2 recent changes to existing posts:

    • The post announcing the UN’s new DRC listings was updated to also include Canada’s adoption of the changes the same day
    • And the post that carried the US State Department about the FTO and SDGT designations of La Viagras and the Juarez Cartel mistakenly said it preceded changes by OFAC. In this case, on Wednesday at about 11:20 AM, OFAC did update those two designations, although the title of the Recent Actions post did not say that designations were being updated (yes, technically, an existing ILLICIT DRUGS E.O. was added to the FTO and SDGT programs making them “new” designations). And the State Department notice came out over 25 hours later, at about 12:30 PM yesterday (all times Eastern). My friend Yoshi tells me that this sort of delay, while much larger than typical post-designation PR by State, is typical. You live and you learn, I guess.

    Humblest apologies,

    Mr. Sanctions

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  • July 15, 2026: OFAC adds to non-proliferation and counter-terror sanctions

    Non-Proliferation Designations; Counter Terrorism Designations

    Additions:

    Treasury Press Release: Treasury Targets Global Network Procuring Weapons for Iranian Regime

    State Press Release: Targeting Facilitators of IRGC Weapons Procurement

    The following individuals have been added 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

    DRUZHBIN, Vadim Anatolyevich

    • Address: Russia
    • DOB: 10 May 1987
    • Nationality: Russia
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Tax ID No.: 781699698096 (Russia)
    • Party Type: Individual
    • Linked to: AVRATEK OOO

    Supplemental Information: Druzhbin is a Russian national who, per the Treasury press release, is an employee at Avratek alongside Selina (below) and has coordinated travel for Namazi and Selina; Treasury noted he has previously been involved in coordinating Iranian shipments. He was designated for acting or purporting to act on behalf of Avratek.

    ETTAIB, Dounia

    • Address: Milan, Italy
    • DOB: 27 Apr 1979
    • POB: Casablanca, Morocco
    • Nationality: Italy
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Female
    • Passport: YC7432706 (Italy) expires 24 Sep 2034
    • Party Type: Individual
    • Linked to: NAMAZI, Behrouz

    Supplemental Information: Ettaib, an Italian national based in Milan, is described in the Treasury press release as a knowing participant in efforts to procure weapons for Namazi (below). She was designated for having provided, or attempted to provide, support to Namazi’s procurement efforts.

    NAMAZI, Behrouz (Arabic: بھروز نمازی)

    • AKA: NAMAZI, Behruz
    • Address: Tehran, Iran
    • DOB: 22 Jul 1987
    • POB: Tehran, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: T72756886 (Iran)
    • National ID No.: 0083311688 (Iran)
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    Supplemental Information: Namazi is the general director of Nika Jet Company (below), a Tehran-based provider of aircraft-parts and drone production, distribution, and maintenance services, and per Treasury has sought to secure weapons on behalf of the IRGC. He was designated for having provided, or attempted to provide, support to the IRGC.

    SELINA, Mariya Vladimirovna (Cyrillic: СЕЛИНА, Мария Владимировна)

    • Address: Russia
    • DOB: 17 Feb 1985
    • Nationality: Russia
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Female
    • Passport: 766355168 (Russia)
    • Tax ID No.: 711706408303 (Russia)
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    Supplemental Information: Selina is described by Treasury as a longtime procurement agent for Iran who heads the financial department at Avratek OOO (below), a Moscow-based aviation transportation company, and has supported Namazi’s IRGC-linked procurement efforts. She was designated for having provided, or attempted to provide, support to the IRGC.

    The following entities have been added 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

    AVRATEK OOO

    • Address: Pom. 3/23, D. 39, Str. 80, Prospekt Leningradsky, Moscow 125167, Russia
    • Website: https://avratek.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 06 Dec 2013
    • Tax ID No.: 7715985119 (Russia)
    • Registration Number: 5137746162296 (Russia)
    • Linked to: NAMAZI, Behrouz

    Supplemental Information: Avratek OOO is a Moscow-based aviation transportation company where designated individuals Selina (head of the financial department) and Druzhbin work. Per Treasury, it supported Namazi’s procurement efforts and was designated for having provided, or attempted to provide, support to Namazi.

    NIKA JET COMPANY (Arabic: شرکت نیکا جت)

    • Address:
      • Ground Floor, Falsafi Building, No. 1190, Dr. Ali Shariati St. Falsafi Alley, Davoodiyeh, Tehran 1913633593, Iran
      • Office 102, Floor 10, Almas Tower, Pesiyan St., Moqaddas Ardebili St., Zaferaniyeh, Tehran, Iran
      • Floor 3, No. 370, Mirdamad Boulevard, First Alley, Davoudiyeh, Tehran, Iran
    • Website: http://nikajet.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 18 Jan 2016
    • Organization Type: Manufacture of air and spacecraft and related machinery
    • National ID No.: 14005551194 (Iran)
    • Registration Number: 485863 (Iran)
    • Linked to: NAMAZI, Behrouz

    Supplemental Information: Nika Jet Company is the Tehran-based aircraft-parts and drone production, distribution, and maintenance provider headed by Namazi as general director. It was designated for being owned or controlled by, or acting for or on behalf of, Namazi.

    VANGUARD TACTICAL SUPPLY LIMITED

    • Address: Stallion Estate by Lobito Crescent, Wuse 2, Abuja, Nigeria
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 20 May 2026
    • Registration Number: 9562580 (Nigeria)
    • Linked to: NAMAZI, Behrouz

    Supplemental Information: Vanguard Tactical Supply Limited, based in Abuja, Nigeria and established May 20, 2026, served as an intermediary for Namazi’s procurement efforts, per Treasury, and was designated for having provided, or attempted to provide, support to Namazi.

    Amendments:

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

    OFAC Programs:

    • SDNTK  Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598
    • FTO  Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597
    • SDGT  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
    • ILLICIT-DRUGS-EO14059  Executive Order 14059

    JUAREZ CARTEL

    • AKA:
      • CARTEL DE JUAREZ
      • “BARRIO AZTECA”
      • “CARRILLO FUENTES DRUG TRAFFICKING ORGANIZATION”
      • “LA LINEA”
      • “VCFO”
      • “VICENTE CARRILLO FUENTES ORGANIZATION”
    • Address: Mexico
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Type: Transnational Terrorist Group
    • Target Type: Criminal Organization

    Supplemental Information: This amendment appears tied to a broader State Department effort to designate Mexican drug-trafficking organizations as Foreign Terrorist Organizations. Public reporting indicates Secretary of State Marco Rubio signed a determination on July 2, 2026 adding the Juarez Cartel and Los Viagras (below) to the FTO list, effective July 16, 2026 upon Federal Register publication, and put the cumulative total of Mexican criminal organizations so designated at eight. The Juarez Cartel, also known as the Vicente Carrillo Fuentes Organization, had previously been listed by OFAC only under counter-narcotics authority; today’s amendment adds the FTO and SDGT tags while retaining its existing SDNTK and ILLICIT-DRUGS-EO14059 designations.

    List of Changes:

    • AKA:
      • Added: “BARRIO AZTECA”
      • Added: “VICENTE CARRILLO FUENTES ORGANIZATION”
    • Secondary Sanctions Risk:
      • Added: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Type:
      • Added: Transnational Terrorist Group
    • Target Type:
      • Added: Criminal Organization
    • Program Tags:
      • Added: FTO
      • Added: SDGT

    OFAC Programs:

    • FTO  Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597
    • SDGT  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
    • ILLICIT-DRUGS-EO14059  Executive Order 14059

    LOS VIAGRAS

    • AKA:
      • CARTEL DE LOS VIAGRAS
      • LOS VIAGRAS CARTEL
      • “LOS BLANCOS DE TROYA”
    • Address: Mexico
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 2013
    • Organization Type: Transnational Terrorist Group
    • Target Type: Criminal Organization

    Supplemental Information: As with the Juarez Cartel above, this amendment reflects the same State Department FTO designation action, reportedly effective July 16, 2026. Los Viagras had previously been listed by OFAC only under the ILLICIT-DRUGS-EO14059 program; today’s amendment adds the FTO and SDGT tags.

    List of Changes:

    • AKA:
      • Added: “LOS BLANCOS DE TROYA”
    • Secondary Sanctions Risk:
      • Added: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date:
      • Added: 2013
    • Organization Type:
      • Added: Transnational Terrorist Group
    • Program Tags:
      • Added: FTO
      • Added: SDGT

    Sources consulted beyond the OFAC update page and the Treasury and State press releases:

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  • July 14, 2026: State Department Press Release on Iranian sanctions designations

    Iran: Dismantling Shamkhani’s Illicit Shipping Empire

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, SPOKESPERSON

    JULY 14, 2026

    As part of the United States’ effort to increase pressure on the Iranian regime amid their unlawful attacks on commercial shipping in the Strait of Hormuz, the United States is acting to disrupt and degrade the illicit shipping and sanctions evasion network of U.S.-designated Mohammad Hossein Shamkhani, which serves as a major enabler behind Iran’s oil exports. Today, we are designating more than 50 individuals, entities, and vessels that enable Shamkhani and the Iranian regime to continue profiting while the Iranian people suffer.

    The Shamkhani network relies on a combination of Iranian and foreign nationals and firms to conduct sanctions‑evasion schemes. It also uses offshore shell companies, critical to the network’s ability, to trade sanctioned goods and recover the proceeds of those trades.

    The United States will use all the tools at our disposal to hold the regime accountable for its actions.

    Today’s action is being taken pursuant to Executive Order (E.O.) 13902, which provides authority to the Secretary of the Treasury, in consultation with the Secretary of State, to identify and impose sanctions on key sectors of Iran’s economy. For more information on today’s action, see the Department of the Treasury’s press release.

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  • July 14, 2026: OFAC Update, Part 2: Iran-related General License Z

    Today, OFAC issued another wind-down GL – GL Z (Authorizing Wind Down Activities, Limited Safety and Environmental Transactions, and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on July 14, 2026):

    iran_glzDownload

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  • July 14, 2026: OFAC Update, Part 1: Iran Designations, iran/Counter-terror Designation update

    Iran-related Designations; Iran-related and Counter Terrorism Designation Update; Issuance of Iran-related General License

    Additions:

    Treasury Press Release: Treasury Intensifies Pressure on Shamkhani’s Expansive Illicit Shipping Empire

    Mohammad Hossein Shamkhani, the target of this action, is the son of Ali Shamkhani, a senior political advisor to Iran’s Supreme Leader who was himself sanctioned by the U.S. in 2020. Today’s action brings the total sanctioned under his patronage to more than 200 individuals, entities, and vessels across this and two prior actions (July 2025 and April 2026).

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

    OFAC Program: IRAN-EO13902  Executive Order 13902

    DEHKORDI, Asghar Aghili

    • Address: United Arab Emirates
    • DOB: 21 Feb 1976
    • POB: Shahrekord, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 4621568566 (Iran)
    • Party Type: Individual
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Treasury describes Dehkordi as having served in a strategy role for multiple Shamkhani network companies, including the previously sanctioned Milavous Group Ltd.

    GEORGE, Jijin

    • Address: United Arab Emirates
    • DOB: 16 Jan 1994
    • POB: Trivandrum, India
    • Nationality: India
    • Gender: Male
    • Party Type: Individual
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: George is involved in facilitating the operation of vessels within the Shamkhani fleet and is an employee of the previously sanctioned Teodor Shipping L.L.C.

    KAALUND, Martin Austin

    • AKA: KAALUND, Martin
    • Address: Singapore
    • Address: Dubai, United Arab Emirates
    • DOB: 11 Apr 1973
    • POB: Copenhagen, Denmark
    • Nationality: Denmark
    • Gender: Male
    • Party Type: Individual
    • Linked to: HOUSE OF SHIPPING INVESTMENT FZCO

    Supplemental Information: Kaalund spent years as an executive of the previously sanctioned Shamkhani shipping oversight company House of Shipping Investment FZCO, most recently as its global chief financial officer, and is a co-founder and manager of Dubai-based Evorit Strategy Consulting LLC-FZ.

    MOGHADAS, Behzad (Arabic: بهزاد مقدس)

    • Address: United Arab Emirates
    • Address: Iran
    • DOB: 27 Jul 1987
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Party Type: Individual
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Moghadas is involved in facilitating the operation of vessels within the Shamkhani fleet.

    RAHBAR MADANI, Mohammad Reza

    • Address: Iran
    • DOB: 10 Jun 1973
    • POB: Tehran, Iran
    • Nationality: Iran
    • Alt. Nationality: Dominica
    • Gender: Male
    • Passport: RA020092 (Dominica) expires 29 Apr 2032
    • National ID No.: 0057373078 (Iran)
    • Party Type: Individual
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Madani, along with Zahed (below), worked as a primary financier for the Shamkhani network, providing exchange house services including access to foreign currency and shell companies based outside Iran; Treasury describes both as essential to the network’s ability to trade in sanctioned goods and recoup proceeds. He is the registered owner of Iran-flagged vessel ERIKA, identified as blocked property below.

    RAKHBARMADANI, Ali (Arabic: علي راخبارماداني)

    • AKA: RAHBARMADANI, Ali
    • Address: Dubai, United Arab Emirates
    • Address: Russia
    • DOB: 28 Jan 1975
    • POB: Tehran, Iran
    • Nationality: Iran
    • Alt. Nationality: Russia
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: 516737186 (Russia)
    • Alt. Passport: B97499327 (Iran) expires 29 Feb 2028
    • Party Type: Individual
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: One of Shamkhani’s closest business associates, Rakhbarmadani is linked to the previously sanctioned Koban Shipping L.L.C., Crios Shipping L.L.C., and Marvise SMC DMCC, and owns Al Kina Commercial Broker LLC (designated today). He was deputy CEO of the previously sanctioned Oriel Group before its designation and effectively operated as Shamkhani’s head of shipping, handling network communications with customers and partners. Treasury states he encouraged the Russian side of the network’s trade to evade the price cap on Russian oil following Russia’s invasion of Ukraine.

    RONCO, Alessandra

    • Address: United Arab Emirates
    • DOB: 1980 to 1981
    • POB: Italy
    • Nationality: Italy
    • Gender: Female
    • Party Type: Individual
    • Linked to: EVORIT STRATEGY CONSULTING LLC-FZ

    Supplemental Information: Ronco spent years as an executive of the previously sanctioned House of Shipping Investment FZCO, most recently as its global chief executive officer, and is a co-founder and manager of Evorit Strategy Consulting LLC-FZ (designated today).

    TSERNOSJOV, Maksim

    • Address: United Arab Emirates
    • DOB: 23 Aug 1985
    • Nationality: United Kingdom
    • Gender: Male
    • Passport: 124013929 (United Kingdom)
    • Party Type: Individual
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Treasury identifies Tsernosjov as a senior vessel inspector in Shamkhani’s illicit shipping network.

    VISHAVDEEP, Gautam

    • Address: United Arab Emirates
    • DOB: 27 Jul 1967
    • POB: Ludhiana, India
    • Nationality: India
    • Gender: Male
    • Passport: Z5557980 (India)
    • Party Type: Individual
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Vishavdeep is a manager within the network, facilitating shipments of Iranian oil and coordinating with network partners.

    ZAHED, Hossein Ghorbani

    • AKA: GHORBANIZAHED, Hossein
    • Address: Dubai, United Arab Emirates
    • DOB: 13 Oct 1982
    • POB: Tehran, Iran
    • Nationality: Iran
    • Alt. Nationality: Dominica
    • Gender: Male
    • National ID No.: 0075194953 (Iran)
    • Party Type: Individual
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Zahed, along with Madani, worked as a primary financier for the Shamkhani network. He is the beneficial owner of BVI- and Dubai-based Golden Nest Group Ltd and the director of Dubai-based BSG Management Ltd, both designated today.

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

    OFAC Program: IRAN-EO13902  Executive Order 13902

    AARE LINES INC.

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 17 May 2022
    • Identification Number: IMO 6324125
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner and operator of St. Kitts & Nevis-flagged NADIA, identified as blocked property below.

    AL KINA COMMERCIAL BROKER LLC (Arabic: الكينا للوساطة التجارية ش ذ م م)

    • Address: 1909 and 1901 Burj Khalifa, Bur Dubai, Dubai, United Arab Emirates
    • Organization Established Date: 26 Feb 2019
    • License: 827606 (United Arab Emirates)
    • Chamber of Commerce Number: 316979 (United Arab Emirates)
    • Registration Number: 1395777 (United Arab Emirates)
    • Economic Register Number (CBLS): 11500101 (United Arab Emirates)
    • Linked to: RAKHBARMADANI, Ali

    Supplemental Information: Owned by network associate Ali Rakhbarmadani.

    AVA TARABAR DARYA COMPANY (Arabic: شرکت آوا ترابر دریا)

    • AKA: AVA TARABAR DARYA CO LTD
    • Address: No. 0 Ground Floor, Imam Khomeini Boulevard, Nezami Alley, Post Neighborhood, Khorramshahr, Khouzestan 6415953185, Iran
    • Organization Established Date: 07 Jun 2022
    • National ID No.: 14011215616 (Iran)
    • Identification Number: IMO 6327561
    • Business Registration Number: 3920 (Iran)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner of Iran-flagged SEPEHR PAYAM, part of Shamkhani’s Caspian Sea fleet transporting goods between Iran and Russia; identified as blocked property below.

    BSG MANAGEMENT LTD (Arabic: بي اس جي مانجمنت ليميتد)

    • Address: Unit L-05-28, Level 28, Dubai International Financial Centre, Bur Dubai, Dubai, United Arab Emirates
    • Organization Established Date: 19 Aug 2021
    • License: 4945 (United Arab Emirates)
    • Economic Register Number (CBLS): 11723352 (United Arab Emirates)
    • Linked to: ZAHED, Hossein Ghorbani

    Supplemental Information: Zahed serves as director of this company.

    DEZERA SHIPPING FZCO (Arabic: ديزيرا شيبينج ش م ح)

    • Address: First Floor, Building A2, BCA2 125 Business Cluster, Dubai CommerCity, Dubai, United Arab Emirates
    • Organization Established Date: 08 Jul 2024
    • License: 50420 (United Arab Emirates)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Provides management services, including serving as a billing company, for Shamkhani vessels OPAL and JADE, both identified as blocked property below.

    EVORIT STRATEGY CONSULTING LLC-FZ (Arabic: ايفوريت ستراتيجي كونسالتينج-منطقة حرة ذ م م)

    • Address: 6th Floor, The Meydan Hotel Grandstand, Meydan Road, Nad Al Shiba, Bur Dubai, Dubai, United Arab Emirates
    • Address: M Floor, Business Center 1, Nad Al Shiba, Bur Dubai, Dubai, United Arab Emirates
    • Website: https://evoritglobal.com
    • Organization Established Date: 24 Sep 2025
    • License: 2537797.01 (United Arab Emirates)
    • Linked to: KAALUND, Martin Austin

    Supplemental Information: Co-founded and managed by Kaalund and Ronco, both former House of Shipping executives.

    GLAVOS SHIPPING FZCO (Arabic: غلافوس شيبينج ش م ح)

    • Address: Dubai, United Arab Emirates
    • Organization Established Date: 05 Aug 2024
    • License: 50426 (United Arab Emirates)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: A service provider to the Shamkhani fleet.

    GOLDEN NEST GROUP LTD

    • Address: Boulevard Plaza Tower, 2, Office 2504, Dubai, United Arab Emirates
    • Address: Ellen L Skelton Building, 2nd Floor, Fishers Lane, Road Town, Tortola VG1110, Virgin Islands, British
    • Organization Established Date: 07 Mar 2023
    • Company Number: OE028423 (United Kingdom)
    • Registration Number: 2103334 (Virgin Islands, British)
    • Linked to: ZAHED, Hossein Ghorbani

    Supplemental Information: Zahed is the beneficial owner of this company.

    HANSA SHIPPING INC.

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island, Marshall Islands
    • Organization Established Date: 03 May 2024
    • Identification Number: IMO 0171833
    • Entity Code: 125737 (Marshall Islands)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner of tanker DARIKA, which Treasury says transported cargoes of Russian petroleum products for the network; identified as blocked property below.

    HOPE 1 SHIPPING INC

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 04 Feb 2022
    • Identification Number: IMO 6335884
    • Entity Code: 112970 (Marshall Islands)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner and operator of Antigua and Barbuda-flagged HOPE 1, previously managed and operated by Sai Wan Shipping Limited; identified as blocked property below.

    KANGRI 1 INC

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 06 Dec 2024
    • Identification Number: IMO 0134656
    • Registration Number: 129141 (Marshall Islands)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner and operator of Antigua and Barbuda-flagged CICCIO, identified as blocked property below.

    LUBECK SHIPPING LLC (Arabic: لوبيك للشحن ذ م م)

    • Address: Office No 1-032, Al Garhoud, Deira, Dubai, United Arab Emirates
    • Address: BCB3 119, First Floor, Business Cluster – Building 3, Dubai CommerCity, Dubai, United Arab Emirates
    • Organization Established Date: 31 May 2018
    • Identification Number: IMO 6418449
    • License: 808300 (United Arab Emirates)
    • Chamber of Commerce Number: 305098 (United Arab Emirates)
    • Economic Register Number (CBLS): 11306758 (United Arab Emirates)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner and operator of Palau-flagged GEMMA, identified as blocked property below.

    NUVETRRO SHIPPING INC

    • Address: Building 1, Nelson Spring Business Complex, Nelson Spring, Nevis, Saint Kitts and Nevis
    • Organization Established Date: 2025
    • Identification Number: IMO 0422802
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner and operator of Antigua and Barbuda-flagged JADE, identified as blocked property below.

    OCEAN SEARUM ONE LIMITED

    • Address: Level 54, Hopewell Centre, 183, Queen’s Road East, Wan Chai, Hong Kong, China
    • Organization Established Date: 23 May 2022
    • Identification Number: IMO 6335306
    • Business Registration Number: 74066533 (Hong Kong)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner and operator of Barbados-flagged ELPINIKI (also known as CORN), identified as blocked property below.

    PLATINUM KNIGHTS LTD

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 04 Jan 2024
    • Identification Number: IMO 6505796
    • Entity Code: 123580 (Marshall Islands)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner of tanker VIRENT, which Treasury says transported cargoes of Russian petroleum products for the network; identified as blocked property below.

    SAI WAN SHIPPING LIMITED (Chinese Traditional: 西環船務有限公司)

    • Address: 21/F CMA Building, 64 Connaught Road, Hong Kong, China
    • Organization Established Date: 06 Jul 2018
    • Business Registration Number: 69604477 (Hong Kong)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: One of the network’s shipping firms; previous manager and operator of HOPE 1, ELPINIKI, JADE, and OPAL. As of March 2026, it was part of the previously sanctioned House of Shipping group of companies, alongside Sea Lead Shipping PTE. Ltd. and its subsidiaries.

    SEA LEAD SHIPPING AGENCY INDIA PRIVATE LIMITED

    • Address: C-1102, Godrej Coliseum Near Somaiya Hospital Road, Lokmanya Pan Bazar, Sion (East) Sion, Mumbai 400022, India
    • Organization Established Date: 20 Sep 2022
    • C.I.N.: U63030MH2022FTC390753 (India)
    • Linked to: SEA LEAD SHIPPING PTE. LTD.

    Supplemental Information: An Indian subsidiary of Sea Lead Shipping PTE. Ltd., part of the network’s key containerized shipping operation.

    SEA LEAD SHIPPING DMCC (Arabic: سي ليد شيبينغ م.د.م.س)

    • Address: Unit No 3057, Level 1, Jewellry & Gemplex 3, DMCC Business Centre, New Dubai, Dubai, United Arab Emirates
    • Organization Established Date: 29 Jul 2018
    • License: DMCC-506318 (United Arab Emirates)
    • Business Registration Number: DMCC130391 (United Arab Emirates)
    • Economic Register Number (CBLS): 11469509 (United Arab Emirates)
    • Linked to: SEA LEAD SHIPPING PTE. LTD.

    Supplemental Information: A Dubai-based subsidiary of Sea Lead Shipping PTE. Ltd.; as of March 2026, part of the previously sanctioned House of Shipping group of companies.

    SEA LEAD SHIPPING MARSHALL ISLANDS LTD

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 07 Dec 2021
    • Identification Number: IMO 6275841
    • Residency Number: 112141 (Marshall Islands)
    • Linked to: SEA LEAD SHIPPING PTE. LTD.

    Supplemental Information: A Marshall Islands-based subsidiary of Sea Lead Shipping PTE. Ltd.; as of March 2026, part of the previously sanctioned House of Shipping group of companies.

    SEA LEAD SHIPPING PTE. LTD.

    • Address: 78 Shenton Way, #10 Unit No. 001, Singapore 79120, Singapore
    • Organization Established Date: 28 Mar 2017
    • Identification Number: IMO 6104579
    • Registration Number: 201708559N (Singapore)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: A key containerized shipping firm within the network, managing and operating a fleet carrying goods worldwide; Treasury says it and its subsidiaries, together with Dubai-based Volta Shipping Services LLC, enable the network to carry licit and illicit goods to and from Iran, including to the Houthis in Yemen. Manager and operator of SHENTON WAY, TANJONG PAGAR 1, and PAYA LEBAR, all identified as blocked property below.

    SEPEHR NOOR MOBIN COMPANY (Arabic: شرکت سپهر نور مبین)

    • AKA: SEPEHR NOOR MOBIN SHIPPING CO
    • Address: Unit 3, Level 2, Mellat Tower, Ansari Street, Vali-e Asr Avenue, Tehran 1967713374, Iran
    • Address: Unit 201, 2nd Floor, No. 42, Enghelab Street, 12th Farvardin Street, corner of Nowruz Alley, Tehran 1314694161, Iran
    • Organization Established Date: 20 Dec 2015
    • National ID No.: 14005480093 (Iran)
    • Identification Number: IMO 5920175
    • Registration Number: 484305 (Iran)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owns, operates, and manages Iran-flagged ARKANOOR 2 and ARKANOOR 3, part of Shamkhani’s Caspian Sea fleet; both identified as blocked property below.

    VELTRRIVO SHIPPING INC

    • Address: Building 1, Nelson Spring Business Complex, Nelson Spring, Nevis, Saint Kitts and Nevis
    • Organization Established Date: 2025
    • Identification Number: IMO 0422793
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Owner and operator of Antigua and Barbuda-flagged OPAL, identified as blocked property below.

    VOLTA SHIPPING SERVICES LLC (Arabic: فولتا لخدمات الشحن ذ م م)

    • AKA: VOLTA SHIPPING SERVICES FZCO
    • Address: Office No 1-024, Al Garhoud, Deira, Dubai, United Arab Emirates
    • Address: Business Cluster Building 3 108, Fl 1, Dubai, United Arab Emirates
    • Organization Established Date: 07 Jun 2017
    • Alt. Organization Established Date: 01 Oct 2023
    • License: 784220 (United Arab Emirates)
    • Alt. License: 50335 (United Arab Emirates)
    • Chamber of Commerce Number: 290374 (United Arab Emirates)
    • Registration Number: 1290166 (United Arab Emirates)
    • Economic Register Number (CBLS): 10957213
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Alongside Sea Lead, enables the network to carry licit and illicit goods to and from Iran, including to the Houthis in Yemen.

    WE FREIGHT SHIPPING LLC (Arabic: وي فرايت للشحن ذ م م)

    • AKA:
      • WE FREIGHT INVESTMENT FZCO (Arabic: وي فرايت انفستمنت ش م ح)
      • WE FREIGHT SHIPPING AND LOGISTICS THAILAND LIMITED
      • WEFREIGHT INDIA PRIVATE LIMITED
    • Address: Office No B2007-160, Trade Centre First, Bur Dubai, Dubai, United Arab Emirates
    • Address: BCB3 218, Second Floor, Business Cluster Building 3, Dubai CommerCity, Dubai, United Arab Emirates
    • Address: Unit 711, CTS-266, 266/1-172, Prakashwadi Sale, Village Gundavali, A.K. Road, Chakala Midc, Mumbai, Maharashtra 400093, India
    • Address: 4th, A/409, Ratnakar 9 Square, Mansi Circle Road, Vastrapur, Ahmedabad, Gujarat 380015, India
    • Address: 71 Sukhumvit Road, Soi Sukhumvit 101/1, Phra Khanong 10260, Thailand
    • Website: https://wefreight.com/
    • Organization Established Date: 15 Feb 2016
    • Alt. Organization Established Date: 18 Jul 2019
    • Alt. Organization Established Date: 2022
    • Alt. Organization Established Date: 28 Jun 2022
    • License: 752407 (United Arab Emirates)
    • Alt. License: 18363 (United Arab Emirates)
    • Chamber of Commerce Number: 264431 (United Arab Emirates)
    • Registration Number: 2238929 (United Arab Emirates)
    • Alt. Registration Number: U74999MH2019PTC328229 (India)
    • Alt. Registration Number: 0105565143097 (Thailand)
    • Economic Register Number (CBLS): 10936447 (United Arab Emirates)
    • Alt. Economic Register Number (CBLS): 11905125 (United Arab Emirates)
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: Part of the We Freight group of companies (offices in the UAE, India, and Thailand), providing transportation intermediary services for the network’s container shipping businesses; Treasury says the group allows for the blending of illicit and licit trade, with proceeds from both ultimately benefiting Shamkhani.

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

    OFAC Program: IRAN-EO13902  Executive Order 13902

    ARKANOOR 2 (EPDO3)

    • Vessel Type: General Cargo
    • Vessel Flag: Iran
    • Vessel Year of Build: 1989
    • Vessel Registration Identification: IMO 8727848
    • MMSI: 422075700
    • Party Type: Vessel
    • Linked to: SEPEHR NOOR MOBIN COMPANY

    Supplemental Information: Part of Shamkhani’s Caspian Sea fleet, transporting goods primarily between Iran and Russia.

    ARKANOOR 3 (EPDP9)

    • Vessel Type: General Cargo
    • Vessel Flag: Iran
    • Vessel Year of Build: 1990
    • Vessel Registration Identification: IMO 8832083
    • MMSI: 422077300
    • Party Type: Vessel
    • Linked to: SEPEHR NOOR MOBIN COMPANY

    Supplemental Information: Part of Shamkhani’s Caspian Sea fleet, transporting goods primarily between Iran and Russia.

    CICCIO (V2C2007)

    • Vessel Type: Container Ship
    • Vessel Flag: Antigua & Barbuda
    • Vessel Year of Build: 2000
    • Vessel Registration Identification: IMO 9192442
    • MMSI: 305007400
    • Party Type: Vessel
    • Linked to: KANGRI 1 INC

    Supplemental Information: Part of the Shamkhani containerized fleet.

    DARIKA (3E8661)

    • Vessel Type: Chemical/Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2011
    • Vessel Registration Identification: IMO 9506693
    • MMSI: 352005381
    • Party Type: Vessel
    • Linked to: HANSA SHIPPING INC.

    Supplemental Information: One of two tankers Treasury says transported cargoes of Russian petroleum products for the network.

    ELPINIKI (8PQT)

    • AKA: “CORN”
    • Vessel Type: General Cargo
    • Vessel Flag: Barbados
    • Vessel Year of Build: 2014
    • Vessel Registration Identification: IMO 9606015
    • MMSI: 314159000
    • Party Type: Vessel
    • Linked to: OCEAN SEARUM ONE LIMITED

    Supplemental Information: Previously managed and operated by Sai Wan Shipping Limited.

    ERIKA (EPCL7)

    • Vessel Type: General Cargo
    • Vessel Flag: Iran
    • Vessel Year of Build: 1987
    • Vessel Registration Identification: IMO 8721454
    • MMSI: 422049900
    • Party Type: Vessel
    • Linked to: RAHBAR MADANI, Mohammad Reza

    Supplemental Information: Part of Shamkhani’s Caspian Sea fleet, owned by network financier Mohammad Reza Rahbar Madani.

    GEMMA (T8A3035)

    • Vessel Type: General Cargo
    • Vessel Flag: Palau
    • Vessel Year of Build: 2011
    • Vessel Registration Identification: IMO 9509097
    • MMSI: 511873000
    • Party Type: Vessel
    • Linked to: LUBECK SHIPPING LLC

    Supplemental Information: Part of the Shamkhani containerized fleet.

    HOPE 1 (V2C2008)

    • Vessel Type: Bulk Carrier
    • Vessel Flag: Antigua and Barbuda
    • Vessel Year of Build: 2012
    • Vessel Registration Identification: IMO 9514339
    • MMSI: 305008400
    • Party Type: Vessel
    • Linked to: HOPE 1 SHIPPING INC

    Supplemental Information: Previously managed and operated by Sai Wan Shipping Limited.

    JADE (V2C2005)

    • Vessel Type: General Cargo
    • Vessel Flag: Antigua and Barbuda
    • Vessel Year of Build: 2010
    • Vessel Registration Identification: IMO 9418999
    • MMSI: 305005400
    • Party Type: Vessel
    • Linked to: NUVETRRO SHIPPING INC

    Supplemental Information: Previously managed and operated by Sai Wan Shipping Limited; Dezera Shipping FZCO provides management services, including billing, for this vessel.

    NADIA (V4CL4)

    • Vessel Type: Container Ship
    • Vessel Flag: St Kitts & Nevis
    • Vessel Year of Build: 1997
    • Vessel Registration Identification: IMO 9122461
    • MMSI: 341765000
    • Party Type: Vessel
    • Linked to: AARE LINES INC.

    Supplemental Information: Part of the Shamkhani containerized fleet.

    OPAL (V2C2006)

    • Vessel Type: General Cargo
    • Vessel Flag: Antigua and Barbuda
    • Vessel Year of Build: 2012
    • Vessel Registration Identification: IMO 9467158
    • MMSI: 305006400
    • Party Type: Vessel
    • Linked to: VELTRRIVO SHIPPING INC

    Supplemental Information: Previously managed and operated by Sai Wan Shipping Limited; Dezera Shipping FZCO provides management services, including billing, for this vessel.

    PAYA LEBAR (V2C2003)

    • Vessel Type: Container Ship
    • Vessel Flag: Antigua & Barbuda
    • Vessel Year of Build: 1997
    • Vessel Registration Identification: IMO 9134232
    • MMSI: 305003400
    • Party Type: Vessel
    • Linked to: SEA LEAD SHIPPING PTE. LTD.

    Supplemental Information: Managed and operated by Sea Lead Shipping PTE. Ltd.

    SEA ANCHOR

    • Vessel Type: General Cargo
    • Vessel Flag: Unknown
    • Former Vessel Flag: Palau
    • Vessel Year of Build: 1984
    • Vessel Registration Identification: IMO 8858099
    • Party Type: Vessel
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: One of four vessels with undisclosed ownership and unknown flag state that Treasury says are known to operate for Shamkhani directly.

    SEA CASTLE

    • Vessel Type: General Cargo
    • Vessel Flag: Unknown
    • Former Vessel Flag: Palau
    • Vessel Year of Build: 1983
    • Vessel Registration Identification: IMO 8891572
    • Party Type: Vessel
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: One of four vessels with undisclosed ownership and unknown flag state that Treasury says are known to operate for Shamkhani directly.

    SEA CRUISER

    • Vessel Type: General Cargo
    • Vessel Flag: Unknown
    • Former Vessel Flag: Palau
    • Vessel Year of Build: 1989
    • Vessel Registration Identification: IMO 8729963
    • Party Type: Vessel
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: One of four vessels with undisclosed ownership and unknown flag state that Treasury says are known to operate for Shamkhani directly.

    SEA GALLEON

    • Vessel Type: General Cargo
    • Vessel Flag: Unknown
    • Former Vessel Flag: Palau
    • Vessel Year of Build: 1990
    • Vessel Registration Identification: IMO 8843666
    • Party Type: Vessel
    • Linked to: SHAMKHANI, Mohammad Hossein

    Supplemental Information: One of four vessels with undisclosed ownership and unknown flag state that Treasury says are known to operate for Shamkhani directly.

    SEPEHR PAYAM (EPCU9)

    • Vessel Type: Container Ship
    • Vessel Flag: Iran
    • Vessel Year of Build: 1995
    • Vessel Registration Identification: IMO 9110535
    • MMSI: 422058200
    • Party Type: Vessel
    • Linked to: AVA TARABAR DARYA COMPANY

    Supplemental Information: Part of Shamkhani’s Caspian Sea fleet, transporting goods primarily between Iran and Russia.

    SHENTON WAY (3E8302)

    • Vessel Type: Container Ship
    • Vessel Flag: Panama
    • Vessel Year of Build: 1998
    • Vessel Registration Identification: IMO 9146314
    • MMSI: 352005129
    • Party Type: Vessel
    • Linked to: SEA LEAD SHIPPING PTE. LTD.

    Supplemental Information: Managed and operated by Sea Lead Shipping PTE. Ltd.

    TANJONG PAGAR 1 (3E8523)

    • Vessel Type: Container Ship
    • Vessel Flag: Panama
    • Vessel Year of Build: 2007
    • Vessel Registration Identification: IMO 9404508
    • MMSI: 352006054
    • Party Type: Vessel
    • Linked to: SEA LEAD SHIPPING PTE. LTD.

    Supplemental Information: Managed and operated by Sea Lead Shipping PTE. Ltd.

    VIRENT (3E3834)

    • Vessel Type: Chemical/Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2007
    • Vessel Registration Identification: IMO 9332171
    • MMSI: 352002167
    • Party Type: Vessel
    • Linked to: PLATINUM KNIGHTS LTD

    Supplemental Information: One of two tankers Treasury says transported cargoes of Russian petroleum products for the network.

    Amendments:

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

    OFAC Programs:

    • IRAN  Iranian Transactions and Sanctions Regulations, 31 CFR part 560
    • SDGT  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
    • IRGC  Iranian Financial Sanctions Regulations, 31 CFR Part 561
    • IFSR  Iranian Financial Sanctions Regulations, 31 CFR part 561

    BANK MARKAZI JOMHOURI ISLAMI IRAN

    • AKA:
      • BANK MARKAZI IRAN
      • CENTRAL BANK OF IRAN
      • CENTRAL BANK OF THE ISLAMIC REPUBLIC OF IRAN (Arabic: بانک مرکزی جمهوری اسلامی ایران)
    • Address: PO Box 15875/7177, 144 Mirdamad Blvd, Tehran, Iran
    • Address: 213 Ferdowsi Avenue, Tehran 11365, Iran
    • Address: Mirdamad Blvd, 144 – P.O. Box 15875/7/77, Tehran, Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Digital Currency Address – TRX: TNiq9AXBp9EjUqhDhrwrfvAA8U3GUQZH81
    • Alt. Digital Currency Address – TRX: TTiDLWE6fZK8okMJv6ijg42yrH6W2pjSr9
    • Alt. Digital Currency Address – TRX: TAhwhFv3JpK39Nc2m8W5LPCcoTisutiRfp
    • Alt. Digital Currency Address – TRX: TJdgB1k6ot3f2nLuZug6D8eD3HavTmzmSK
    • Alt. Digital Currency Address – TRX: TXGHxdYbGy574z5hBu4LNzq9NzjZQ9bhUf
    • Alt. Digital Currency Address – TRX: TFQbqaNbmq2xsVor2NbufLkYZvxFC9wC7k
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE
    • Linked to: HIZBALLAH

    Supplemental Information: Neither of today’s two source documents discusses this amendment; it is not part of the Shamkhani action and appears to be a routine addition of newly identified digital currency addresses to Iran’s central bank, already on the SDN List.

    List of Changes:

    • Field Name: Alt. Digital Currency Address – TRX
      • Added: TAhwhFv3JpK39Nc2m8W5LPCcoTisutiRfp
    • Field Name: Alt. Digital Currency Address – TRX
      • Added: TJdgB1k6ot3f2nLuZug6D8eD3HavTmzmSK
    • Field Name: Alt. Digital Currency Address – TRX
      • Added: TXGHxdYbGy574z5hBu4LNzq9NzjZQ9bhUf
    • Field Name: Alt. Digital Currency Address – TRX
      • Added: TFQbqaNbmq2xsVor2NbufLkYZvxFC9wC7k

    Sources (beyond the update and press release PDFs):

    —

    , , ,

  • July 10, 2026: OFAC Update, Part 2: the Designations

    Iran-related and Counter Terrorism Designations; Issuance of Iran-related General License

    Treasury Press Release: Treasury Targets Key Supreme Leader Financier and Iran’s Shadow Exchange Houses

    State Press Release: U.S. Squeezes Iran’s Regime Financiers and Shadow Banking Networks

    Additions:

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

    OFAC Program: IRAN-EO13902  Executive Order 13902

    ABADI, Shokufeh Rostam

    • Arabic Name: شکوفه رستم آبادی
    • AKA: ROSTAMABADI, Shokoofeh
    • Address: Iran
    • DOB: 22 May 1956
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Female
    • National ID No.: 0491083157 (Iran)
    • Party Type: Individual
    • Linked to: Mohammad Darbani and Partners Exchange General Partnership Company

    Supplemental Information: Per Treasury’s release, Rostam Abadi serves as chief executive officer of Mohammad Darbani and Partners Exchange General Partnership Company, one of three Iran-based currency exchange houses – family-run “general partnership” companies – that Treasury describes as collectively moving billions of dollars annually on behalf of sanctioned Iranian banks. As of early 2026, the exchange held tens of millions of dollars in foreign currency on behalf of its sanctioned Iranian bank customers.

    DARBANI, Mohammad

    • Arabic Name: محمد دربانی
    • Address: Iran
    • DOB: 15 Jul 1946
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 0491004435 (Iran)
    • Party Type: Individual
    • Linked to: Mohammad Darbani and Partners Exchange General Partnership Company

    Supplemental Information: Per Treasury’s release, Darbani is chairman of the board of directors of Mohammad Darbani and Partners Exchange General Partnership Company, which has facilitated transactions moving hundreds of millions of dollars in foreign currency on behalf of sanctioned Iranian banks over the last several years.

    KHANDAN, Ali Asghar

    • Arabic Name: علی اصغر خندان
    • Address: Shiraz, Iran
    • DOB: 08 Aug 1958
    • POB: Estahban, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 2529610525 (Iran)
    • Party Type: Individual
    • Linked to: Mohsen Khandan and Partners General Partnership Company

    Supplemental Information: Per Treasury’s release, Ali Asghar Khandan is the only other partner and a board member of Mohsen Khandan and Partners General Partnership Company, alongside CEO Mohsen Khandan. The exchange has contracted with sanctioned Iranian banks including Parsian Bank, Export Development Bank, Bank Saderat, Bank Sepah, Sina Bank, Karafarin Bank, Saman Bank, and Tejarat Bank, and held over $117 million in foreign currency on behalf of sanctioned Iranian banks.

    KHANDAN, Mohsen

    • Arabic Name: محسن خندان
    • Address: Shiraz, Iran
    • DOB: 10 Aug 1985
    • Nationality: Iran
    • Alt. Nationality: Dominica
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: R0107863 (Dominica)
    • National ID No.: 2529897204 (Iran)
    • Party Type: Individual
    • Linked to: Mohsen Khandan and Partners General Partnership Company

    Supplemental Information: Per Treasury’s release, Khandan is CEO of Mohsen Khandan and Partners General Partnership Company, which held over $117 million in foreign currency on behalf of sanctioned Iranian banks including Parsian Bank, Export Development Bank, Bank Saderat, Bank Sepah, Sina Bank, Karafarin Bank, Saman Bank, and Tejarat Bank.

    LAVASANI, Ahmad Navai

    • Arabic Name: احمد نوائی لواسانی
    • AKA: LAVASANI, Ahmad Navaei
    • Address: Iran
    • DOB: 27 Jul 1972
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 0056443005 (Iran)
    • Party Type: Individual
    • Linked to: Lavasani and Partners General Partnership Company

    Supplemental Information: Per Treasury’s release, Ahmad Navai Lavasani is CEO of Lavasani and Partners General Partnership Company, which has contracted with sanctioned Iranian banks including Bank Melli, Bank Saderat, Sina Bank, Shahr Bank, Eghtesad Novin Bank, Tourism Bank, Bank Pasargad, and Bank Mellat. As of early 2026, the exchange held hundreds of millions of dollars in foreign currency on behalf of its sanctioned Iranian bank customers.

    LAVASANI, Amir Navai

    • Arabic Name: امیر نوائی لواسانی
    • Address: Iran
    • DOB: 06 Sep 1970
    • POB: Tehran, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: K54424834 (Iran) expires 06 Sep 2026
    • National ID No.: 0054082951 (Iran)
    • Party Type: Individual
    • Linked to: Lavasani and Partners General Partnership Company

    Supplemental Information: Per Treasury’s release, Amir Navai Lavasani is chairman of the board of directors of Lavasani and Partners General Partnership Company.

    SARSHARI, Zahra

    • Arabic Name: زھرا سرشاری
    • Address: Iran
    • DOB: 22 Dec 1961
    • POB: Shiraz, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Female
    • National ID No.: 2297395132 (Iran)
    • Party Type: Individual
    • Linked to: Mohammad Darbani and Partners Exchange General Partnership Company

    Supplemental Information: Per Treasury’s release, Sarshari is a board member of Mohammad Darbani and Partners Exchange General Partnership Company.

    OFAC Programs:

    • SDGT  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
    • IRGC  Iranian Financial Sanctions Regulations, 31 CFR Part 561
    • IFSR  Iranian Financial Sanctions Regulations, 31 CFR part 561
    • IRAN-EO13876  Executive Order 13876

    ANSARI, Ali

    • Arabic Name: علی انصاری
    • AKA: ANSARI, Ali Ali Akbar
    • Address: Dubai, United Arab Emirates
    • DOB: 26 Dec 1968
    • POB: Ghazvin, Iran
    • Nationality: Iran
    • Alt. Nationality: Saint Kitts and Nevis
    • Alt. Nationality: Cyprus
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: B65348454 (Iran)
    • Alt. Passport: M54968815 (Iran) expires 27 Nov 2026
    • Alt. Passport: L00017629 (Cyprus)
    • Alt. Passport: RE0036662 (Saint Kitts and Nevis)
    • National ID No.: 4320705718 (Iran)
    • Party Type: Individual
    • Linked to:
      • KHAMENEI, Mojtaba
      • ISLAMIC REVOLUTIONARY GUARD CORPS

    Supplemental Information: Treasury’s release describes Ansari as a Dubai-based Iranian financial facilitator who oversees a global network of assets benefiting Supreme Leader Mojtaba Khamenei and other regime elites, and identifies him as the former owner and director of the now-defunct Ayandeh Bank, using that position to overextend loans and embezzle from the Iranian people before the Iranian government forced the bank’s dissolution in mid-October 2025. Using shell companies and bank accounts across multiple jurisdictions, Ansari built a portfolio – held through Smart Global Limited – of real estate and commercial holdings in Germany, Luxembourg, Spain, the United Kingdom, Cyprus, and the UAE, among other locations, benefiting Khamenei, his family, and other regime and IRGC figures. Ansari is designated pursuant to E.O. 13876 for materially assisting Khamenei, and pursuant to E.O. 13224, as amended, for acting on behalf of the IRGC. Treasury notes the action follows Iran’s resumption of attacks on international shipping in the Strait of Hormuz.

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

    OFAC Program: IRAN-EO13902  Executive Order 13902

    CDM TRADING LIMITED

    • Address: Rm23, 7/F Lee on Industrial Building No. 70 Hung To Rd, Kowloon, Hong Kong, China
    • Organization Established Date: 21 Jan 2022
    • Company Number: 3123352 (Hong Kong)
    • Business Registration Number: 73747617 (Hong Kong)

    Supplemental Information: Per Treasury’s release, CDM Trading Limited is a Hong Kong-based front company used to conduct financial transactions by multiple Iranian exchange houses, including Mohsen Khandan and Partners General Partnership Company.

    LAVASANI AND PARTNERS GENERAL PARTNERSHIP COMPANY

    • Arabic Name: شرکت تضامنی لواسانی و شرکاء
    • AKA:
      • LAVASANI AND PARTNERS COMPANY (Arabic: شرکت لواسانی و شرکاء)
      • LAVASANI AND PARTNERS EXCHANGE (Arabic: صرافی لواسانی و شرکاء)
      • SABZEH MEYDAN EXCHANGE
    • Address: Ground Floor, Iranian Gold and Coin Shopping Center Building, Number 820, Sabzeh Meydan Square, Bazaar Auction Alley, Bazaar, Tehran, Tehran 1161766113, Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 31 Aug 2005
    • National ID No.: 10102943860 (Iran)
    • Registration Number: 253979 (Iran)

    Supplemental Information: Per Treasury’s release, this Tehran-based exchange house is controlled by partners Ahmad Navai Lavasani (CEO) and Amir Navai Lavasani (chairman), and has contracted with sanctioned Iranian banks Bank Melli, Bank Saderat, Sina Bank, Shahr Bank, Eghtesad Novin Bank, Tourism Bank, Bank Pasargad, and Bank Mellat. As of early 2026 it held hundreds of millions of dollars in foreign currency on behalf of its sanctioned Iranian bank customers, and it is designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.

    MOHAMMAD DARBANI AND PARTNERS EXCHANGE GENERAL PARTNERSHIP COMPANY

    • Arabic Name: شرکت تضامنی صرافی محمد دربانی و شرکاء
    • AKA: MOHAMMAD DARBANI AND PARTNERS EXCHANGE COMPANY (Arabic: شرکت صرافی محمد دربانی و شرکاء)
    • Address: Ground Floor, No. 2, Ziba Dead End, Shahid Baradaran Jozi Street, Ekhtiariyeh Neighborhood, Tehran, Tehran 1951876364, Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 28 May 2016
    • National ID No.: 14005872174 (Iran)
    • Registration Number: 492428 (Iran)

    Supplemental Information: Per Treasury’s release, this Tehran-based exchange house is controlled by partners Mohammad Darbani (chairman), Shokufeh Rostam Abadi (CEO), and Zahra Sarshari (board member). As of early 2026 it held tens of millions of dollars in foreign currency on behalf of its sanctioned Iranian bank customers and has facilitated transactions moving hundreds of millions of dollars over the last several years; it is designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.

    MOHSEN KHANDAN AND PARTNERS GENERAL PARTNERSHIP COMPANY

    • Arabic Name: شرکت تضامنی محسن خندان و شرکا
    • AKA:
      • KHANDAN EXCHANGE
      • MOHSEN KHANDAN AND PARTNERS COMPANY
    • Address: Ground Floor, No. 0, Shahid Rajaee Boulevard (54 Shahid Rajaee), Baharan Alley 8, Moali Abad, Shiraz, Fars 7187611451, Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 09 Jan 2017
    • National ID No.: 14006482791 (Iran)
    • Registration Number: 45635 (Iran)

    Supplemental Information: Per Treasury’s release, this Shiraz-based exchange house is controlled by partners Mohsen Khandan (CEO) and Ali Asghar Khandan (board member), has contracted with sanctioned Iranian banks Parsian Bank, Export Development Bank, Bank Saderat, Bank Sepah, Sina Bank, Karafarin Bank, Saman Bank, and Tejarat Bank, and holds over $117 million in foreign currency on behalf of sanctioned Iranian banks. Hong Kong-based CDM Trading Limited and UAE-based Naba Alzaki Raw Materials Trading LLC have both been used as front companies by this exchange house, the latter as part of what Treasury describes as Iran’s “rahbar” network.

    NABA ALZAKI RAW MATERIALS TRADING LLC

    • Address: Dubai, United Arab Emirates
    • Organization Established Date: 20 Aug 2024
    • Commercial Registry Number: 2369427 (United Arab Emirates)
    • License: 1390462 (United Arab Emirates)

    Supplemental Information: Per Treasury’s release, this UAE-based company is a front company used by Mohsen Khandan and Partners General Partnership Company as part of Iran’s “rahbar” network.

    OFAC Programs:

    • SDGT  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
    • IRAN-EO13876  Executive Order 13876

    SMART GLOBAL LIMITED

    • AKA: ZIBA LEISURE LIMITED
    • Address: Charlestown, Saint Kitts and Nevis
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 20 Oct 2011
    • Organization Type: Activities of holding companies
    • Registration Number: C39335 (Saint Kitts and Nevis)
    • Linked to: ANSARI, Ali

    Supplemental Information: Per Treasury’s release, Smart Global Limited is a Saint Kitts and Nevis-based holding company established in 2011 under the former name Ziba Leisure Limited, through which Ansari invested Iranian public funds into real estate and commercial holdings across Germany, Luxembourg, Spain, the United Kingdom, Cyprus, and the UAE. The company is designated pursuant to E.O. 13876 and E.O. 13224, as amended, for being owned or controlled by, or for acting on behalf of, Ali Ansari.

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  • July 13, 2026: OFAC Update, Part 2: New OFAC Cuba-related Frequently Asked Question

    It’s FAQ 1262:

    1262. On July 13, 2026, the Department of State designated the Cuban entities Grupo Empresarial del Comercio Exterior (GECOMEX) and Grupo Empresarial de Transporte Marítimo Portuario (GEMAR) pursuant to E.O. 14404. Are non-U.S. persons, including foreign financial institutions (FFIs), exposed to sanctions risk for winding down transactions with GECOMEX or GEMAR? 

    The U.S. government does not intend to target non-U.S. persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, through August 12, 2026. However, non-U.S. persons, including FFIs, should proceed with caution in any dealings with a party sanctioned under this authority. Actions to return assets to GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, or transfer such assets to another jurisdiction could expose non-U.S. persons to significant sanctions risk.

    Non-U.S. persons unable to wind down transactions involving GECOMEX, GEMAR, or any entity in which either GECOMEX or GEMAR owns, directly or indirectly, a 50 percent or greater interest, before August 12, 2026, are encouraged to contact the OFAC Compliance Hotline.

    Persons subject to U.S. jurisdiction, including U.S. entities owned or controlled by U.S. persons, have long been prohibited pursuant to the Cuban Assets Control Regulations (CACR), 31 CFR part 515, from transacting with GECOMEX and GEMAR, absent OFAC authorization. Accordingly, persons subject to U.S. jurisdiction continue to be prohibited from engaging in transactions involving GECOMEX or GEMAR, including in connection with a non-U.S. person’s wind down of activities with GECOMEX or GEMAR, unless separately authorized by OFAC. Relevant authorizations may include humanitarian-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1. For additional information on GL 1, see FAQ 1253.

    Released on Jul 13, 2026

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  • July 13, 2026: OFAC Update, Part 1: Cuba and Cyber Designations

    Cyber-related Designations; Cuba Designations; Issuance of Cuba-related Frequently Asked Question

    Additions:

    Treasury Press Release: Treasury Sanctions Malware and Infrastructure Providers Supporting Ransomware Attacks Against Americans

    State Press Release: Sanctioning Ransomware Enablers in Coordinated International Action

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

    OFAC Program: CYBER4  Executive Order 13694; Executive Order 13757; Executive Order 14144; Executive Order 14306

    RASHEVSKYI, Dmytro

    • AKA:
      • CHABANENKO, Roman
      • RASHEVSKY, Dmitry
      • SORIN, Maksim
      • “JOBBERJOBBER777”
      • “JOHNYW255”
      • “RASHDV7”
      • WALKER, Johny
    • Address: Dnipro, Ukraine
    • DOB: 05 Jan 1981
    • Nationality: Ukraine
    • Gender: Male
    • Digital Currency Address – XBT: 1MTndG4K51RRMvkzyvguaHnQpiMLnxFGzM
    • Alt. Digital Currency Address – XBT: 1DfyWkiXVVqWfcSduj23qTDis9kb2qvRDa
    • Digital Currency Address – ETH: 0x1d19b52b54e7ef5ea1a4b40b616165e798eac9f8
    • Alt. Digital Currency Address – ETH: 0x2C7DcD774b33e10367F7d6385479e04F97d179dc
    • Digital Currency Address – LTC: LcP1DumXkNJbBtSYD3XxAfsJ2nZR5hLdpM
    • Alt. Digital Currency Address – LTC: LbPAqHvemZBv3pvAqiAtDnZ3U1t6EziaL1
    • Digital Currency Address – ZEC: t1LHesgnkapziGQCJtrfZWYXhyjfTVo1dvh
    • Digital Currency Address – DASH: XcuGqRfrR85zyDrzVr1gSL5RNjwwpbu2KS
    • Alt. Digital Currency Address – DASH: XowUeMFa1FkEUnAHL78E5oqpezMfSB6xP1
    • Digital Currency Address – TRX: TTLRNgLpz5H5tLPuNU4FViUs7zmmAtyvzW
    • Alt. Digital Currency Address – TRX: TBFW9gF4oDX5cG44gS7AoxQeujScmm3z6h
    • Digital Currency Address – DOGE: DHzAVdEoL3PjGeLWNdEJwwMA1CeQ9J9Cpo
    • Alt. Digital Currency Address – DOGE: DTqpKQ96rqkTvHcohQQd9BksmgRjasHgGo
    • Digital Currency Address – SOL: Fc1EwQUZyTEagaDvA1utHXCcZNyG1x2PLt2DfNu1cJdH
    • Alt. Digital Currency Address – SOL: FuCC7GoYwt5TsNTjWL23Xx9UKCvC18chjMEFPL3vJDCC
    • Passport: FG819665 (Ukraine)
    • Party Type: Individual

    Supplemental Information: Rashevskyi is the administrator of First VPN Service (1VPNS). Treasury states he used the false identities above (“Maksim Sorin,” “Roman Chabanenko”) specifically to acquire infrastructure from providers who might otherwise have declined to do business with him, given abuse complaints already on file about illegal activity traced to 1VPNS servers.

    SILAYEV, Yevgeniy Vladimirovich

    • AKA: SILAYEU, Yauheni
    • Address: Pestraa iela 8-7, Grodno, Belarus
    • DOB: 09 Nov 2000
    • Nationality: Belarus
    • Gender: Male
    • Passport: KH3188588 (Belarus) expires 04 May 2033
    • Party Type: Individual

    Supplemental Information: Silayev, a Belarusian national, supplied “cryptor” encryption and obfuscation services to ransomware operators targeting the U.S. and its allies. Treasury distinguishes cryptors from legitimate encryption tools: rather than protecting user data, they’re built specifically to disguise malware as harmless files so security software fails to flag it. Reporting from The Record indicates Silayev has no affiliation with First VPN Service; his designation reflects a separate contribution to the same ransomware-enabling ecosystem.

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

    OFAC Program: CYBER4  Executive Order 13694; Executive Order 13757; Executive Order 14144; Executive Order 14306

    FIRST VPN SERVICE

    • AKA:
      • 1VPNS
      • FIRSTVPN
      • “FVPNS”
    • Address: Dnipro, Ukraine
    • Website: 1vpns.com
    • Alt. Website: 1vpns.net
    • Alt. Website: 1vpns.org
    • Alt. Website: 1jabber.com
    • Alt. Website: t.me/FirstVPNService
    • Email Address: support@1vpns.com
    • Digital Currency Address – XBT: bc1qdnr88f4d2yqunnc4mjsguezm6g3mlwe44z5dw8
    • Alt. Digital Currency Address – XBT: bc1qr4ankqmvmrhce3ydvzse86dfx5s3zhehfr9tg9
    • Digital Currency Address – ETH: 0x2711d73d559f62f4f855ee21f38378f528e07985
    • Digital Currency Address – LTC: ltc1qr8ntsedq8tv0svmxqhzvdcdl5k7kntdmnhwep7
    • Organization Established Date: Oct 2014
    • Organization Type: Computer programming activities
    • Digital Currency Address – TRX: TUuaxBAWfA5nmsqNfycxYrzEvz4a5GJMGY

    Supplemental Information: 1VPNS is a VPN provider whose principal clients include ransomware groups and other cybercriminals; per Treasury, its infrastructure was used to hide attack origins, deploy malware, and manage exfiltrated data, with victims including U.S. businesses, financial services firms, hospitals, and municipal governments. It advertised on cybercriminal forums (identified by the FBI as Exploit and XSS) since 2014, marketing itself on a no-logs policy and refusal to cooperate with law enforcement. An FBI Flash advisory issued May 21, 2026 puts the service at roughly 32 exit-node servers across 27 countries, used by at least 25 ransomware groups (including Avaddon Ransomware) for reconnaissance, scanning, botnet activity, and denial-of-service operations. European law enforcement dismantled 1VPNS’s website and infrastructure in May 2026 with support from the FBI’s Boston Field Office; this action was coordinated with the UK’s Foreign, Commonwealth & Development Office, which sanctioned other cyber actors the same day.

    State Fact Sheet: Further Sanctions on the Cuban Regime’s Sources of Funding and Tools of Oppression

    OFAC Program: CUBA-EO14404  Executive Order 14404

    ASSOCIATION OF COMBATANTS OF THE CUBAN REVOLUTION

    • AKA:
      • ASOCIACION DE COMBATIENTES DE LA REVOLUCION CUBANA
      • “ACRC”
    • Address: Havana, Cuba
    • Organization Established Date: 07 Dec 1993
    • Party Type: Civil Society Organization

    Supplemental Information: Designated under Sec. 2(a)(i)(B) of E.O. 14404 for being owned or controlled by, or acting on behalf of, the Cuban government. State describes ACRC as a social and paramilitary organization overseen by Cuba’s Ministry of the Revolutionary Armed Forces (MINFAR, already designated) that conducts surveillance of dissidents at the direction of Cuba’s Ministry of the Interior.

    COREYDAN S.A.

    • Address: Havana, Cuba
    • Organization Established Date: 19 Feb 2020
    • Organization Type: Wholesale of solid, liquid and gaseous fuels and related products
    • Entity Code: 60637 (Cuba)

    Supplemental Information: Designated under Sec. 2(a)(i)(A) for operating in the energy sector of the Cuban economy. State identifies it as a Cuban state-owned entity engaged in importing solid, liquid, and gaseous fuels and related products.

    CORPORACION ANTILLANA EXPORTADORA SA

    • AKA:
      • ANTEX EXPORTING CORPORATION S.A.
      • ANTEX S.A.
      • ANTILLEAN EXPORTER PLC
      • CORPORACION ANTEX, S.A.
      • CORPORACION COMERCIAL ANTEX, S.A.
    • Address: Havana, Cuba
    • Organization Established Date: 01 Jan 1998
    • Organization Type: Management consultancy activities
    • Party Type: State-Owned Enterprise
    • Entity Code: 60245 (Cuba)
    • Linked to: GRUPO DE ADMINISTRACION EMPRESARIAL S.A.

    Supplemental Information: Designated under Sec. 2(a)(i)(B) for being owned or controlled by, or acting on behalf of, Cuba’s GAESA (Grupo de Administracion Empresarial S.A.), a person already blocked under E.O. 14404. State identifies ANTEX S.A. as the Cuban state-owned entity managing the export of Cuban forced labor to Angola.

    ENETEC S.A.

    • Address: Havana, Cuba
    • Organization Established Date: 09 Dec 2019
    • Organization Type: Wholesale of solid, liquid and gaseous fuels and related products
    • Entity Code: 60631 (Cuba)

    Supplemental Information: Designated under Sec. 2(a)(i)(A) for operating in the energy sector of the Cuban economy. State identifies it as a Cuban entity engaged in the import and export of fuels and lubricants.

    GRUPO EMPRESARIAL DE TRANSPORTE MARITIMO PORTUARIO

    • AKA: “GEMAR”
    • Address: Havana, Cuba
    • Organization Established Date: 2015
    • Organization Type: Activities of holding companies
    • Party Type: State-Owned Enterprise

    Supplemental Information: Designated under Sec. 2(a)(i)(B) as owned/controlled by, or acting on behalf of, the Cuban government. State describes GEMAR as a Cuban state-owned entity with a strong presence in the country’s maritime sector.

    GRUPO EMPRESARIAL DEL COMERCIO EXTERIOR

    • AKA: GECOMEX
    • Address: Havana, Cuba
    • Organization Established Date: 04 Jun 2013
    • Organization Type: Wholesale and retail trade
    • Party Type: State-Owned Enterprise

    Supplemental Information: Designated under Sec. 2(a)(i)(B). State identifies GECOMEX as the Cuban state-owned business group managing the country’s foreign trade, handling a significant share of imports and exports.

    MILICIAS DE TROPAS TERRITORIALES

    • AKA:
      • “MTT”
      • “TERRITORIAL TROOP MILITIAS”
    • Address: Cuba
    • Organization Established Date: 20 Jan 1980
    • Party Type: Government Entity

    Supplemental Information: Designated under Sec. 2(a)(i)(F) for being a political subdivision, agency, or instrumentality of the Cuban government. State describes MTT as a part-time civilian paramilitary force under the command of Cuba’s Ministry of the Revolutionary Armed Forces (MINFAR, already designated).

    MINISTRY OF TOURISM OF CUBA

    • AKA:
      • MINISTERIO DE TURISMO DE CUBA
      • “MINTUR”
    • Address: Havana, Cuba
    • Organization Established Date: 21 Apr 1994
    • Party Type: Government Entity

    Supplemental Information: Designated under Sec. 2(a)(i)(F). State describes MINTUR as Cuba’s ministry responsible for regulating tourism in and out of the country, and the largest single tourism-sector player outside of GAESA.

    ORGANIZACION SUPERIOR DE DIRECCION EMPRESARIAL CAUDAL S.A.

    • AKA:
      • GRUPO CAUDAL S.A.
      • OSDE CAUDAL S.A.
    • Address: Havana, Cuba
    • Organization Established Date: 31 Mar 2000
    • Organization Type: Activities of holding companies
    • Party Type: State-Owned Enterprise

    Supplemental Information: Designated under Sec. 2(a)(i)(B). State identifies CAUDAL as a Cuban state-owned entity specializing in insurance, reinsurance, financial services, and related professional services.

    RAPID RESPONSE BRIGADES

    • AKA:
      • BRIGADAS DE ACCION RAPIDA
      • BRIGADAS DE RESPUESTA RAPIDA
      • DESTACAMENTOS DE RESPUESTA RAPIDA
    • Address: Cuba
    • Organization Established Date: Jun 1991
    • Organization Type: Public order and safety activities

    Supplemental Information: Designated under Sec. 2(a)(i)(B). State describes these brigades as armed civilian para-police groups organized and trained by the Cuban government.

    Sources (beyond the update and press release/fact sheet PDFs):

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  • Burning Questions: Secondary Sanctions Risk, and are firms over-reacting to it?

    Prompt #1:

    Why do some OFAC listings include “secondary sanctions risk” wording and others do not? Are there listings where the risk does exist but the wording doesn’t appear? If so, why not? What are the implications – from a regulatory or practical sense – of that wording appearing? Check your response against your sources and flag anything that is not well-supported by the sources

    First response:

    Why some listings carry the wording and others don’t

    The “Secondary sanctions risk:” line is a remark field OFAC appends to an SDN (or SSI) entry to point the reader to the specific legal authority under which dealings with that person could expose a non-US person to secondary consequences. In the entries you’ll see, it takes forms like “Secondary sanctions risk: See Section 11 of Executive Order 14024” for Russia-EO14024 designations, “Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201” for legacy Ukraine/Russia entries, and program-specific citations like “section 1(b) of Executive Order 13224, as amended by Executive Order 13886” on a terrorism-linked entry.

    The presence or absence tracks the program, not the individual designee. Secondary sanctions authority is program-specific: it exists for Iran, Russia (EO 14024/14114 §11 and CAATSA §231), North Korea, and certain counterterrorism/narcotics authorities, but not for every OFAC program. An SDGT/SDNTK designation carries the tag where the underlying EO 13224/13886 authority provides for it; a designation under a program with no secondary-sanctions statute behind it won’t have the line because there’s no secondary authority to cite.

    A second driver is timing. OFAC added the remark to many pre-existing entries retroactively. In mid-2024, following EO 14114’s revision of Section 11 of EO 14024, OFAC amended existing SDN and SSI list entries to include an explicit reference to “secondary sanctions risk” pursuant to revised Section 11 of Executive Order 14024. So an entry designated before that authority existed (or before OFAC did the bulk update) might not carry wording that a functionally identical entry added later would.

    Are there listings where the risk exists but the wording doesn’t appear?

    Yes — and this is the practically important part. The remark is informational, not a determination of your exposure.Two mechanisms produce risk without the tag:

    The 50% Rule. Entities owned 50%-or-more by blocked persons are themselves blocked without being separately listed at all. Under OFAC guidance, any entity owned 50% or more, individually or collectively, by sanctioned persons is itself treated as blocked, and entities may be subject to sanctions even if they are not expressly listed. An unlisted subsidiary of a secondary-sanctionable parent carries the parent’s risk profile but has no SDN entry, hence no remark.

    Retroactive-tagging gaps and program coverage. Because the tagging was applied program-by-program and in batches, and because OFAC “overwrites rather than versions” its public data, an entry can lag the current legal reality. The tag reflects OFAC’s citation choice at a point in time, not a guarantee that no secondary authority reaches the party.

    ⚠️ Flag — not well-supported by my sources: I could not, in these searches, locate an OFAC FAQ or a data-specification document in which OFAC itself explicitly states that the “secondary sanctions risk” field is non-determinative and that its absence does not mean no risk exists. That characterization is the well-established practitioner reading (and it follows logically from how the 50% Rule and program-specific authorities operate), but I’m presenting it as sound inference rather than a sourced OFAC statement. If you want to publish it as OFAC’s own position, that specific claim should be verified against the SDN List data specification or the relevant FAQ before it goes out.

    Implications of the wording appearing

    The remark does not change what is prohibited for US persons — they are already barred from dealings with any blocked party regardless of whether the line appears. Its function is a signal to non-US persons, particularly foreign financial institutions.

    For an FFI, the tag flags that dealing with this party could expose the institution itself to consequences that amount to exclusion from the US financial system — OFAC can require US banks to close the foreign bank’s correspondent or payable-through accounts, or designate the foreign bank itself on the SDN List.

    Critically, the exposure typically turns on a “significant transaction” standard with no bright line. OFAC weighs the size, number, and frequency of the transactions; their nature; the level of management awareness and whether they form a pattern of conduct; and the nexus to sanctioned persons. There is no bright-line dollar threshold for significance.

    Two practical points worth making for your audience:

    The tag has become a de facto compliance trigger ahead of formal enforcement. Financial institutions in jurisdictions such as China, the UAE, and Turkey began restricting or delaying Russia-related transactions due to perceived secondary sanctions risk — banks act as gatekeepers before regulators formally move. So the wording’s real-world effect is often screening-driven de-risking rather than a government action.

    And the wording is a pointer to an authority, not the scope of that authority. The cited EO or CFR section is where the actual conditions, thresholds, and exemptions live; the remark just tells you which door to open.

    Follow-up prompt:

    Are companies treating the secondary sanctions wording as a risk rating? Is there a pattern to this – e.g. by industry, by asset class, by geography or otherwise?

    And the response:

    This is the sharper version of the “Burning Questions” angle from before — whether the field is being read as a rating rather than a citation, and whether that misreading clusters anywhere. Let me search for evidence rather than reason from priors, because the honest answer may be that this specific behavior is under-documented.That gave me adjacent material (screening mechanics, one vendor that tags secondary sanctions as a labeling feature) but not direct evidence of firms misreading the field as a rating. Let me look specifically at the de-risking / over-compliance pattern, which is where any geographic or asset-class clustering would show up.I now have solid material on the de-risking pattern and where it clusters, but I want to be honest about a distinction: the question asks specifically whether firms treat the wording as a rating, and most of what I’ve found is about firms reacting to the underlying risk. Those aren’t the same thing, and I don’t want to conflate them. Let me do one more targeted search on the data-field-as-signal angle.I have enough to give an honest, well-bounded answer. The key finding I need to be upfront about: the sources document a strong de-risking pattern around the underlying secondary-sanctions risk, but almost nothing directly documents firms reading the remark field itself as a rating. Those are different claims, and the interesting piece for a practitioner audience is precisely that gap.

    The short answer

    There’s a real, well-documented behavioral pattern here — but it’s not quite the one the question names, and the distinction matters.

    What the sources robustly support: firms, especially foreign financial institutions, are over-reacting to secondary-sanctions exposure, cutting off parties well beyond what the law strictly prohibits. What the sources do not directly support: that firms are specifically reading the SDN entry’s “Secondary sanctions risk:” remark text as a risk score or rating. I found essentially no direct documentation of that narrower claim. So I’ll give you the pattern that is evidenced, then be explicit about where your framing outruns the record — which is itself the interesting part.

    The pattern that is well-supported: de-risking as over-compliance

    The dominant behavior is precautionary avoidance driven by the threat of secondary sanctions rather than by any single data field. Banks in Asia, Africa, and the Middle East have disengaged from Russian-linked transactions even where the dealing is technically legal, and many have cut off clients only remotely linked to Russian entities where no direct violation exists. This is firms treating the possibility of secondary exposure as a reason to exit, which is functionally “risk-rating” behavior — just triggered by the designation and its program, not by parsing the remark.

    OFAC appears to have designed for exactly this. Davis Polk’s read is that the US has historically been highly selective in imposing secondary sanctions, and that the expanded FFI measures seem calibrated to have a broad deterrent effect and to encourage de-risking. In other words, the deterrent-by-ambiguity is intentional; the over-compliance is a feature, not an accident.

    Where the pattern clusters

    The evidence does show clustering, and it’s worth laying out by the axes you asked about.

    By asset class / sector. Energy is the clearest. After the Rosneft and Lukoil designations, purchasers in India and major companies in China tended to avoid buying from sanctioned sellers or intermediaries, and third-country operators and banks were deterred from ongoing business with those firms. Correspondent banking is the other concentration: documentary credits and guarantees involving Russian exporters became high-risk instruments, and trade finance is where much of the avoidance shows up.

    By geography. The avoidance concentrates in the transshipment and energy-buyer jurisdictions — China, India, Turkey, the UAE — precisely the third countries OFAC’s FFI authority targets. OFAC’s own updated FFI advisory flags that small- and medium-size institutions in jurisdictions that continue significant Russia trade present particularly high risk, which pushes correspondent banks to de-risk entire categories of respondent institutions in those markets.

    By institution type. Smaller FFIs without deep compliance benches de-risk more bluntly, because nuanced analysis of “significant transaction” thresholds is expensive and the downside — loss of US correspondent access — is existential. Larger banks can afford the granular analysis; smaller ones exit the whole exposure.

    The common thread: the clustering tracks the programs that actually carry secondary-sanctions authority (Russia, Iran, North Korea) and the choke points (correspondent banking, energy trade finance) — not the presence or absence of the remark text on any given entry.

    Where your framing outruns the sources — and why that’s the actual story

    ⚠️ Flag — not supported by my sources: I could not find direct evidence that compliance teams or screening systems ingest the “Secondary sanctions risk:” remark field and treat it as a rating that ranks one designee above another. That specific claim should not be published as established.

    Two things from the record actually cut against it, and they’re useful to you:

    The remark lives in the remarks field — the same catch-all field OFAC historically used for information that didn’t fit existing structured categories, and where weak AKAs and identifiers also sit. It’s descriptive text pointing to a legal authority, not a structured, scored data element. Screening vendors that do differentiate secondary-sanctions exposure describe it as a labeling / tagging feature they add — referencing the specific regulation or executive order under which a sanction applies — which implies the raw list doesn’t hand them a rating; they construct one.

    And modern screening guidance pushes the opposite of field-reading: a name match is only the beginning, and analysts are expected to work from ownership, nexus, transaction context and the 50% Rule rather than from a line of remark text. The sophisticated read of secondary risk is contextual (who owns whom, is the transaction “significant,” is there a US nexus), and none of that is legible from the remark.

    So the honest synthesis, and the sharper “Burning Question,” is this: firms are absolutely treating secondary-sanctions exposure as a risk gradient — but they’re inferring that gradient from the program, the sector, and the geography, not from the remark field. The remark is a citation; the market has built its own rating on top of it. The failure mode worth writing about isn’t “firms misread the field as a rating” (I can’t evidence that) but the inverse risk: because the field is a citation, not a rating, its presence tells you which authority applies, not how much risk you carry, and its absence tells you nothing — yet the de-risking reflex behaves as though listed-with-tag equals hot and untagged equals cool. Given the 50% Rule and the retroactive-tagging gaps we discussed last time, that reflex is exactly backwards for the unlisted-subsidiary and pre-tagging-batch cases.

    If you want to make the piece defensible, the claim to lead with is the evidenced one (over-compliance clusters in Russia/Iran energy and correspondent banking, in China/India/Turkey/UAE, among smaller FFIs) and to frame the “reading the field as a rating” idea explicitly as a hypothesis you’re raising, not a documented practice — then invite practitioners to tell you whether their screening logic actually weights the field. That’s both the intellectually honest move and, for your readership, probably the thing that generates the most useful responses.

    One caveat on my own evidence base: most of what I found on the behavioral pattern comes from law-firm client alerts and vendor blogs, which are reliable on the direction of travel but have an obvious interest in emphasizing risk. I’d treat the existence and rough clustering of the de-risking pattern as well-established, and any specific magnitude claims as softer.

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