Additionally, OFAC is amending the Terrorism List Governments Sanctions Regulations to implement changes resulting from the rescission of the designation of Syria as a State Sponsor of Terrorism. Specifically, OFAC is removing and reserving a Syria-specific general license because the authorization is no longer necessary following the rescission.
Here are the amended regs:
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is consolidating previously existing information regarding enforcement procedures and penalties, including the rights of U.S. persons being investigated for violations, that are currently located in individual parts of 31 CFR chapter V into a new part, the Sanctions Penalties Regulations. Following publication of this part, OFAC will update parts within 31 CFR chapter V to replace existing penalties information with cross-references to the Regulations, resulting in the deletion of over 100 subparts from existing regulations.
Here they are (I’ll spin up Claude to summarize and compare to what used to be later):
The following deletions have been made to OFAC’s SDN List:
OFAC Program: DRCONGO Democratic Republic of the Congo Sanctions Regulations, 31 C.F.R. 547
OLENGA, Francois (Latin: OLENGA, François) (a.k.a. OKUNJI, Francois (Latin: OKUNJI, François); a.k.a. OLENGA TATE, Francois; a.k.a. OLENGA TETE, Francois (Latin: OLENGA TETE, François); a.k.a. OTSHUNDI, Francois (Latin: OTSHUNDI, François)), Kinshasa, Congo, Democratic Republic of the; DOB 09 Oct 1948; alt. DOB 10 Sep 1948; alt. DOB 10 Jul 1949; POB Kindu, Maniema, Democratic Republic of the Congo; nationality Congo, Democratic Republic of the; citizen Congo, Democratic Republic of the; Gender Male; General; Chef de la Maison Militaire; Head of the Military House of the President (individual).
OLENGA TETE, Francois (Latin: OLENGA TETE, François) (a.k.a. OKUNJI, Francois (Latin: OKUNJI, François); a.k.a. OLENGA TATE, Francois; a.k.a. OLENGA, Francois (Latin: OLENGA, François); a.k.a. OTSHUNDI, Francois (Latin: OTSHUNDI, François)), Kinshasa, Congo, Democratic Republic of the; DOB 09 Oct 1948; alt. DOB 10 Sep 1948; alt. DOB 10 Jul 1949; POB Kindu, Maniema, Democratic Republic of the Congo; nationality Congo, Democratic Republic of the; citizen Congo, Democratic Republic of the; Gender Male; General; Chef de la Maison Militaire; Head of the Military House of the President (individual).
OLENGA TATE, Francois (a.k.a. OKUNJI, Francois (Latin: OKUNJI, François); a.k.a. OLENGA TETE, Francois (Latin: OLENGA TETE, François); a.k.a. OLENGA, Francois (Latin: OLENGA, François); a.k.a. OTSHUNDI, Francois (Latin: OTSHUNDI, François)), Kinshasa, Congo, Democratic Republic of the; DOB 09 Oct 1948; alt. DOB 10 Sep 1948; alt. DOB 10 Jul 1949; POB Kindu, Maniema, Democratic Republic of the Congo; nationality Congo, Democratic Republic of the; citizen Congo, Democratic Republic of the; Gender Male; General; Chef de la Maison Militaire; Head of the Military House of the President (individual).
OKUNJI, Francois (Latin: OKUNJI, François) (a.k.a. OLENGA TATE, Francois; a.k.a. OLENGA TETE, Francois (Latin: OLENGA TETE, François); a.k.a. OLENGA, Francois (Latin: OLENGA, François); a.k.a. OTSHUNDI, Francois (Latin: OTSHUNDI, François)), Kinshasa, Congo, Democratic Republic of the; DOB 09 Oct 1948; alt. DOB 10 Sep 1948; alt. DOB 10 Jul 1949; POB Kindu, Maniema, Democratic Republic of the Congo; nationality Congo, Democratic Republic of the; citizen Congo, Democratic Republic of the; Gender Male; General; Chef de la Maison Militaire; Head of the Military House of the President (individual).
OTSHUNDI, Francois (Latin: OTSHUNDI, François) (a.k.a. OKUNJI, Francois (Latin: OKUNJI, François); a.k.a. OLENGA TATE, Francois; a.k.a. OLENGA TETE, Francois (Latin: OLENGA TETE, François); a.k.a. OLENGA, Francois (Latin: OLENGA, François)), Kinshasa, Congo, Democratic Republic of the; DOB 09 Oct 1948; alt. DOB 10 Sep 1948; alt. DOB 10 Jul 1949; POB Kindu, Maniema, Democratic Republic of the Congo; nationality Congo, Democratic Republic of the; citizen Congo, Democratic Republic of the; Gender Male; General; Chef de la Maison Militaire; Head of the Military House of the President (individual).
SAFARI CLUB (a.k.a. CENTRE DE LOISIR SAFARI CLUB; a.k.a. “SAFARI BEACH”), Nsele, Kinshasa, Congo, Democratic Republic of the; Gombe, Kinshasa, Congo, Democratic Republic of the; Registration ID 1322 (Congo, Democratic Republic of the) (Linked To: OLENGA, Francois).
CENTRE DE LOISIR SAFARI CLUB (a.k.a. SAFARI CLUB; a.k.a. “SAFARI BEACH”), Nsele, Kinshasa, Congo, Democratic Republic of the; Gombe, Kinshasa, Congo, Democratic Republic of the; Registration ID 1322 (Congo, Democratic Republic of the) (Linked To: OLENGA, Francois).
“SAFARI BEACH” (a.k.a. CENTRE DE LOISIR SAFARI CLUB; a.k.a. SAFARI CLUB), Nsele, Kinshasa, Congo, Democratic Republic of the; Gombe, Kinshasa, Congo, Democratic Republic of the; Registration ID 1322 (Congo, Democratic Republic of the) (Linked To: OLENGA, Francois).
Unrelated Administrative List Changes
This administrative update only changes the character “½” to the characters “1/2” in the address of an existing listing. No new listings have been added, and no new sanctions apply to this name.
OFAC Program: CUBA-EO14404 Executive Order 14404
CENTRO DE INVESTIGACION Y DESARROLLO DE ARMAMENTO DE INFANTERIA
List of Changes:
Today, OFAC issues Russia-related GL 131J:
and updated FAQs 1224 and 1225 accordingly:
1225. What activities do Russia-related General License 128C and General License 131J authorize related to Lukoil International GmbH (LIG)?
OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128C and GL 131J. The GLs are similar but have different expiration dates and terms as each serves a different purpose.
- To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C to extend the existing authorization until October 29, 2026.
- To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, GL 131H, GL 131I, and GL 131J, to extend the existing authorization until October 22, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.
GL 128C and GL 131J expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128C and GL 131J. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128C and GL 131J authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.
Both GL 128C and GL 131J also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.
Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128C and GL 131J. Similarly, non-U.S. persons may rely upon GL 128C and GL 131J regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128C and GL 131J, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.
Date Updated: September 18, 2026
Updated on Sep 18, 2026
Russian Harmful Foreign Activities Sanctions
1224. What negotiations does Russia-related General License 131J authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?
On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131J, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131Jexpires on October 22, 2026.
GL 131J does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131J must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.
As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.
OFAC may revoke GL 131J at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.
Date Updated: September 18, 2026
Updated on Sep 18, 2026
The national emergency declared in Executive Order (E.O.) 14046 of September 17, 2021, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” has expired.
Following the expiration of the national emergency declared in E.O. 14046, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has removed from the List of Specially Designated Nationals and Blocked Persons (SDN List), persons designated pursuant to E.O. 14046 whose property had been blocked. In addition, OFAC has removed Frequently Asked Questions pertaining to this program from its website.
The following deletions have been made to OFAC’s SDN List:
OFAC Program: [ETHIOPIA-EO14046] Executive Order 14046
PEOPLE’S FRONT FOR DEMOCRACY AND JUSTICE, Eritrea; Organization Established Date 1993; Organization Type: Activities of political organizations.
W KIDAN, Hagos Ghebrehiwet (a.k.a. WELDEKIDANE, Hagos Ghebrehiwet; a.k.a. WOLDEKIDAN, Hagos Ghebrehiwet), Asmara, Eritrea; DOB 25 Apr 1953; POB Senafe, Eritrea; nationality Eritrea; Gender Male; National ID No. 0882109 (Eritrea) (individual).
WOLDEKIDAN, Hagos Ghebrehiwet (a.k.a. W KIDAN, Hagos Ghebrehiwet; a.k.a. WELDEKIDANE, Hagos Ghebrehiwet), Asmara, Eritrea; DOB 25 Apr 1953; POB Senafe, Eritrea; nationality Eritrea; Gender Male; National ID No. 0882109 (Eritrea) (individual).
WELDEKIDANE, Hagos Ghebrehiwet (a.k.a. W KIDAN, Hagos Ghebrehiwet; a.k.a. WOLDEKIDAN, Hagos Ghebrehiwet), Asmara, Eritrea; DOB 25 Apr 1953; POB Senafe, Eritrea; nationality Eritrea; Gender Male; National ID No. 0882109 (Eritrea) (individual).
NEMARIAM, Abraha Kassa (a.k.a. KASSA, Abraha; a.k.a. KASSA, Wedi), Eritrea; DOB 15 Jul 1953; POB Eritrea; nationality Eritrea; Gender Male; Passport D000294 (Eritrea) (individual).
KASSA, Wedi (a.k.a. KASSA, Abraha; a.k.a. NEMARIAM, Abraha Kassa), Eritrea; DOB 15 Jul 1953; POB Eritrea; nationality Eritrea; Gender Male; Passport D000294 (Eritrea) (individual).
KASSA, Abraha (a.k.a. KASSA, Wedi; a.k.a. NEMARIAM, Abraha Kassa), Eritrea; DOB 15 Jul 1953; POB Eritrea; nationality Eritrea; Gender Male; Passport D000294 (Eritrea) (individual).
ERITREAN DEFENSE FORCES (a.k.a. ERITREAN DEFENSE FORCE), Eritrea; Organization Established Date 1993; Target Type Government Entity.
ERITREAN DEFENSE FORCE (a.k.a. ERITREAN DEFENSE FORCES), Eritrea; Organization Established Date 1993; Target Type Government Entity.
RED SEA TRADING CORPORATION, Felket Street, Asmara, Eritrea; Dubai, United Arab Emirates; Organization Established Date 1984.
HIDRI TRUST, Felket Street, Asmara, Eritrea; Organization Established Date 1994.
The following individuals have been added to OFAC’s SDN List:
OFAC Program: [CUBA-EO14404] Executive Order 14404
CANCIO MONTEAGUDO, Joaquin Francisco
Supplemental Information: A Senior Colonel in the Cuban Revolutionary Armed Forces (FAR) and the Director General of Centro de Investigacion y Desarrollo de Simuladores (SIMPRO), which was designated in the same action. The State Department designated him under Section 2(a)(i)(E) of E.O. 14404, which reaches leaders, officials, senior executive officers and board members of the Government of Cuba or of an entity blocked under that order.
HURTADO BETANCOURT, Julio
Supplemental Information: A Senior Colonel in the FAR and the Director General of Centro de Investigacion y Desarrollo de Armamento de Infanteria (CIDAI), which was designated in the same action. He was designated under Section 2(a)(i)(E) of E.O. 14404 in his capacity as a leader of a blocked entity.
PEDRERA ARGUELLO, Dioglis
Supplemental Information: A Captain in the FAR and the Director General of Centro de Investigacion y Desarrollo Naval (CIDNAV), which was designated in the same action. He was designated under Section 2(a)(i)(E) of E.O. 14404 in his capacity as a leader of a blocked entity.
HEIDARI, Seyed Adel
Supplemental Information: Heidari is the Vice Chairman of the board of directors of Dot One Value Creation Group, the OFAC-designated holding company at the center of Babak Zanjani’s digital assets network, and Treasury identifies him as one of Zanjani’s key lieutenants for sanctions evasion using digital assets. OFAC designated him under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Dot One.
ZAKER HOSSEIN, Hossein Ali
Supplemental Information: An executive of Dot One Value Creation Group, Zaker Hossein has been involved in most of Zanjani’s sanctions evasion activity, including the export of Iranian oil and other digital asset transfers. Treasury also states that he brokered digital asset transactions that ultimately went to the Islamic Revolutionary Guard Corps. OFAC designated him under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Zanjani.
ZAKER HOSSEIN, Mohammad Mahdi
Supplemental Information: A manager and representative of Dot One Value Creation Group, he is also the chief executive of Pishtaz Simorgh Electronic Trade Company, which was designated in the same action. OFAC designated him under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Pishtaz Simorgh.
The following entities have been added to OFAC’s SDN List:
BITBANK
Supplemental Information: BitBank is an Iranian digital assets exchange controlled by OFAC-designated Iranian financier Babak Zanjani. Zanjani has advertised its services on his social media accounts since at least 2024, and multiple other companies in his network list it as a partner. Between June and July of 2026, Zanjani used BitBank to move hundreds of millions of dollars’ worth of Bitcoin to the Islamic Revolutionary Guard Corps, and since June 2026 OFAC-designated Hormuz Safe Marine Services Authority has used the platform to pass payments it received on to the Iranian regime. OFAC designated BitBank under E.O. 13902 for operating in the digital asset sector of the Iranian economy, a sector determination made as part of Operation Economic Outcast, the campaign Secretary Bessent announced on August 24, 2026 and labeled “Economic D-Day.” This action follows earlier rounds of designations against Zanjani-linked digital assets entities and facilitators on January 30, 2026 and July 24, 2026. Zanjani himself was sentenced to death in Iran in 2016 for embezzling from the National Iranian Oil Company, had that sentence commuted in 2024, and re-emerged publicly in 2025 as a backer of regime-linked economic projects. Treasury points to FAQs 1250 and 1257 for sanctions risk associated with Iranian digital asset exchanges.
PISHTAZ SIMORGH ELECTRONIC TRADE COMPANY
Supplemental Information: Pishtaz Simorgh developed BitBank’s digital assets software and has built a brand around the exchange. It is a subsidiary of OFAC-designated Dot One Value Creation Group. OFAC designated it under E.O. 13902 for operating in the digital asset sector of the Iranian economy. Note that its listed address is identical to BitBank’s.
OFAC Program: [CUBA-EO14404] Executive Order 14404
CENTRO DE INVESTIGACION Y DESARROLLO DE ARMAMENTO DE INFANTERIA
Supplemental Information: A Cuba-based military enterprise that runs research programs for the development, acquisition, modernization and evaluation of infantry armaments. The State Department designated it under Section 2(a)(i)(A) of E.O. 14404 for operating in the defense and related materiel sector of the Cuban economy. Its Director General, Julio Hurtado Betancourt, was designated in the same action.
CENTRO DE INVESTIGACION Y DESARROLLO DE SIMULADORES
Supplemental Information: A Cuba-based military enterprise that develops and manufactures simulators and training for the Cuban Revolutionary Armed Forces (FAR) and other Cuban government entities. The State Department designated it under Section 2(a)(i)(A) of E.O. 14404 for operating in the defense and related materiel sector of the Cuban economy. Its Director General, Joaquin Francisco Cancio Monteagudo, was designated in the same action.
CENTRO DE INVESTIGACION Y DESARROLLO NAVAL
Supplemental Information: A Cuba-based military enterprise that runs research programs for the Cuban Revolutionary Navy (MGR). The State Department designated it under Section 2(a)(i)(A) of E.O. 14404 for operating in the defense and related materiel sector of the Cuban economy. Its Director General, Dioglis Pedrera Arguello, was designated in the same action.
CENTRO DE INVESTIGACION, DESARROLLO Y PRODUCCION GRITO DE BAIRE
Supplemental Information: A Cuba-based military enterprise that produces electronics and communications products. The State Department designated it under Section 2(a)(i)(A) of E.O. 14404 for operating in the defense and related materiel sector of the Cuban economy. It is the only one of the four Cuban military research enterprises designated in this action whose director general was not designated alongside it.
CENTRO DE INVESTIGACIONES DEL NIQUEL CAPITAN ALBERTO FERNANDEZ MONTES DE OCA
Supplemental Information: A Cuban state-owned research center that conducts industrial research, development and innovation support for the country’s nickel sector. The State Department designated it under Section 2(a)(i)(A) of E.O. 14404 for operating in the metals and mining sector of the Cuban economy.
EMPRESA DE INGENIERIA Y PROYECTOS DEL NIQUEL
Supplemental Information: A Cuba-based engineering company that executes projects within the Cuban nickel industry and coordinates the country’s state-run mineral extraction operations. The State Department designated it under Section 2(a)(i)(A) of E.O. 14404 for operating in the metals and mining sector of the Cuban economy.
EMPRESA DE SERVICIOS TECNICOS DE COMPUTACION COMUNICACIONES Y ELECTRONICA
Supplemental Information: A Cuban state-owned enterprise that supplies tools and services to the nickel industry in Cuba. The State Department designated it under Section 2(a)(i)(A) of E.O. 14404 for operating in the metals and mining sector of the Cuban economy.
PINARES S.A.
Supplemental Information: A Cuban state-owned mining company that carries out geological surveying of mineral deposits in Cuba. The State Department designated it under Section 2(a)(i)(A) of E.O. 14404 for operating in the metals and mining sector of the Cuban economy.
The following deletions have been made to OFAC’s SDN List:
OFAC Program: [BELARUS] Belarus Sanctions Regulations, 31 C.F.R. part 548; Executive Order 13405
LAKOKRASKA OAO (a.k.a. LAKOKRASKA OPEN JOINT-STOCK COMPANY), 71 Ignatova Street, Grodnenskaya Region, Lida 231300, Belarus; ul. Ignatova, 71, Grodnenskaya oblast, Lida 231300, Belarus.
LAKOKRASKA OPEN JOINT-STOCK COMPANY (a.k.a. LAKOKRASKA OAO), 71 Ignatova Street, Grodnenskaya Region, Lida 231300, Belarus; ul. Ignatova, 71, Grodnenskaya oblast, Lida 231300, Belarus.
OFAC Program: [BELARUS-EO14038] Executive Order 14038
BELARUSIAN PRODUCTION AND TRADE CONCERN OF TIMBER WOODWORKING AND PULP AND PAPER INDUSTRY (Cyrillic: БЕЛОРУССКИЙ ПРОИЗВОДСТВЕННО ТОРГОВЫЙ КОНЦЕРН ЛЕСНОЙ ДЕРЕВООБРАБАТЫВАЮЩЕЙ И ЦЕЛЛЮЛОЗНО БУМАЖНОЙ ПРОМЫШЛЕННОСТИ) (a.k.a. BIELARUSKI VYTVORCHA HANDLIOVY KANCERN LIASNOJ DREVAAPRACOWCHAJ I CELIULOZNA PAPIAROVAJ PRAMYSLOVASCI (Cyrillic: БЕЛАРУСКІ ВЫТВОРЧА ГАНДЛЁВЫ КАНЦЭРН ЛЯСНОЙ ДРЭВААПРАЦОЎЧАЙ І ЦЭЛЮЛОЗНА ПАПЯРОВАЙ ПРАМЫСЛОВАСЦІ); a.k.a. KONTSERN BELLESBUMPROM (Cyrillic: КОНЦЕРН БЕЛЛЕСБУМПРОМ)), GSP, K. Marx Street, 16, Minsk 220030, Belarus; Organization Established Date 21 Jun 1991; Target Type State-Owned Enterprise; Tax ID No. 100377850 (Belarus).
KONTSERN BELLESBUMPROM (Cyrillic: КОНЦЕРН БЕЛЛЕСБУМПРОМ) (a.k.a. BELARUSIAN PRODUCTION AND TRADE CONCERN OF TIMBER WOODWORKING AND PULP AND PAPER INDUSTRY (Cyrillic: БЕЛОРУССКИЙ ПРОИЗВОДСТВЕННО ТОРГОВЫЙ КОНЦЕРН ЛЕСНОЙ ДЕРЕВООБРАБАТЫВАЮЩЕЙ И ЦЕЛЛЮЛОЗНО БУМАЖНОЙ ПРОМЫШЛЕННОСТИ); a.k.a. BIELARUSKI VYTVORCHA HANDLIOVY KANCERN LIASNOJ DREVAAPRACOWCHAJ I CELIULOZNA PAPIAROVAJ PRAMYSLOVASCI (Cyrillic: БЕЛАРУСКІ ВЫТВОРЧА ГАНДЛЁВЫ КАНЦЭРН ЛЯСНОЙ ДРЭВААПРАЦОЎЧАЙ І ЦЭЛЮЛОЗНА ПАПЯРОВАЙ ПРАМЫСЛОВАСЦІ)), GSP, K. Marx Street, 16, Minsk 220030, Belarus; Organization Established Date 21 Jun 1991; Target Type State-Owned Enterprise; Tax ID No. 100377850 (Belarus).
BIELARUSKI VYTVORCHA HANDLIOVY KANCERN LIASNOJ DREVAAPRACOWCHAJ I CELIULOZNA PAPIAROVAJ PRAMYSLOVASCI (Cyrillic: БЕЛАРУСКІ ВЫТВОРЧА ГАНДЛЁВЫ КАНЦЭРН ЛЯСНОЙ ДРЭВААПРАЦОЎЧАЙ І ЦЭЛЮЛОЗНА ПАПЯРОВАЙ ПРАМЫСЛОВАСЦІ) (a.k.a. BELARUSIAN PRODUCTION AND TRADE CONCERN OF TIMBER WOODWORKING AND PULP AND PAPER INDUSTRY (Cyrillic: БЕЛОРУССКИЙ ПРОИЗВОДСТВЕННО ТОРГОВЫЙ КОНЦЕРН ЛЕСНОЙ ДЕРЕВООБРАБАТЫВАЮЩЕЙ И ЦЕЛЛЮЛОЗНО БУМАЖНОЙ ПРОМЫШЛЕННОСТИ); a.k.a. KONTSERN BELLESBUMPROM (Cyrillic: КОНЦЕРН БЕЛЛЕСБУМПРОМ)), GSP, K. Marx Street, 16, Minsk 220030, Belarus; Organization Established Date 21 Jun 1991; Target Type State-Owned Enterprise; Tax ID No. 100377850 (Belarus).
—
GL 5 has been updated to GL 5Z:
And Frequently Asked Question 595 got updated, too:
595. What does Venezuela-related General License 5Z authorize?
Answer
The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.
General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times. Most recently, OFAC issued General License 5Z on September 16, 2026, which further delays the effectiveness of the authorization in GL 5 until November 5, 2026. Between October 24, 2019 and November 5, 2026 (the date the authorization in General License 5Z becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.
To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.
Date Updated: September 16, 2026
Date Released
January 20, 2022
The following deletions have been made to OFAC’s SDN List:
OFAC Program: [SDNTK] Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598
VEGA SANCHEZ, Jose Raul, c/o AGRICOLA GAXIOLA S.A. DE C.V., Hermosillo, Sonora, Mexico; c/o INMUEBLES SIERRA VISTA S.A. DE C.V., Hermosillo, Sonora, Mexico; c/o TEMPLE DEL PITIC S.A. DE C.V., Hermosillo, Sonora, Mexico; DOB 19 Oct 1956; POB Cananea, Sonora, Mexico; nationality Mexico; citizen Mexico; C.U.R.P. VESR561019HSRGNL09 (Mexico); alt. C.U.R.P. VEXR561019HSRGXL05 (Mexico) (individual).
OFAC Program: [RUSSIA-EO14024] Executive Order 14024
BOMATTER, Hans Peter, La Zubia, Spain; DOB 19 May 1965; POB Schattdorf, Switzerland; nationality Switzerland; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport F3848406 (Switzerland) (individual) (Linked To: TAMYNA AG).
MODULSAN MAKINA KESICI TAKIM VE DISLI SANAYI TICARET LIMITED SIRKETI, 1CA Blok, 1575. Sokak No. 1 CA/2, Akcaburgaz Mahallesi, Esenyurt 34522, Turkey; Website http://www.modulsan.com; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Organization Established Date 09 Oct 2006; Tax ID No. 3340494281 (Turkey); Identification Number 0334049428100019 (Turkey); Registration Number 602993 (Turkey).
My prompt to Claude (yes, it was a tad snarky):
So… other than publicity, and maybe some secondary sanctions exposure, what was the value, if any, of that update? VTB was already subject to an asset freeze, no? explain in language for the common public
Claude’s initial response, which I took issue with:
You’re right about the core of it. VTB’s money was already frozen. Nothing about how an American bank handles a VTB hit changed on Sunday. Blocked is blocked, and there is no such thing as more blocked. If the only audience were US institutions, this update would be paperwork.
The audience is not US institutions.
The new tag changes which rulebook foreign banks apply. Russia sanctions and Iran sanctions are not two flavors of the same thing to a bank in Dubai, Istanbul, Mumbai or Shanghai. The Russia rules that expose foreign banks to US penalties are discretionary. Treasury may act against a foreign bank that handles significant business for a sanctioned Russian entity, and in practice it has acted sparingly, often with a warning first. The Iran rules are older, partly written by Congress rather than the President, and carry mandatory triggers. Foreign bank boards have long memories about what happened to institutions that got caught on the wrong side of Iran sanctions in the 2010s, and the fines involved.
There is a second layer that has nothing to do with US law. Many non-US banks write their own internal policies so that any Iran connection is a hard stop, while Russia exposure gets a case-by-case review. Adding an Iran tag to VTB can therefore trip a stricter internal rule automatically at institutions that had been carefully doing limited Russia business. That is my read from how these policies are typically drafted, not something Treasury said.
The designation also outlives a Russia deal. This is the part I would put first if I were writing it for a general reader. There is real talk of the Ukraine war ending and of Russia sanctions being unwound as part of a settlement. If that happens, VTB’s Russia designations come off. The Iran designation would not, because it rests on different conduct under a different authority. Think of a condemned building. A second violation notice does not make it more condemned, but if the first notice is withdrawn, the second one still keeps the doors locked. Treasury has bought itself a lock that a Russia peace deal does not open.
And it puts the accusation on the public record. Until this week, a foreign bank could plausibly say it had no idea VTB was running correspondent accounts for sanctioned Iranian banks or moving frozen Iranian assets. Now that claim is on a US government page with VTB’s name on it. Nobody gets to be surprised anymore, and “we didn’t know” stops being available as a defense.
One smaller thing that matters to people who run screening systems. OFAC took 21 of VTB’s old names, things like plain “VNESHTORGBANK,” and moved them from “used to be called this” to “also called this.” Some screening setups treat former names as lower priority or filter them out. Those 21 names just came back to full strength, and no press release explains why.
So the honest summary is that this update does very little to VTB’s money and quite a lot to VTB’s remaining business relationships and to the government’s negotiating position. Which is roughly what you would expect from a campaign whose stated goal is isolation rather than seizure.
My follow-up:
well, if you were already defying the US Russia sanctions, how likely is it that this would change your behavior? Is it just because the President is more focused on Iran now than Russia? And would it really change the behavior of Chinese firms?
And the response:
Your first question mostly answers itself, and it exposes something soft in what I told you earlier.
Anyone still clearing business for VTB in September 2026 has already made peace with being outside the US financial system. That population is self-selected for indifference. Adding a tag to a party you were already willing to be caught dealing with is not a new deterrent, it is the same deterrent restated. The banks that could be moved by this are the ones with US correspondent accounts they still want to keep, and those banks mostly exited VTB in 2022. So the group sitting between “already gone” and “already defiant” is thin.
I also overstated one thing. I said the Iran rules carry mandatory triggers where the Russia ones are discretionary. That is true of the statutory Iran provisions, CISADA and IFCA and the NDAA correspondent-account section, but it is not true of what OFAC actually invoked here. Treasury’s own release says OFAC “can prohibit or impose strict conditions on” a foreign bank’s correspondent account. That is permissive language. The legal difference between the Russia exposure and the new Iran exposure is narrower than I made it sound. What is genuinely different is reputational, not statutory.
On whether this is about presidential attention, largely yes, and I would put it more bluntly than I did. Treasury is running an Iran campaign that needs visible targets while it is simultaneously negotiating over Russia. Hitting VTB under a Russia authority would cut across the negotiation. Hitting the same bank under an Iran authority produces the headline without disturbing that track. The choice of authority is doing diplomatic work as much as legal work. The durability point I raised stands, since an Iran designation survives a Russia settlement, but I should be clear that is a benefit to Treasury’s future position rather than a cost imposed on VTB today.
Chinese firms are the weakest part of the case. The large state banks pulled back from VTB years ago and have run conservative Iran policies since the last decade. Nothing here reaches them because they already left. The institutions that do handle sanctioned trade are small regional banks with no dollar business to lose, and the precedent for how that plays out is Bank of Kunlun, which the US designated in 2012 over Iran and which China then simply used as the designated channel. Cutting a bank off from a system it does not use is not much of a penalty. Add that a growing share of this trade settles in renminbi through CIPS, and the lever you are pulling is attached to nothing.
Where I think there is real value, and it is plumbing rather than deterrence, is that a designation under an Iran authority creates a predicate for designating the people who help VTB with its Iran business. Those orders generally include a materially-assisted prong, though I have not pulled the text of 13902 to confirm the specific wording. If that is right, the update is less a punishment of VTB than a hook for whoever gets named next.
so, maybe not Much Ado About Nothing, but more like Much Ado About Something Possibly in the Future…. meh.
