well, OFAC is also a strict liability regime – all who touch the transaction have violated the regulations, but the consequences, if any, vary according to the Enforcement Guidelines. So, OFAC just balances the scales differently, wouldn’t you say?
Claude responded:
Yes — and that’s a genuinely better way to put it than how it was left last message, so it’s worth correcting rather than defending the weaker version.
The mechanics check out
OFAC’s civil liability is strict: a violation exists the moment a blockable transaction occurs, full stop — OFAC need not prove fault or intent to bring an enforcement action and issue a civil penalty, and a civil penalty can be assessed even if the violator had no idea they were dealing with a sanctioned party. What actually happens next is calibrated entirely by the Enforcement Guidelines at 31 CFR Part 501, Appendix A — egregious versus non-egregious, voluntary self-disclosure, willfulness or recklessness, quality of the compliance program, awareness of the conduct, harm to program objectives. So the fault inquiry hasn’t been discarded, it’s just been relocated to the remedy stage instead of the liability stage. “Balances the scales differently” describes that far more precisely than the earlier “bets on speed vs. bets on accuracy” line, which overstated the contrast.
And here’s the part that actually strengthens the parallel rather than just conceding it: the UK made exactly this same move. For breaches committed on or after 15 June 2022, OFSI can impose civil monetary penalties on a strict liability basis, regardless of the absence of knowledge or a reasonable cause to suspect — before that date, OFSI had to show knowledge or reasonable cause to suspect on the balance of probabilities. So the “we wait for fault before we act” framing offered earlier doesn’t even hold up as a clean description of the UK’s own penalty regime anymore. Knowledge and intent still matter there, but now as a severity factor within OFSI’s case assessment, not as a threshold for liability — the same architecture as OFAC’s General Factors.
So where does the real difference actually live now?
Not in whether fault matters — both regimes have converged on “fault affects the size of the punishment, not whether a violation occurred.” It survives in what strict liability is allowed to reach. OFAC’s fault-blindness attaches to an immediate, automatic property action: the money gets locked up the moment the objective trigger exists, and that seizure doesn’t reverse just because a later fault inquiry clears the customer — unblocking still requires its own separate license. The UK’s 2022 reform, notably, didn’t build an equivalent mechanism. It made it easier to fine someone for the underlying conduct without proving they knew — but it stopped there. It didn’t create a parallel power to seize Customer A’s payment while that question gets sorted out, because there’s still nothing belonging to the designated person to seize in Scenario A, for the reasons worked through earlier.
That’s actually a more interesting finding than where things were left before: it isn’t that UK-style regimes are squeamish about strict liability in general — 2022 proves they aren’t. It’s that they’ve kept strict liability confined to punishing conduct after the fact, and never extended it into a mechanism for provisionally seizing an uninvolved party’s property before fault is even alleged. OFAC does both.
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 5Y on August 3, 2026, which further delays the effectiveness of the authorization in GL 5 until September 17, 2026. Between October 24, 2019 and September 17, 2026 (the date the authorization in General License 5Y 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.
When OFAC and the EU Spell the Same Name Differently, What Are You Liable For?
It is a question experienced practitioners run into constantly but rarely see answered head-on. A person is designated by both OFAC and the EU. OFAC’s SDN entry romanizes the name one way; the EU’s Official Journal renders it another. Your screening system matches one string cleanly and scores the other below threshold. If a transaction slips through against the spelling you did not catch, what exactly is the liability – and is “we ran a standard edit-distance match” a defense?
The short version: you are liable for the person, not the spelling, and the expectation clearly goes beyond raw edit distance. Here is the reasoning, with the supporting regulatory language.
1. The obligation attaches to the designated person, not to a romanization
OFAC’s prohibitions run against the designated person and that person’s property and interests in property. The name spellings, aliases, and other identifiers published in an SDN entry are aids to identification; they are not the legal definition of the target. That distinction matters because it means a spelling discrepancy between OFAC’s list and another regulator’s list is not, by itself, a shield. You cannot defend a missed match by pointing out that OFAC and the EU transliterated the underlying name differently, because your obligation was never keyed to a specific Latin string in the first place.
This is reinforced by the strict-liability character of most OFAC prohibitions. Civil liability under IEEPA-based programs does not require intent or knowledge, so “the file we screened against spelled it differently” is not a recognized excuse. It goes to mitigation, not to whether an apparent violation occurred.
2. Each list is authoritative in its own jurisdiction – so you screen against each as published
OFAC, the EU, the UN, and OFSI transliterate Arabic, Cyrillic, Farsi, and Chinese names using different conventions. The same human being legitimately produces different Latin strings across the lists – Mohammed / Muhammad / Mohamed; Qadhafi / Gaddafi / Kadafi; hyphenated, spaced, or dropped “Al-” prefixes. Each list is, in its own jurisdiction, the authoritative legal instrument. A firm subject to more than one regime is therefore expected to screen against each list as published and to reconcile the fact that one person maps to several spellings across them. There is no regulator that publishes an explicit “you must reconcile our transliteration against the EU’s” rule – the expectation is inferred from how the obligations are framed and enforced, not from a single on-point statement.
3. Does the expectation go beyond standard edit-distance matching? Yes – and OFAC has said so in substance
Edit distance (Levenshtein, Jaro-Winkler, and similar) is treated as necessary but not sufficient. OFAC does not prescribe an algorithm, but its guidance and enforcement record point squarely at the failure modes that character-level distance handles poorly.
In A Framework for OFAC Compliance Commitments (May 2, 2019), OFAC identifies deficient screening as a recurring root cause of apparent violations, and it specifically calls out the failure to account for alternative spellings of designated parties. Commentators summarizing the Framework note that OFAC warns screening software must, among other things, account for alternative spellings of prohibited firms or people – the Habana / Havana example is OFAC’s own. That is the closest thing to a direct statement that naive string matching is not enough.
Why edit distance alone falls short in the cross-list transliteration scenario:
Cross-alphabet variance. Two valid romanizations of one name can sit at a large character-level distance from each other. “Qadhafi” versus “Kadafi” is a big edit distance but the same person. A threshold tight enough to suppress false positives will miss these; a threshold loose enough to catch them floods the review queue.
Phonetic equivalence. Names that sound alike but score as distant (the “Mohammed” / “Muhammad” family) are better bridged by phonetic logic (Soundex, Metaphone) or transliteration-aware normalization than by raw distance.
Name-order and segmentation. Arabic kunya/nasab structures, Chinese surname-first ordering, and dropped or added particles defeat token-by-token distance scoring.
Culture and script-specific normalization rather than a single global threshold applied to every population.
4. The enforcement record: tool tuning for name variants is a cited deficiency
Two settlements make the point concretely, and neither turns on willful conduct – both are about how the screening tool was configured.
Apple / SIS (FNKSR, 2023 settlement). As part of resolving apparent violations tied to a designated Slovenian developer, OFAC highlighted remedial measures Apple undertook, including reconfiguring its primary screening tool to fully capture spelling and capitalization variations and to account for country-specific business suffixes, plus annual review of the tool’s logic and configuration. The remediation itself tells you what OFAC viewed as the gap: a tool that did not adequately capture variant spellings.
JPMorgan Chase (FNKSR and Syria, 2018 Finding of Violation). OFAC found that the bank’s screening system, as configured over a multi-year period, failed to identify customer names with hyphens, initials, or additional middle or last names as potential matches to identical or similar names on the SDN List – and that staff did not escalate the red flags despite matching addresses and dates of birth. Again, the deficiency is in the matching logic and the procedures around it, not in the absence of screening.
The through-line: OFAC does not penalize you for the existence of a spelling difference. It looks at whether a reasonable, risk-appropriate program – with fuzzy matching, phonetic and transliteration handling, and periodic tuning and testing – should have caught the target. A tool that “ran” but was mis-tuned to variant spellings is treated as a deficient program.
5. How the liability actually resolves
Put the pieces together and the liability is not “for the spelling” as such. It is for processing a transaction involving a designated person you should reasonably have identified. If your program screens against OFAC’s spelling with matching logic calibrated to catch reasonable variants, and a genuinely divergent EU transliteration was the only version that would have matched, OFAC’s inquiry is whether a reasonable, risk-based program should have caught it anyway. A documented, risk-based methodology – fuzzy plus phonetic and transliteration-aware matching, with periodic tuning and testing – is simultaneously the compliance expectation and, under OFAC’s Economic Sanctions Enforcement Guidelines, a mitigating factor if something still slips through.
Bottom line
No regulator publishes an express “reconcile our transliteration against the EU’s” instruction. But the combination of three things – strict liability, the principle that the obligation runs to the designated person rather than to a designated spelling, and OFAC’s explicit citation of alternate-spelling failures as an enforcement root cause – produces a clear expectation. Screen against each authoritative list as published, and use matching logic that goes beyond raw edit distance to account for transliteration, phonetic, and structural name variation. Edit distance alone, without transliteration and phonetic handling and risk-based tuning, would most likely be viewed as a deficient program.
Source confidence. The Framework‘s treatment of alternate spellings as a screening root cause, and the Apple/SIS and JPMorgan Chase remediation details, are well supported by OFAC’s published materials and settlement summaries. The broader proposition – that this framework requires cross-list transliteration reconciliation – is inference drawn from the Framework, the enforcement record, and the strict-liability structure, rather than from a single on-point OFAC statement, because OFAC has not issued express guidance addressing cross-regulator transliteration divergence directly.
Key references: OFAC, A Framework for OFAC Compliance Commitments (May 2, 2019), Appendix root-cause analysis; OFAC settlement with Apple Inc. under the Foreign Narcotics Kingpin Sanctions Regulations; OFAC Finding of Violation involving JPMorgan Chase (FNKSR and Syrian Sanctions Regulations, 2018).
In a practical sense, isn’t freezing the assets in Scenario A a more forceful way to accomplish the goals of sanctions policy, even if the transaction can get accomplished through some other means – by creating immediate real-world economic consequences for the failed attempt that even reporting on attempted transactions just can’t measure up to?
Claude responded:
This is the crux of it, and the sharpest way to answer is: forceful against whom?
Walk through what actually happens to the designated person under each model
In Scenario A, freeze and reject produce the identical outcome for the sanctioned party: they don’t get paid, either way. They’re equally free, either way, to go find the same money — or different money — through Beijing or Istanbul. Freezing the funds doesn’t touch anything the designated person owns, because as established previously, nothing was theirs yet. So the marginal “forcefulness” being described isn’t landing on the sanctions target at all. It’s landing on Customer A — the non-designated party whose money actually gets locked away, indefinitely, based on nothing more than their instruction to pay someone.
That’s a real distinction worth sitting with: freezing in Scenario A is expropriating an unadjudicated third party’s property because of what they attempted, not punishing the person the sanctions regime actually targets.
But there’s something real here too
There is a genuine difference between freeze and reject that survives this reframing, and it’s not nothing: reject hands Customer A their money back, fully unencumbered, free to try the exact same payment again five minutes later through a different bank — the “ammunition” is untouched. Freeze removes that specific pool of liquidity from anyone’s use entirely. If the underlying deal is going to happen at all now, it needs fresh capital, not this capital. That’s a real cost, and it’s the honest, defensible case for the US approach here — it just achieves that cost by seizing the property of someone who hasn’t been found to have done anything wrong, rather than the property of someone who has.
And the EU-family model doesn’t actually leave the attempt costless — it just sequences the cost differently
If Customer A knowingly tried to pay a designated person, that attempt is itself a prosecutable sanctions offense in every jurisdiction covered — participating in or facilitating a breach of the making-available prohibition carries real civil and often criminal penalties, frequently well beyond the value of the blocked transaction itself. So both models are capable of imposing a serious, real cost on Customer A specifically. The difference is procedural: OFAC’s block is automatic and immediate, applied the instant the instruction is given, regardless of whether Customer A knew anything about the designation. The EU-family model waits for an investigation to actually establish knowledge or intent before it converts “you tried this” into a penalty. One bets on speed and volume (freeze everything that touches you, sort out culpability later, if ever); the other bets on accuracy (don’t touch anyone’s property until you can show they did something wrong).
So a gentle pushback on “even reporting can’t measure up” — reporting isn’t the alternative to a real economic consequence, it’s the on-ramp to one. It’s slower and it requires someone to actually build the case. Whether that trade-off is worth it depends on how much you weight “we caught more bystanders along with more real violators, faster” against “we only touched people we could actually show did something wrong.” That’s a genuine values question in sanctions design, not a case of one side simply declining to try.
let’s go back to Scenario A: there has to be, in order to effectuate the instruction, an account relationship of some kind, doesn’t there? So why is that case different? You’ve got assets being allocated for a sanctioned party – the only difference is that, in Scenario A, it’s being taken from an existing pooled asset. Or am I missing something?
Claude responded:
You’re not missing something, and it’s a sharp catch — there genuinely is an “account relationship” and something IS being drawn from a pooled asset. But the question is whether that operational fact amounts to a legal interest for the designated person, and here payment law itself already draws the line you’re looking for, independent of sanctions law entirely.
A wire transfer isn’t one asset moving through a pipe — it’s a chain of separate obligations
Under the commercial law that actually governs funds transfers (UCC Article 4A in the US; the EU’s Settlement Finality Directive and the payment-services framework in Europe), a beneficiary acquires zero legal claim against their own bank until that bank “accepts” the payment order — the beneficiary’s bank is only obliged to pay the beneficiary once it accepts the order, and acceptance itself is defined narrowly: the earliest of the bank paying the beneficiary, notifying them of receipt, or receiving settlement for the order. Before that moment, nothing has legally reached the beneficiary — the money belongs to the recipient, free of any strings, only once finality is reached. This isn’t a sanctions-specific fiction. It’s the ordinary rule that governs every wire transfer on earth, sanctions or not — it’s what determines, say, whose money it is if a bank fails mid-transfer, or if a payment gets mis-keyed to the wrong account.
So what is actually happening at your end when you debit Customer A?
Bank A debiting Customer A’s account and sending a payment message isn’t Bank A moving the designated person’s property — it’s Bank A discharging (or beginning to discharge) its own contractual obligation to Customer A, funded out of Bank A’s own balance sheet and correspondent liquidity. That pooled asset is Bank A’s, being drawn down pursuant to A’s instruction; the designated person is a total stranger to that relationship until their own bank actually accepts the order on their behalf. If you refuse at that point, nothing reverses because nothing left — Customer A’s account was never debited (or is simply uncredited if it briefly was), and there’s no moment where the designated person held anything that now has to be “returned.” That’s precisely why refusal doesn’t require a licence the way unwinding a completed freeze does: there’s nothing to unwind.
Why “belonging to/held/controlled by” tracks this, and why OFAC doesn’t
The EU-family test (belonging to, owned, held, or controlled by) is simply importing the ordinary payment-law vesting point rather than inventing its own. OFAC’s blocking regime is the outlier specifically because its “interest of any nature whatsoever, direct or indirect” definition is deliberately written to reach behind that ordinary vesting rule — US commercial law (the same UCC 4A) agrees with the EU-family approach that the beneficiary has no claim pre-acceptance, but OFAC’s sanctions regulations override that for blocking purposes, treating mere intended-beneficiary status as sufficient. So the divergence being described here isn’t a difference in what property law says happens to a payment in flight — both systems’ underlying commercial law agrees on that. It’s that only one of them layers a sanctions-specific rule on top that disregards it.
This also explains the countermand test from the UK “trapped payments” guidance covered previously — asking whether a designated bank still had the right to recall the funds is just asking whether finality/irrevocability had occurred yet. Same doctrinal line, applied to figure out whether the freeze duty travels with the money through a correspondent chain. And it’s why an intermediary bank in the EU-family model typically has nothing of the designated person’s to freeze mid-chain at all: under this same logic, none of the intervening correspondent legs constitute the beneficiary holding anything either, right up until the final beneficiary’s bank accepts.
One thing worth keeping separate: this settles whether the Scenario A/B line is legally real rather than cosmetic — it doesn’t reopen the policy question of whether refuse is a strong enough response on its own. Those are different questions.
The following individual has been added to OFAC’s SDN List:
OFAC Programs:
SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
IFSR Iranian Financial Sanctions Regulations, 31 CFR part 561
TANG, Xin
AKA: “TANG, Mike”
Address: China
DOB: 16 Dec 1969
Nationality: China
Gender: Male
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
National ID No.: 110105196912164113 (China)
Party Type: Individual
Linked to: MAHAN AIR
Supplemental Information: Per Treasury, Tang Xin is the managing director of Shanghai Wings International Logistics Co, having coordinated travel for Mahan Air, and is also the executive director and 50 percent owner of Shanghai Elite International Travel Co, another Mahan Air representative in China. Mahan Air, sanctioned by both the United States and the European Union, has long served as the IRGC’s airline of choice despite presenting itself as a civilian carrier, providing travel services for IRGC-Qods Force personnel and supporting Iran’s procurement and transport of UAV systems and weapons. OFAC first designated Mahan Air under E.O. 13224 in October 2011 for supporting the IRGC-Qods Force, which OFAC had designated in October 2007; the IRGC itself was designated by State under E.O. 13382 in 2007 and by OFAC under E.O. 13224 in October 2017. Tang Xin is designated for providing material or technological support to Mahan Air.
The following entities have been added to OFAC’s SDN List:
OFAC Programs:
SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
IFSR Iranian Financial Sanctions Regulations, 31 CFR part 561
AIR CARGO PRO LIMITED
AKA:
AIRCARGOPRO LTD
LIMITED LIABILITY COMPANY AIRCARGOPRO
Address: Moscow, Russia
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
Organization Established Date: 26 May 2010
Tax ID No.: 5047116112 (Russia)
Linked to: MAHAN AIR
Supplemental Information: Per Treasury, Air Cargo Pro Limited serves as Mahan Air’s general sales agent in Russia, handling sales and customer support and liaising with freight forwarders and shippers on the airline’s behalf. It is designated for materially supporting Mahan Air.
SHANGHAI ELITE INTERNATIONAL TRAVEL CO LTD (Chinese Simplified: 上海马汉国际旅行社有限公司)
AKA: SHANGHAI MAHAN INTERNATIONAL TRAVEL SERVICE COMPANY LTD
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
Organization Established Date: 24 Feb 2014
Tax ID No.: 310104087826111 (China)
Registration Number: 310104000567670 (China)
Unified Social Credit Code (USCC): 913101040878261110 (China)
Linked to: TANG, Xin
Supplemental Information: Per Treasury, Shanghai Elite International Travel Co Ltd (also doing business as Shanghai Mahan International Travel Service Company Ltd) represents Mahan Air in China. It is majority-owned and directed by Tang Xin, who holds a 50 percent stake and serves as its executive director, and is designated for being owned, controlled, or directed by him.
SHANGHAI WINGS INTERNATIONAL LOGISTICS CO (Chinese Simplified: 上海翼上国际货运有限公司)
AKA:
SHANGHAI WINGS INTERNATIONAL FREIGHT CO LTD
SHANGHAI YISHANG INTERNATIONAL FREIGHT CO LTD
Address:
Shenzhen, Guangdong, China
Room 172, Building A, No. 888, Huanhu West, 2nd Road, Lingang New Area, Pilot Free Trade Zone, Shanghai 200120, China
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
Organization Established Date: 15 Jan 2021
Trade License No.: 310142000159721 (China)
Unified Social Credit Code (USCC): 91310000MA1H3GWY6C (China)
Linked to: MAHAN AIR
Supplemental Information: Per Treasury, Shanghai Wings International Logistics Co serves as a general sales agent for Mahan Air and has coordinated the transport of electronics from China to Iran. Its managing director, Tang Xin, has also coordinated travel arrangements for Mahan Air. It is designated for materially supporting Mahan Air.
SKIEZ TRAVELS AND LOGISTICS PRIVATE LIMITED
AKA:
SKIEZ TRAVELS AND LOGISTICS PVT LTD
“SKIEZ TRAVEL”
Address:
Srinagar, Jammu and Kashmir 190001, India
A-287, Second Floor, Defence Colony, New Delhi, Delhi, India
Supplemental Information: Per Treasury, Skiez Travels and Logistics Private Limited serves as Mahan Air’s general sales agent in India. It is designated for materially supporting Mahan Air.
OFAC Program: SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
DADENEGAR STARTUP STUDIO
Address:
Fereydounkhani Street, South Dibaji, Tehran, Iran
Heravi Hossein Abad, Tehran, Iran
6743 W 75th St, Al Fallujah, Al Anbar Governate 31002, Iraq
Supplemental Information: Per State and Treasury, DadeNegar Startup Studio is an IRGC-affiliated front company that used a website to solicit the locations of American and Israeli military equipment in the Middle East in support of Iranian military targeting; in coordination with the IRGC, it received strike requests against U.S. targets in the region. It is designated for materially supporting the IRGC.
Amendments:
The following changes have been made to OFAC’s SDN List:
OFAC Programs:
NPWMD Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544
IFSR Iranian Financial Sanctions Regulations, 31 CFR part 561
DURANSOY, Cagri
Address: Turkey
DOB: 04 Aug 1985
POB: Kadikoy, Turkey
Nationality: Turkey
Additional Sanctions Information: Subject to Secondary Sanctions
By refusing or rejecting a transaction, isn’t the regulator copping out? After all, the transaction could be accomplished somewhere else – say, in China or Turkey
Claude responded:
It’s a fair gut reaction, but it conflates two different questions: “does this stop the sanctioned party from ever getting the money” and “what happens to the specific transaction sitting in front of this specific firm.” Those aren’t the same question, and once you separate them, block doesn’t actually beat reject on the first one.
The workaround problem is real, but it’s not a reject-specific problem
If a UK bank refuses to send the payment, sure, the customer can try Beijing, Istanbul, or Dubai. But if a US bank blocks the payment instead, the designated person’s next attempt at financing can just as easily route through those same channels — blocking one wire doesn’t inoculate the rest of their commercial life. This is a well documented, general limitation of unilateral and even coordinated multilateral sanctions: research on sanctions evasion has tracked how Chinese and Russian arms have continued flowing to embargoed destinations for decades through non-dollar channels that sit outside any single regime’s reach. So “they’ll just go elsewhere” is a real critique of sanctions regimes in general — it applies to block just as much as reject. Neither mechanism solves global circumvention; both only capture what happens to already be within a given firm’s grasp at a given moment.
So is releasing that specific transaction really nothing?
Not quite. A rejected payment still comes with a mandatory report to the competent authority in every jurisdiction covered so far — so even though the money moves on, the attempt gets logged: who tried to pay whom, through which counterparties, on what pretext. That’s raw material for future listings, for identifying facilitators, and for building the kind of evidentiary record these regimes’ own courts increasingly demand. It’s a much thinner form of “action” than seizing the money, and it isn’t honest to pretend otherwise — but it isn’t nothing either.
The real reason isn’t laziness, it’s legal exposure
Here’s the part that actually answers the question. The EU, UK, Switzerland, Canada, and Australia are all legal systems where courts have been genuinely aggressive about policing sanctions listings on due-process and property-rights grounds — and the cleanest illustration is that the same person, Mr. Kadi, brought parallel challenges in EU and US courts over the same asset freeze, and the EU courts ruled the listing process lacked fundamental protections while the US courts rejected the equivalent constitutional claims. If that’s how exacting these courts are about freezing a person who has actually been designated, extending that seizure power further — to a non-designated customer’s own money, based solely on their stated intent to pay someone else — would be a considerably bigger and more legally exposed step, one these systems have chosen not to take. The US, operating under IEEPA’s far more executive-deferential tradition, doesn’t face the same internal constraint, which is a large part of why it’s comfortable blocking property whose ownership hasn’t fully vested yet.
There’s a structural reason layered on top of the legal one. The US can afford to cast that wide a net because so much of world trade has no way to avoid touching dollar clearing — roughly 88 percent of foreign-exchange transactions involve the dollar, and the correspondent banking system that actually moves the money concentrates through a small number of banks in New York and London. Blocking a dollar payment captures real marginal value precisely because rerouting around the dollar is genuinely hard. A rejected euro, pound, franc, Canadian, or Australian dollar payment is comparatively easy to complete elsewhere without touching that currency’s clearing system at all, so the deterrent value of seizing a non-designated customer’s funds is lower relative to the legal and political cost of doing it — this half of the explanation is an original synthesis of the two facts above, not something any regulator has stated as its rationale.
And this isn’t a “the EU goes soft” story — the freeze side still bites, hard
Worth remembering: none of this caution applies once a resource actually belongs to the designated party. The clearest proof is sitting in Belgium right now — roughly €210 billion of Russian Central Bank reserves are frozen in Europe, most of it at the Euroclear depository, and that’s a Scenario B freeze, not a reject outcome, because those securities already belonged to the CBR the moment it was designated. And the EU’s own hesitation about going one step further — from freezing that money to actually using it for a reparations loan — is itself a live demonstration of the exact caution just described: Belgium has resisted precisely on expropriation grounds, warning other reserve holders might flee European custody, and Russia’s central bank has already sued Euroclear for roughly $230 billion over the freeze itself. That’s not a regime being casual about property rights; if anything it’s the same instinct that keeps the reject rule in place for in-flight payments, now playing out at nation-state scale.
Self-check
Kadi I/II outcomes and the EU/US divergence: confirmed across multiple sources including a direct comparison piece and the CJEU’s own case summary.
Dollar/FX and correspondent-concentration figures: from a 2026 explainer drawing on the Farrell & Newman “weaponized interdependence” literature — solid secondary sourcing, not a primary BIS/Fed data pull.
Euroclear/CBR figures (~€210bn, ~€193bn at Euroclear, Belgium’s objections, the Russian lawsuit): converging figures across CFR, CEPR, Squire Patton Boggs, and AP reporting from November 2025–January 2026 — figures move slightly by source and date, so treat the exact number as “roughly €200–210bn” rather than a fixed figure if publishing this.
The causal argument connecting legal-rights culture and dollar centrality to the reject/block design choice is original synthesis — no regulator has published that rationale in those terms.
The following entities have been added to OFAC’s SDN List:
OFAC Program: IRAN-EO13902 Executive Order 13902
BILLION NEXUS INT’L CO., LIMITED
AKA: BILLION NEXUS INT’L CO LTD
Address: Unit 60, 3rd Floor, Yau Lee Centre, 45, Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong, China
Organization Established Date: 22 Jul 2025
Identification Number: IMO 0306224
Business Registration Number: 78498463 (Hong Kong)
Supplemental Information: Billion Nexus Int’l Co., Limited, based in Hong Kong, owns and operates the crude oil tanker AL SALMI, which has moved hundreds of thousands of barrels of Iranian oil to China since 2025. It is one of eight companies designated today for operating in Iran’s petroleum sector, part of a broader campaign that has now covered more than 100 vessels linked to Iran’s shadow fleet since the start of the year.
BRANCH SAYING INTERNATIONAL TRADING CO LTD
Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
Organization Established Date: 10 Sep 2025
Identification Number: IMO 0359778
Business Registration Number: 133779 (Marshall Islands)
Supplemental Information: Branch Saying International Trading Co Ltd, based in the Marshall Islands, owns the crude oil tanker YEHOPE, which has carried hundreds of thousands of barrels of Iranian crude to China in 2026. It is designated for operating in Iran’s petroleum sector.
Address: Room D, 10th Floor, Tower A Billion Centre, 1, Wang Kwong Road, Kowloon Bay, Kowloon, Hong Kong, China
Organization Established Date: 31 Dec 2024
Identification Number: IMO 0123299
Business Registration Number: 77537070 (Hong Kong)
Supplemental Information: Confident Apex Limited, based in Hong Kong, owns and operates the crude oil tanker LILY (also known by the name “DANYA”), which has carried millions of barrels of Iranian oil since 2025. It is designated for operating in Iran’s petroleum sector.
Additional Sanctions Information: Subject to Secondary Sanctions
Organization Established Date: 2026
Organization Type: Financial and Insurance Activities
Supplemental Information: Per Treasury and State, HormuzSafe (also marketed as Hormuz Safe) is an Iranian digital insurance venture developed by Iran’s Ministry of Economy that advertises maritime services – insurance, traffic control, security, and emergency response – to vessels transiting the Strait of Hormuz. It accepts Bitcoin and other digital-asset payments as part of the regime’s efforts to route around Western sanctions, and was promoted to social media followers by previously sanctioned regime financier Babak Morteza Zanjani. Along with the Persian Gulf Marine Insurance Company, HormuzSafe brokers IRGC-approved policies covering risks – chiefly vessel seizure – that Iran itself largely manufactures, generating revenue for IRGC operations. It is designated for operating in the financial sector of the Iranian economy.
MARINOVA FREIGHT LIMITED
Address: Room 310 3/F, Stag Building, 148-150 Queen’s Road Central, Hong Kong, China
Organization Established Date: 26 Mar 2026
Identification Number: IMO 0451967
Business Registration Number: 80062070 (Hong Kong)
Supplemental Information: Marinova Freight Limited, based in Hong Kong, owns, operates, and manages the crude oil tanker NATSUMI, which has carried millions of barrels of Iranian crude to China since 2022. It is designated for operating in Iran’s petroleum sector.
NEVADA SPIRIT COMPANY LIMITED
AKA: NEVADA SPIRIT CO LTD
Address: Rm 8 15/F Witty Coml Bldg, 1A-1L Tung Choi St, Mongkok, Kowloon, Hong Kong, China
Organization Established Date: 05 May 2022
Identification Number: IMO 6326461
Business Registration Number: 74012178 (Hong Kong)
Supplemental Information: Nevada Spirit Company Limited, based in Hong Kong, owns and operates the crude oil tanker BREEZE V, which has carried millions of barrels of Iranian oil to China in 2026. It is designated for operating in Iran’s petroleum sector.
OCEAN TRANQUILITY LIMITED
Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
Organization Established Date: 18 Feb 2022
Identification Number: IMO 6357680
Business Registration Number: 113191 (Marshall Islands)
Supplemental Information: Ocean Tranquility Limited, based in the Marshall Islands, owns, operates, and manages the crude oil tanker NIRETA, which has carried hundreds of thousands of barrels of Iranian crude to China in 2026. It is designated for operating in Iran’s petroleum sector.
PERSIAN GULF MARINE INSURANCE COMPANY (Arabic: شركة تأمین الخلیج الفارسي البحري)
Address: Iran
Additional Sanctions Information: Subject to Secondary Sanctions
Organization Established Date: 2026
Organization Type: Financial and Insurance Activities
Supplemental Information: Per Treasury, the Persian Gulf Marine Insurance Company (PGMIC) was established by the Central Insurance of the Islamic Republic of Iran, the country’s primary insurance regulator. PGMIC brokers and issues policies approved by the Persian Gulf Strait Authority (PGSA), an IRGC-backed body Treasury designated on May 27, 2026 pursuant to E.O. 13224, as amended, for materially supporting the IRGC. PGMIC’s coverage addresses risks – most notably vessel seizure – that are largely of Iran’s own making, generating revenue that helps fund the regime’s terror and corruption. It is designated for operating in the financial sector of the Iranian economy.
QI HANG SHIP MANAGEMENT LIMITED (Chinese Traditional: 啟航船舶管理有限公司)
Address:
Room D, 16th Floor, China Merchants Tower, 1008, Wanghai Lu, Nanshan Qu, Shenzhen, Guangdong, China
Rm 30 3/F East Sun Indl Ctr Blk A, 16 Shing Yip St, Kwun Tong, Kowloon, Hong Kong, China
Organization Established Date: 29 Jul 2025
Identification Number: IMO 0301550
Business Registration Number: 78537348 (Hong Kong)
Supplemental Information: Qi Hang Ship Management Limited, based in China and Hong Kong, owns, operates, and manages the chemical/products tanker WELL SAIL, which has carried hundreds of thousands of barrels of Iranian petroleum products to the United Arab Emirates in 2026. It is designated for operating in Iran’s petroleum sector.
VAST MIGHTY LIMITED
Address:
12th Floor, Fu Cheong Centre 5-7, Wong Chuk Yeung Street, Fo Tan, Sha Tin, New Territories, Hong Kong, China
Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
Organization Established Date: 30 Sep 2022
Alt. Organization Established Date: 06 Jul 2023
Identification Number: IMO 0024761
Business Registration Number: 120802 (Marshall Islands)
Registration Number: 74471259 (Hong Kong)
Supplemental Information: Vast Mighty Limited, based in Hong Kong and the Marshall Islands, owns, operates, and manages the crude oil tanker CRYSTAL, which has carried millions of barrels of Iranian crude to China in 2026. It is designated for operating in Iran’s petroleum sector.
The following vessels have been added to OFAC’s SDN List:
OFAC Program: IRAN-EO13902 Executive Order 13902
AL SALMI
Vessel Type: Crude Oil Tanker
Vessel Flag: Unknown
Former Vessel Flag: Panama
Vessel Year of Build: 2005
Vessel Registration Identification: IMO 9298296
Party Type: Vessel
Linked to: BILLION NEXUS INT’L CO., LIMITED
Supplemental Information: Per Treasury, AL SALMI has transported hundreds of thousands of barrels of Iranian oil to China since 2025.
BREEZE V (8P2249)
Vessel Type: Crude Oil Tanker
Vessel Flag: Barbados
Vessel Year of Build: 2003
Vessel Registration Identification: IMO 9259355
MMSI: 314887000
Party Type: Vessel
Linked to: NEVADA SPIRIT COMPANY LIMITED
Supplemental Information: Per Treasury, BREEZE V has transported millions of barrels of Iranian oil to China in 2026.
CRYSTAL (YJRP6)
Vessel Type: Crude Oil Tanker
Vessel Flag: Vanuatu
Vessel Year of Build: 2002
Vessel Registration Identification: IMO 9223887
MMSI: 577706000
Party Type: Vessel
Linked to: VAST MIGHTY LIMITED
Supplemental Information: Per Treasury, CRYSTAL has transported millions of barrels of Iranian crude oil to China in 2026.
LILY (3EVK3)
AKA: “DANYA”
Vessel Type: Crude Oil Tanker
Vessel Flag: Mozambique
Former Vessel Flag: Panama
Vessel Year of Build: 2005
Vessel Registration Identification: IMO 9294331
MMSI: 353502000
Party Type: Vessel
Linked to: CONFIDENT APEX LIMITED
Supplemental Information: Per Treasury, LILY has transported millions of barrels of Iranian oil since 2025.
NATSUMI (8PTM)
Vessel Type: Crude Oil Tanker
Vessel Flag: Barbados
Vessel Year of Build: 2006
Vessel Registration Identification: IMO 9331244
MMSI: 314231000
Party Type: Vessel
Linked to: MARINOVA FREIGHT LIMITED
Supplemental Information: Per Treasury, NATSUMI has transported millions of barrels of Iranian crude oil to China since 2022.
NIRETA (YJRR9)
Vessel Type: Crude Oil Tanker
Vessel Flag: Vanuatu
Vessel Year of Build: 2003
Vessel Registration Identification: IMO 9237785
MMSI: 577715000
Party Type: Vessel
Linked to: OCEAN TRANQUILITY LIMITED
Supplemental Information: Per Treasury, NIRETA has transported hundreds of thousands of barrels of Iranian crude oil to China in 2026.
WELL SAIL (V7A4071)
Vessel Type: Chemical/Products Tanker
Vessel Flag: Marshall Islands
Vessel Year of Build: 2007
Vessel Registration Identification: IMO 9321938
MMSI: 538012177
Party Type: Vessel
Linked to: QI HANG SHIP MANAGEMENT LIMITED
Supplemental Information: Per Treasury, WELL SAIL has transported hundreds of thousands of barrels of Iranian petroleum products to the United Arab Emirates in 2026.
YEHOPE (8PPX)
Vessel Type: Crude Oil Tanker
Vessel Flag: Barbados
Vessel Year of Build: 2003
Vessel Registration Identification: IMO 9243320
MMSI: 314001154
Party Type: Vessel
Linked to: BRANCH SAYING INTERNATIONAL TRADING CO LTD
Supplemental Information: Per Treasury, YEHOPE has transported hundreds of thousands of barrels of Iranian crude oil to China in 2026.
ok… let’s open the aperture a bit. Explain what a compliant firm is supposed to do, for the US, UK, EU, Canada, Australia and Switzerland, in the following 2 scenarios – assuming we’re talking blocking/freezing sanctions only: Scenario A: You receive instructions to make a payment that involved a sanctioned party. Scenario B: You receive funds that involve a sanctioned party. For each scenario, also denote whether the answer is different in the case you are the beneficiary bank or an intermediary bank. Phrase this for a sanctions novice, but feel free to quote text (not full regulatory sections) – like “make economic resources available”, for example. Assume that my goal is to eventually, once I refine the response, make a “Burning Questions” post out of this
Claude responded:
This is exactly the kind of question that makes a good Burning Questions piece, because the honest answer isn’t “six jurisdictions, six rules” — it’s one rule almost everyone agrees on, and one narrow but consequential place where the US breaks from the rest.
Two moves, and two roles, defined simply
A compliant firm facing a sanctioned party has two different levers available, and confusing them is the single most common mistake:
Freeze/block: take the resource into your own custody, lock it away from everyone — including the customer who originally owned it — and report it. Nobody gets it until a regulator says otherwise.
Refuse/reject: simply decline to carry out the instruction. The money never leaves the paying customer’s account, so there’s nothing to freeze.
And two roles matter for how this plays out:
Beneficiary bank: the bank holding the account of the person or entity who’s supposed to end up with the money.
Intermediary (correspondent) bank: a bank in the middle of the chain, routing the payment onward, with no account relationship to either the sender or the ultimate recipient.
Scenario A: you receive instructions to make a payment that involves a sanctioned party
Picture a customer who isn’t sanctioned asking you to send money to someone who is.
Jurisdiction
What you do
Beneficiary vs. intermediary bank
US (OFAC)
Block. Take the funds into a blocked, interest-bearing account. Don’t send them, and don’t hand them back to the customer either.
No difference in principle — blocking applies regardless of whether it is the originating or intermediary bank in the chain. A purely blind intermediary with no account relationship to a non-listed related party gets a narrow pass on investigating what it has no way of knowing, but the moment it knows or should know a designated person is involved, it blocks too.
UK (OFSI)
Refuse. Don’t execute the payment; the customer’s own funds are untouched.
Same principle for any bank in the chain — but correspondent banks caught mid-chain have created a genuine practical headache here (see below).
EU
Refuse — going ahead would mean making economic resources available to the designated person, which every EU regulation prohibits directly or indirectly.
Same in principle for whoever in the chain is asked to move the money.
Switzerland (SECO)
Refuse, for the same reason — Swiss ordinances closely mirror the EU wording, prohibiting third parties from making economic resources available to a listed person.
Same in principle.
Canada
Refuse — completing the payment would breach the ban on making any goods available to a designated person, or providing services to their benefit.
Same in principle, though published Canadian guidance addressing intermediary banks specifically the way the US and UK have could not be located.
Australia (DFAT/ASO)
Refuse — a person commits an offence if they make assets available to a designated person or entity.
Same in principle.
The one country that flips the answer is the US, and it’s worth pausing on why. OFAC treats a designated person’s status as intended beneficiary of a payment as itself an “interest” in the funds, so the moment the firm has possession or control of the money for the purpose of sending it their way, it’s already blockable property — even though it started out as the customer’s own money and never actually reached anyone. Everyone else in this table requires the resource to actually belong to, or be held or controlled by, the designated person before the freeze duty exists — and a payment instruction that hasn’t been executed yet doesn’t meet that bar. So the divergence isn’t really about freeze versus reject as competing philosophies; it’s about how early each regime decides a sanctioned party has acquired an interest in money that hasn’t arrived yet.
Scenario B: you receive funds that involve a sanctioned party
Now flip it: money has actually arrived, or is already sitting in an account, where a designated person has a real, present interest — as the account holder, or as the completed beneficiary of an inbound transfer.
Jurisdiction
What you do
Beneficiary vs. intermediary bank
US (OFAC)
Block, and report within 10 business days.
No difference — whoever’s possession or control the funds come within, blocks, subject to the same narrow intermediary safe harbor as above.
UK (OFSI)
Freeze, and report.
The beneficiary bank freezes without question. An intermediary bank is generally fine to keep routing a payment onward provided the funds aren’t owned, held, or controlled by a designated person at the point it’s dealing with them — which gets complicated fast if a designated bank sat somewhere upstream (see below).
EU
Freeze, and report to the national competent authority. Notably, a bank is explicitly permitted to credit an incoming third-party payment into a frozen account without needing prior authorization for that specific act — the funds simply join the frozen pool once they land.
Same logic as the UK: a true intermediary that never holds the designated person’s resources has nothing to freeze; a beneficiary bank freezes on receipt.
Switzerland
Freeze, and report to SECO.
Same principle as the EU.
Canada
Freeze (functionally, by disclosing the property to the RCMP and being barred from dealing with it) — firms must report property in their possession or control that is owned or controlled by designated persons and freeze such property.
Same principle, applied to whoever holds it.
Australia
Freeze, and notify the Australian Federal Police.
Same principle for whoever is holding the asset.
This is really the headline finding: on receipt, all six jurisdictions land in the same place. The freeze duty is nearly universal once a designated person actually has a stake in the resource — the interesting divergence lives entirely in Scenario A, where the US alone extends that duty backward to cover an unexecuted instruction.
Two wrinkles worth knowing for intermediary banks specifically
US: OFAC’s own guidance draws the safe-harbor line precisely. An intermediary bank with no account relationship to a non-listed party referenced in a wire, and no actual or constructive knowledge of a blocking issue, isn’t expected to go digging — but the instant it has information suggesting blocked status, the duty to block attaches regardless of its position in the chain.
UK: because the UK (unlike the EU generally) has designated entire banks, correspondent banks kept finding themselves holding payments that had passed through a now-designated bank somewhere upstream, with no clean way to either complete or return them — the industry calls these “trapped payments.” OFSI’s analysis turned on whether the designated bank still had a right of countermand over the funds at that point in the chain: if it had already discharged its role and lost any right to pull the funds back, the funds were no longer considered owned, held, or controlled by that designated bank, so the freeze duty didn’t travel downstream with it. That general licence has since been superseded by later amendments, so it’s an illustration of the reasoning rather than current operative guidance — worth pulling OFSI’s live Russia guidance before citing the mechanism itself.
EU: Regulation 36/2012 Article 14 template and the Council’s July 2024 Best Practices document, both previously verified.
UK: OFSI’s general guidance and reporting pages (gov.uk, ofsi.blog.gov.uk) plus the Trapped Payments general licence publication notice — flagged above as superseded, useful for the reasoning, not for current citation.
Canada: Global Affairs Canada’s own “Dealings prohibition and asset freeze” and disclosure pages — solid primary sourcing, but nothing found specific to intermediary-bank treatment; that’s a gap in published guidance, not a claim made by extension.
Australia: DFAT/Australian Sanctions Office guidance notes, all primary and current (2024–2025 dated).
Switzerland: sourced mainly through a Swiss press account describing the ordinance language rather than a direct ordinance or SECO FAQ pull — worth swapping in the exact ordinance article, and worth checking whether SECO’s FAQs address this reject/freeze point directly before publishing.
The “when does an interest attach” framing that ties the whole piece together is an original synthesis of the sourced material above, not a line any one source states outright.
On July 27, 2026, OFAC published its second round of list “modernization” housekeeping in as many months, this time touching the SDN List, the Sectoral Sanctions Identifications (SSI) List, and the Non-SDN Palestinian Legislative Council (NS-PLC) List. There are no new SDN designations in this update — it is entirely deletions, amendments, and one net-new addition (a consolidated Ismail Haniyah entry, discussed below). The accompanying Treasury press release is “Second Round of Sanctions Removals, Updates in Modernization Initiative.”
The throughline for the whole update is one OFAC has been chipping away at for a while: retiring the old convention of listing every known alias as its own free-standing, fully-detailed SDN entry, in favor of a single record with an AKA field. OFAC’s own framing: it has “consolidated 18 duplicate list entries in which a distinct target appears on OFAC’s sanctions lists multiple times.” The persons and property behind the deleted entries remain sanctioned; only the redundant entries are removed. The same dynamic shows up three times over in this update, at three different scales:
18 duplicate entries formally consolidated across the SDN, SSI, and NS-PLC Lists (chart below);
286 SDN deletions, a meaningful share of which are old-style per-alias duplicate listings for designees who remain sanctioned under a different, still-active entry;
19 SSI deletions that are simply old aliases of the 4 entities added to the SSI List in this same update; and
3 NS-PLC deletions that collapse into the 1 new, consolidated Ismail Haniyah entry.
Duplicate List Entry Consolidation
OFAC’s own chart, reproduced below: for each row, the “Deleted UID” entry was removed as a duplicate and the “Retained UID” entry is the one that survives (and, in four cases, was itself upgraded to a modern-format entry — see the SSI section below).
#
Name of Sanctioned Target Being Altered
Deleted UID
Retained UID
1
JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY ZAVOD IMENI PLANDINA
37526
47488
2
CSOFT DEVELOPMENT
48745
45766
3
JOINT STOCK COMPANY POLEMA
49463
49247
4
SPECIAL SYSTEMS PHOTONICS LIMITED LIABILITY COMPANY
Rows 15–18 are worth flagging up front: those four “retained” UIDs are the same four entities OFAC simultaneously re-added to the SSI List in modern, fully-detailed format (Cyrillic names, current addresses, tax IDs, directive determinations) — see the SSI section below. Rows 13–14 are a small, self-contained case: two different old-style deleted UIDs for the same person (ATIA, Hachim K.) both point to one retained UID.
Specially Designated Nationals List Updates
No additions. Two categories of change: 286 deletions and 37 amendments.
Deletions (286)
Every deleted entry carried exactly one program tag; the breakdown below is a complete count. As the consolidation chart above illustrates, a meaningful share of these are old-style, per-alias duplicate entries for designees who remain sanctioned under a separate, still-active SDN entry — deletion here does not mean the underlying person or entity is off the list, only that this particular free-standing record for one of their known names is gone. Two clusters stand out for a closer look if you work Iraq2 or counter-terrorism screening: the 42 IRAQ2 deletions are almost entirely Gulf War/Iraqi-sanctions-era shell and trading companies (many UK- and offshore-registered), and the SDGT/SOMALIA/SDNTK clusters below include long alias chains for a handful of underlying al-Shabaab, Sinaloa/Arellano Félix-era, and Golden Triangle-era designees.
[GLOMAG] — Executive Order 13818 (Global Magnitsky)
1
[IRAN-EO13846] — Executive Order 13846
1
Total
286
Full name list by tag:
[SDNTK] — 119 entries
Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598
“CHAYO”
“CHINO ANTRAX”
“CHOCLOS”
“EL CHAYO”
“EL DULCE”
“EL INDIO”
“EL MAS LOCO”
“EL MELLADO”
“EL MORENO”
“INGLATERRA”
“KIKE”
“LA CHIVA”
“LA COMADRE”
“LOCO”
“ORION”
“PAEZ Nachillo”
“PAEZ, Nacho”
“SAMUEL FLORES FLORES”
“TINO”
ADEMULERO, Babestan Oluwole
ADT PETROSERVICIOS
AFGHAN, Shear
AFGHAN, Sher
AFGHAN, Shir
ARECHIGA GAMBOA, Jose Rodrigo
ARELLANO FELIX, Ramon Eduardo
AZIZ, Mohammad
BABESTAN, Abeni O.
BABESTAN, Wole A.
CASTREJON PENA, Victor Nazario
CHAN, Changtrakul
CHANG, Chi Fu
CHANG, Ping Yun
CHANG, Shi-Fu
CHANG, Xifu
CHANGTRAKUL, Chan
COLORADO CESSA, Francisco Antonio
COMACHO RODRIGUES, Gilberto
FLORES BORREGO, Samuel
GALINDO MELLADO, Cruz
GARCIA ARBOLEDA, Edward
GIL, Josef
GILBERT, Joseph
GILBOA, Joseph
GILBOA, Joseph Papzian
GILBOA, Yosef
GONZALEZ GARZA, Rolando
GONZALEZ PIZANA JR., Rogelio
GONZALEZ PIZANA, Rogelio Kak, Jr.
HAMEIAH, Jamel
HAMEIAH, Jamil
HAMEIAH, Mamil
HAMEIEH, Jamil
HAMEIH, Jamill
HAMER, Jamil
HAMIAEH, Jamil
HAMIAH, Jamiel
HAMIE, Jamil
HAMIE, Jamil Abdulkarim
HAMIE, Jamile
HAMIEAH, Jamiel
HAMIEAH, Jamil
HAMIEH, Jamal
HAMIEH, Jamiel
HAMIEH, Jamil
HAMIEH, Mamil
HAMIEL, Jamil
HAMIEYE, Jamil
HAMIEYYEH, Jamil
HAMIL, Jamil
HAMIYA, Abdul Jamil
HAMIYE, Jamil
HAMIYYAH, Jamil
HAMIYYEH, Jamil
HAMYH, Jamil
HEATH, Noel Timothy
HERNANDEZ BARRON, Raul
HIGUERA GUERRERO, Ismael
INVERSIONES C.P.C.L. Y CIA. S. EN C.S.
KARIM, Jamil Abdul
KHAN, Abdullah
KHAN, Ali
KHAN, Nafir Ali
KHAN, Nasir Ali
KHAN, Nazir Ali
KHAN, Nisan Ali
KHAN, Nisar Ali
KHUN SA
KHUN, Saeng
LA TIENDA DE MINGO
MELLADO CRUZ, Galdino
MELLADO CRUZ, Galindo
MESA PAEZ, Aristides Manuel
MORENO GONZALEZ, Nazario
MORENO MADRIGAL, Nazario
MORENO, Chayo
MORENO, Jose
NASIR, Ali Khan
NASIR, Khan Ali
NAZIM, Abou
NEZAM, Abu
NIZAM, Abou
OGUNGBUYI, Abeni O.
OGUNGBUYI, Oluwole A.
OGUNGBUYI, Wally
OGUNGBUYI, Wole A.
PADIERNA PENA, Luis Orlando
PAEZ SOTO, Ramon Ignacio
PIZANA GONZALEZ, Rogelio
PLANCARTE SOLIS, Enrique
SHOFESO, Olatude I.
SHOFESO, Olatunde Irewole
SHOFESO, Olatutu Temitope
TORRES MENDEZ, Ramon
VALENZUELA VERDUGO, Jorge Mario
ZAMBA, Noel Heath
ZAMBO, Noel Heath
ZEVALLOS GONZALES, Ricardo
ZEVALLOS GONZALES, Winston Ricardo
[SDGT] — 52 entries
Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
“ABDALLA”
“ABDULLAH”
“ABU CHOLDER”
“ABU KHAOULA”
“ABU SOLAIMAN”
“ABU SOLAYMAN”
“AFADEY”
“AL-FATEH, Abu Hamzah”
“AL-INDONESI, Abu Walid”
“AL-INDUNISI, Abu-Walid”
“AL-LIBI, Shaykh Mahmud”
“AL-MALIZI, Abu Sayyaf”
“APONG SOLAIMAN”
“APUNG”
“MUHAMMAD, Muhammad”
“MUSSE”
“NUHR”
“SMAIL”
“SUDANI, Abdala”
ABD AL-RAHMAN, Atiyah
AL-LIBI, ‘Atiyah ‘Abd al-Rahman
AL-SHATIWI, Jamal
AL-SHITAYWI, Jamal Ibrahim Muhammad
AL-SHITIWI, Jamal
AL-SHTIWI, Jamal
AL-TURKI, Hassan
AL-TURKI, Hassan Abdullah Hersi
ATTO, Abdullah
BUR, Abdullah
DAWOUD, Muhammad
FAIZ, Mohammad Yusuf Karim
FAIZ, Mohammed Karim Yusop
FAIZ, Mohammed Yusop Karin
FAIZ, Mohd Karim Yusop
ISSA, Issa Osman
JEDI, Muhamad Wanndy Mohamad
JEDI, Muhamad Wanndy Muhamad
JEDI, Muhamad Wanndy bin Muhamad
JEDI, Muhammad Wanndy Bin Mohamed
MUZZAMIL, Mohammad Daoud
NUR, Mammam
NUR, Mohammad
NUR, Mohammed
NURA, Mohammed
NURU, Mallam Ahmed
SAIFUDDIN, Muhmmad
SALI JR., Jainal Antel
TUFAIL, Mohammed
TUFAIL, S.M.
TUFAIL, Sheik Mohammed
WANNDY, Muhamad
ZERFAOUI, Ahmad
[IRAQ2] — 42 entries
Executive Order 13315; Executive Order 13350
Note: “ATIA, Hachim K.” appears twice below — two separate old UIDs (8349 and 8350, per the consolidation chart above) for the same person, both retiring to retained UID 8348.
A.T.E. INTERNATIONAL LTD.
A.W.A. ENGINEERING LIMITED
ADMINCHECK LIMITED
ADVANCED ELECTRONICS DEVELOPMENT
AL PETRA COMPANY FOR GOODS TRANSPORT LTD
ARAB PETROLEUM ENGINEERING COMPANY LTD
ARCHI CENTRE I.C.E. LIMITED
ARCHICONSULT LIMITED
ASSOCIATED ENGINEERS
ATIA, Hachim K.
ATIA, Hachim K.
ATLAS AIR CONDITIONING COMPANY LIMITED
ATLAS EQUIPMENT COMPANY LIMITED
BAROON SHIPPING COMPANY LIMITED
ENDSHIRE EXPORT MARKETING
FALCON SYSTEMS
H & H METALFORM GMBH
H AND H METALFORM GMBH
I.P.C. INTERNATIONAL LIMITED
I.P.C. MARKETING LIMITED
INVESTACAST PRECISION CASTINGS
IRAQI ALLIED SERVICES LIMITED
IRAQI FREIGHT SERVICES LIMITED
IRAQI TRADE CENTER
JARACO S.A.
KEENCLOUD LIMITED
MEED INTERNATIONAL LIMITED
ORIENT SHIPPING LIMITED
PANDORA SHIPPING CO. S.A.
PETRA NAVIGATION & INTERNATIONAL TRADING CO. LTD.
PETRA NAVIGATION AND INTERNATIONAL TRADING CO. LTD.
RAJBROOK LIMITED
REYNOLDS AND WILSON
RWR INTERNATIONAL COMMODITIES
SOKTAR
T N K FABRICS LIMITED
T.E.G. LIMITED
TRADACO S.A.
TRADING & MARITIME INVESTMENTS
TRADING AND MARITIME INVESTMENTS
U.I. INTERNATIONAL
WHALE SHIPPING LTD.
[SOMALIA] — 22 entries
Somalia Sanctions Regulations, 31 C.F.R. part 551
“GODANE”
“GODANI”
“HASSAN, Sheikh”
“MUKHTAR, Shaykh”
“ZUBEYR, Abu”
ABU ZUBEYR, Muktar Abdirahman
ABUZUBAIR, Muktar Abdulrahim
ALI, Sheikh Hassan Dahir Aweys
AW MOHAMMED, Ahmed Abdi
AW-MOHAMED, Ahmed Abdi
AW-MOHAMUD, Ahmed Abdi
AWES, Hassan Dahir
AWES, Shaykh Hassan Dahir
AWEYES, Hassen Dahir
AWEYS, Ahmed Dahir
AWEYS, Hassan Dahir
AWEYS, Sheikh
AWEYS, Sheikh Hassan Dahir
DAHIR, Aweys Hassan
IBRAHIM, Mohammed Hassan
OAIS, Hassan Tahir
UWAYS, Hassan Tahir
[SDNT] — 13 entries
Narcotics Trafficking Sanctions Regulations, 31 C.F.R. part 536
“LUCAS”
“MECHAS”
“THE CHESS PLAYER”
AGRICOLA GANADERA HENAO GONZALEZ Y CIA. S.C.S.
ARIZONA S.A.
COMPANIA AGROINVERSORA HENAGRO LTDA.
DESARROLLOS COMERCIALES E INDUSTRIALES HENAO GONZALEZ Y CIA. S.C.S.
GONZALEZ BENITEZ, Olga Patricia
M.T.T. LTDA.
MAQUINARIA TECNICA Y TIERRAS LTDA.
ORGANIZACION EMPRESARIAL A DE J HENAO M E HIJOS Y CIA. S.C.S.
RENDON RAMIREZ, Jose Aldemar
RODRIGUEZ OREJUELA, Gilberto Jose
[RUSSIA-EO14024] — 13 entries
Executive Order 14024
CSOFT DEVELOPMENT
JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY FACTORY NAMED AFTER P. I. PLANDINA
JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY ZAVOD IMENI PLANDINA
JOINT STOCK COMPANY POLEMA
JOINT STOCK COMPANY SHIPREPAIRING CENTER ZVYOZDOCHKA
JOINT-STOCK COMPANY SHIP REPAIR CENTER ZVEZDOCHKA
JOINT-STOCK COMPANY TSS ZVEZDOCHKA
JSC ARZAMASSKY PRIBOROSTROITELNY ZAVOD NAMED AFTER PLANDIN
JSC CENTER SUDOREMONTA ZVEZDOCHKA (Cyrillic: АО ЦЕНТР СУДОРЕМОНТА ЗВЕЗДОЧКА)
SC ZVYOZDOCHKA
SHIPREPAIRING CENTER ZVYOZDOCHKA
SPECIAL SYSTEMS PHOTONICS LLC
USTINOV
[NPWMD] — 8 entries
Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544
KOREA KURYONGGANG TRADING CORPORATION
KOREA KUWOLSAN TRADING CORPORATION
KOREA RYENHAP 2 TRADING CORPORATION
KOREA TANGUN TRADING CORPORATION
RYUNG SENG TRADING CORPORATION
RYUNGSENG TRADING CORPORATION
RYUNGSONG TRADING CORPORATION
SECOND ACADEMY OF NATURAL SCIENCES FOREIGN AFFAIRS BUREAU
[LIBYA2] — 7 entries
Libyan Sanctions, 31 C.F.R. part 570
AL-ZULAYTINI, Abd-Al-Hafid Mahmud
ZLEITNI, Abdel-Hafez
ZLITNI, Abdelhafidh
ZLITNI, Abdul Hafid
ZLITNI, Abdul Hafiz
ZLITNI, Abdulhafid
ZLITNI, Abdulhafid Mahmoud
[DARFUR] — 6 entries
Sudan Stabilization Sanctions Regulations, 31 C.F.R. part 546
IBRAHIM, Khalil
MOHAMED, Khalil Ibrahim
SHANT, Adam Yacub
SHARIF, Adam Yacub
TAHA, Khalil Ibrahim Mohamed Achar Foudail
YACOUB, Adam
[TCO] — 2 entries
Transnational Criminal Organizations Sanctions Regulations, 31 C.F.R. part 590; Executive Order 13581
KIYOTA, Jiro
SIN, Byon-Gyu
[GLOMAG] — 1 entry
Executive Order 13818 (Global Magnitsky)
RIVAS REYES, Roberto Jose
[IRAN-EO13846] — 1 entry
Executive Order 13846
TASCA
Amendments (37)
These are before/after edits to existing SDN entries rather than deletions. Most add previously-unlisted AKAs, gender, nationality, or an identifier (a C.U.R.P. number shows up repeatedly across the Mexican narcotics-kingpin entries, for instance). A handful add a new program tag to an entry that was already listed under a different authority — worth a second look if you screen against a single tag rather than the full record. And a few, flagged individually below, are pure reformatting: an old free-text alias restyled into OFAC’s current “Surname, Given name” convention, not a newly-discovered identity.
#
Name
Program tag(s) after
What changed
1
AKTSIONERNOE OBSCHESTVO ARZAMASSKIY PRIBOROSTROITELNYI ZAVOD IMENI P I PLANDINA
[RUSSIA-EO14024]
added AKA(s): JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY FACTORY NAMED AFTER P. I. PLANDINA; JOINT STOCK COMPANY ARZAMASSKY PRIBOROSTROITELNY ZAVOD IMENI PLANDINA; JSC ARZAMASSKY PRIBOROSTROITELNY ZAVOD NAMED AFTER PLANDIN; org. established date added
2
AL-TURKI, Hassan Abdullah Hersi
[SDGT], [SOMALIA]
added tag SDGT; gender added; AKA restyled from a hyphen line-break artifact (“AL- TURKI”) to “AL-TURKI” — not a new spelling
gender added; C.U.R.P. identifier added; nationality field added/updated
28
OAO SHIP REPAIR CENTER ‘ZVEZDOCHKA’
[UKRAINE-EO13685], [RUSSIA-EO14024]
added tag(s) RUSSIA-EO14024; added AKA(s): JOINT STOCK COMPANY SHIPREPAIRING CENTER ZVYOZDOCHKA; JSC CENTER SUDOREMONTA ZVEZDOCHKA (Cyrillic: АО ЦЕНТР СУДОРЕМОНТА ЗВЕЗДОЧКА); Cyrillic name added; org. established date added
gender added; nationality field added/updated; freestanding “THET NAING WIN” retired now that the primary listing itself is properly split into surname/given-name fields
36
USTINOV
[UKRAINE-EO13661], [RUSSIA-EO14024]
added tag(s) RUSSIA-EO14024; Cyrillic name added; nationality field added/updated
Sectoral Sanctions Identifications (SSI) List Updates
Four entities added, in modern format — and these are exactly the four “retained UID” rows 15–18 from the consolidation chart above, now carrying Cyrillic names, current addresses, tax and registration identifiers, and an explicit EO 13662 directive determination (Directive 1 or Directive 3):
JOINT STOCK COMPANY UNITED ENGINE CORPORATION (Cyrillic: АКЦИОНЕРНОЕ ОБЩЕСТВО ОБЪЕДИНЕННАЯ ДВИГАТЕЛЕСТРОИТЕЛЬНАЯ КОРПОРАЦИЯ), a.k.a. “AO ODK,” Moscow; Directive 3 determination; Tax ID 7731644035 (Russia); Registration Number 1107746081717 (Russia); [UKRAINE-EO13662] [RUSSIA-EO14024]; Linked To: STATE CORPORATION ROSTEC.
LIMITED LIABILITY COMPANY KORUS CONSULTING CIS, St. Petersburg; Directive 1 determination; Tax ID 7801392271 (Russia); Registration Number 1057812752502 (Russia); [UKRAINE-EO13662] [RUSSIA-EO14024]; Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA.
OTKRYTOE AKTSIONERNOE OBSHCHESTVO VNESHNEEKONOMICHESKOE OBEDINENIE TEKHNOPROMEKSPORT, a.k.a. “JSC TPE,” Moscow; Directive 3 determination; Registration ID 1067746244026 (Russia); Tax ID 7705713236 (Russia); [UKRAINE-EO13662] [UKRAINE-EO13685]; Linked To: STATE CORPORATION ROSTEC.
SOVREMENNYE TEKHNOLOGII LIMITED LIABILITY COMPANY, Moscow; Directive 1 determination; Tax ID 7708229993 (Russia); Registration Number 1037708040468 (Russia); [UKRAINE-EO13662] [RUSSIA-EO14024]; Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA.
Nineteen deletions, all tagged [UKRAINE-EO13662] — every one of these is an old-style, single-alias entry for one of the four entities just added above:
LLC SOVREMENNYE TECHNOLOGII
MODERN TECHNOLOGIES LIMITED LIABILITY COMPANY
SOVREMENNYE TEKHNOLOGII, OOO
OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU SOVREMENNYE TEKHNOLOGII
KORUS CONSULTING CIS LIMITED LIABILITY COMPANY
LLL KORUS CONSULTING CIS
KORUS KONSALTING SNG, OOO
OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU KORUS KONSALTING SNG
OTKRYTOE AKTSIONERNOE OBSHCHESTVO UPRAVLYAYUSHCHAYA KOMPANIYA OBEDINENNAYA DVIGATELESTROITELNAYA KORPORATSIYA
Non-SDN Palestinian Legislative Council (NS-PLC) List Updates
One addition — a consolidated entry for HANIYAH, Ismail Abdul Salah (a.k.a. HANIEH, Ismail; a.k.a. HANIYA, Ismael; a.k.a. HANIYA, Ismail; a.k.a. HANIYAH, Ismael; a.k.a. HANIYEH, Ismail Abdel Salam Ahmed; a.k.a. HANIYEH, Ismayil; a.k.a. HANIYYAH, Ismail), DOB 1962, POB Shati refugee camp, Gaza Strip, tagged [SDGT] [NS-PLC]. Three deletions immediately follow: the old-style single/dual-alias entries “HANIYA, Ismail Abdul Salah,” “HANIYA, Ismail,” and “HANIYYA, Ismaeel” — all now folded into the one consolidated record above (row 11 in the chart, retained UID 23627).
