Mr. Sanctions

Category: US Treasury Department (US)

  • Burning Question: How New Is “New” in Operation Economic Outcast?

    I asked Claude the following this evening:

    Attached is today’s State Department Fact Sheet on “Operations Economic Outcast” and Treasury’s related press release. Also attached are Treasury Secretary Bessent’s related remarks. Look at these, and any 3rd party news and commentary pieces on today’s OFAC action. Summarize what happened, and analyze the short-term and longer-term implications of these actions. What is substantive, and what is rhetorical? Are there measures that will be implemented in the really near future, such that US consumers and voters are likely to see tangible benefits from these actions by Election Day in November 2026? Add any other commentary you find that adds to the overall picture. Check all that you write against the sources you use – and correct anything that is not well-supported by the sources. List the sources at the end. No hallucinations, please. Write this for an audience that has interest in US politics and the economy, but is not necessarily well-versed in sanctions except in the most basic way – so write accordingly.

    And here is Claude’s analysis of yesterday’s Iran sanctions actions and rhetoric – with some significant pushback from me on some elements that Claude initially thought too much of:

    Treasury and State spent August 24 rolling out “Operation Economic Outcast” with the kind of language usually reserved for military campaigns: an “economic D-Day,” a “zero leakage” approach, nearly 60 new entries on the SDN list, and five new sectoral determinations under Executive Order 13902 covering digital assets, technology, gold, aviation, and shipping. Secretary Bessent framed it as the start of a sustained campaign to collapse every remaining option for Tehran.

    That’s a lot of rollout. The burning question is how much of it is actually new, once you get past the press conference and into the designation text itself.

    The determinations nobody used

    Start with the five sectoral determinations, since that’s where the branding worked hardest. E.O. 13902 isn’t a new authority. Trump signed it in January 2020 to cover construction, mining, manufacturing, and textiles. Treasury added the financial sector that October. Petroleum and petrochemicals followed in October 2024. Digital assets, technology, gold, aviation, and shipping are the fourth round of sector additions to an order that’s now six and a half years old.

    That history matters for a second reason beyond age. Iran and the Government of Iran are already subject to a comprehensive US embargo under the ITSR. A sectoral determination adds nothing to what a US person is already barred from doing with Iran directly. Its entire function is secondary sanctions exposure for non-US persons. That works by giving OFAC an easier evidentiary path, operating in the sector rather than proving a specific significant transaction, to reach someone who isn’t otherwise within US jurisdiction. Whether a determination matters in practice depends entirely on whether OFAC designates anyone under it.

    So who did OFAC designate today under the five new sectors? Nobody. Every one of the roughly 60 new entries in the State Department fact sheet and the Treasury press release cites an authority that predates this week.

    AuthorityWhat it coversUsed for today’s designations?
    E.O. 13382 (2005)WMD and missile proliferationYes, the Hong Kong/China procurement network supporting Malek Ashtar University, the BRE Line logistics network
    E.O. 13694, as amended (2015 onward)Malicious cyber activityYes, the six individuals tied to Iran’s Ministry of Intelligence and Security
    E.O. 13224, as amended (2001)CounterterrorismYes, Mohammad Ahmed Suhil Fattouh, Ivan Obukhov, and their shipping vehicles
    E.O. 13902, financial sector determination (Oct. 2020)Iran’s financial sectorYes, the shell companies tied to Bank Melli’s shadow banking network
    E.O. 13902, petroleum sector determination (Oct. 2024)Iran’s petroleum and petrochemical sectorYes, the shadow fleet vessels and owners, the Wellbred trading network
    E.O. 13949 (2020)Conventional armsYes, the seven Iranian military officials named by State
    E.O. 13846 (2018)JCPOA reimposition, petroleum tradeYes, the petrochemical traders named by State
    E.O. 13902, the five sectors added Aug. 24, 2026Digital assets, technology, gold, aviation, shippingNo

    Five new sectors, zero new designees. That’s worth sitting with, because it’s a useful diagnostic for reading any Treasury rollout of this size. The announced legal architecture and the actual designation list are two different documents, and they don’t have to move together. A determination is Treasury giving itself a faster path to designate people operating in a sector. It isn’t a designation. Until OFAC puts a name under one of the five new sectors, the practical effect on Iran’s economy from that piece of Monday’s announcement is exactly zero, no different from the day before the press conference.

    There’s a comparison worth keeping in mind for judging how much these five sectors could eventually matter. When Treasury added the financial sector to E.O. 13902 in October 2020, analysts flagged it at the time as functionally close to a full embargo, since almost any transaction with an Iranian counterparty eventually touches Iran’s banking system somewhere. A narrower sector, like textiles or mining, only closes off that one line of business, and a counterparty can just trade in something else. Of this week’s five, shipping and gold probably have that kind of financial-sector-style reach, since they sit close to how Iran actually moves and stores value. Digital assets and technology are narrower by comparison, and aviation narrower still. None of that is testable yet. It’s a question about which sector Treasury reaches for first, once it reaches for any of them. Bessent told reporters he expects Treasury to designate a major financial institution later this week. Whether that designation cites one of Monday’s five new sectors, rather than the financial sector determination that’s already existed since 2020, is the detail worth checking when it happens.

    What the general license suspensions actually touch

    The other piece of Monday’s announcement billed as tightening the screws is the suspension of several general licenses. The Treasury release describes them as licenses that had authorized certain remittance payments to Iran and Iranian access to the US cultural and academic system. OFAC’s own recent actions listing for August 24 confirms Iran General License G, the academic exchange license in place since 2014, covering university exchange agreements, scholarships, and the administration of entrance exams for Iranian applicants, along with a license covering professional and amateur sports exchanges. Trade press reporting also has the personal, noncommercial remittance license under 31 CFR 560.550 suspended, with a wind down running through roughly September 8 under a newly issued General License BB.

    That’s a real change for the people who use those licenses. It isn’t a real change for the IRGC or for regime leadership, and the reason is built into how the licenses were written. General licenses covering personal remittances and academic exchange exist because they were carved out of the comprehensive embargo for individuals and civil society. As a matter of standard OFAC drafting, that class of license already excludes the Government of Iran and any blocked person from using it. The IRGC was never moving money through a remittance channel covered by GL 560.550, and regime officials weren’t the ones administering entrance exams under GL G. The population that loses access when these licenses come off the board is Iranian civilians receiving money from family abroad, and Iranian students, researchers, and athletes trying to participate in exchange programs. Regime and IRGC finance runs through exchange houses, shadow banking networks, gold, and crypto, the same channels the new designations and the sectoral determinations are aimed at, not through a university scholarship program.

    That’s a real tension in how Monday’s action describes itself. The stated target throughout is the regime and its enablers. The general license suspensions land somewhere else, on ordinary Iranians and on the people-to-people channels Iran sanctions programs have historically tried to preserve even during periods of maximum pressure, not on the regime the campaign says it’s targeting.

    What this adds up to

    None of this makes Monday’s action empty. Roughly 60 new SDN entries is a real expansion of target lists in networks already under scrutiny: the Hong Kong and China procurement chains, the shadow fleet, the MOIS cyber cluster, the oil brokerage networks running through the UAE and Singapore. Those designations use existing, well-tested authorities. They carry the consequences designations ordinarily carry:

    • Blocked property in the United States or in the hands of US persons
    • Correspondent banking exposure for foreign financial institutions that keep dealing with the newly listed parties
    • A paper trail other governments and banks will have to account for in their own due diligence

    The two pieces of Monday’s announcement built to sound the most unprecedented are the five new sectors and the general license suspensions. They’re also the two doing the least actual work right now. The determinations haven’t been used yet. The license suspensions hit civilians rather than the regime they’re framed as targeting. That’s a pattern worth checking for in any sanctions rollout that leans hard on scale and language. Look at what got designated under the headline new authority before assuming the headline new authority did anything. If Treasury designates a bank or a shipping registry under the aviation or shipping determination in the coming weeks, that’s the moment the unprecedented framing starts to earn itself. Until then, it’s capacity, not action.

    Source verification

    Sources checked directly: the State Department fact sheet and the Treasury press release announcing Operation Economic Outcast, both dated August 24, 2026; Secretary Bessent’s prepared remarks from the same day; and OFAC’s own recent actions listing for August 24, 2026, which confirms the suspension of Iran General License G and the sports and cultural exchange license. Every legal basis cited above for the roughly 60 new designations was checked against the authority codes in the two primary announcements rather than assumed. The E.O. 13902 sector determination history (2020 construction, mining, manufacturing, and textiles; October 2020 financial sector; October 2024 petroleum and petrochemicals) is confirmed against OFAC FAQ 831 and contemporaneous client alerts from that period. The personal remittance general license under 31 CFR 560.550 and the General License BB wind down window were reported by trade press covering the rollout and have not yet been independently pulled from OFAC’s own general license text. Treat that specific detail as reported rather than primary source confirmed until the underlying license is checked directly.

    —

    , , , , , , ,

  • August 24, 2026: OFAC Syria sanctions relief updates – press release and the updated Tri-Seal Advisory

    The Tri-Seal Advisory first, of course:

    syria_advisory_sanctions_relief_0Download

    And the press release from the Treasury site:

    Treasury and State Departments Deliver Additional Sanctions Relief on Syria

    August 24, 2026

    WASHINGTON—In line with President Trump’s promise to deliver sanctions relief to Syria, the U.S. Department of State today rescinded Syria’s designation as a State Sponsor of Terrorism, and revoked the designation of al-Nusrah Front, also known as Hay’at Tahrir al-Sham (HTS), as a Specially Designated Global Terrorist (SDGT) organization.  Concurrently, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed HTS from the Specially Designated Nationals and Blocked Persons List (“SDN List”). 

    “Treasury is following through on President Trump’s promise to give the Syrian people a chance at greatness,” said Secretary of the Treasury Scott Bessent. “Today’s action will help foster additional investment in Syria to promote political and economic stability.”

    Today’s action builds on the Department of State’s revocation of HTS’s designation as a Foreign Terrorist Organization on July 8, 2025.  For a summary of U.S. sanctions and export control relief for Syria to date, please refer to the Tri-Seal Advisory published by U.S. Departments of Commerce, Treasury, and State.   

    As a result of today’s action, HTS is no longer blocked pursuant to the Global Terrorism Sanctions Regulations, 31 CFR part 594, or Executive Order 13224, as amended.  U.S. persons do not require authorization from OFAC to engage in transactions or activities with HTS, provided such activities do not involve blocked persons or otherwise prohibited activities.

    The decision today to remove these restrictions on Syria does not change Treasury’s posture with regards to countering global terrorism and our commitment to hold bad actors in Syria accountable.  Concurrently with the removal of HTS as an SDGT, OFAC is designating two former HTS affiliates who continue to support al-Qa’ida and Hurras al-Din, respectively.  These two designations ensure appropriate measures are taken against terrorist financing threats and to further safeguard the stability and security of Syria.

    Today’s designations are being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended, which targets terrorist groups and their supporters.  The U.S. Department of State designated al-Qa’ida as a Foreign Terrorist Organization pursuant to section 219 of the Immigration and Nationality Act on October 8, 1999.  On September 25, 2001, the President identified al-Qa’ida as a Specially Designated Global Terrorist (SDGT) in the annex of E.O. 13224.  On September 10, 2019, the Department of State designated Hurras al-Din, al-Qa’ida’s affiliate in Syria, as an SDGT.

    Sa’d Bin Sa’d Muhammad Shariyan al-Ka’bi (al-Ka’bi) supervised the provision of financial and logistical support for terrorist groups, including transferring funds to al-Qa’ida leaders.  OFAC previously designated al-Ka’bi on August 5, 2015, pursuant to E.O. 13224 for his fundraising activities in support of HTS.  Al-Ka’bi is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, al-Qa’ida.

    Jamal Husayn Zayniyah (Zayniyah) has been a leader of Hurras al-Din since 2020, around when he left his role as a senior leader of HTS.  In that same period, Liwa al-Muqatileen Al-Ansar (LMA), a group founded by Zayniyah, split from HTS over strategic disputes.  Zayniyah and LMA continued to align themselves with al-Qa’ida and merged with Hurras al-Din around this time.  OFAC previously designated Zayniyah on November 10, 2016, for acting for or on behalf of HTS.  As of 2025, Zayniyah was forming a Hurras al-Din cell in Syria, which included teaching children how to use weapons and organizing a team to carry out assassinations.  Zayniyah is being designated pursuant to E.O. 13224, as amended, for acting or purported to act for or on behalf of, directly or indirectly, Hurras al-Din.

    SANCTIONS IMPLICATIONS

    As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.  In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.

    Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons.  OFAC may impose civil penalties for sanctions violations on a strict liability basis.  OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions.  In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons.  The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.  Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions.  Individuals located in the United States or abroad who provide information about sanctions violations to Treasury’s Financial Crimes Enforcement Network whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000.

    Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions.  OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority. 

    The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law.  The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.  For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC’s Frequently Asked Question 897 here and to submit a request for removal, click here.

    Click here for more information on the persons designated and any property identified as blocked today.

    —

    , , , ,

  • August 7, 2026: OFAC is last to the party?

    Just got this:

    Severing Iran’s Illicit Cash Pipeline

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, SPOKESPERSON

    AUGUST 7, 2026

    The United States is taking decisive action to cut the financial lifelines that sustain Iran’s ruling elite. Today, the U.S. Department of the Treasury took steps to dismantle a web of currency exchange houses and shell companies that helped Iran secretly move hundreds of millions of dollars through the international financial system. Through these networks, Tehran accessed oil revenue and evaded sanctions designed to curb its destabilizing activities, laundering funds using front companies.

    This action demonstrates the Trump Administration’s continued maximum pressure on Iran by cutting off resources the regime uses to threaten regional stability, support terrorism, and advance its military capabilities. By targeting the banks, exchange houses, and individual facilitators that operate this illicit system, the United States makes clear that those who help Iran evade sanctions will face serious consequences.

    The United States remains committed to working with partners across the region and the world to close every avenue Iran uses to fund its destabilizing activities. As the regime’s economic mismanagement and corruption become increasingly apparent to the Iranian people, actions like today’s further isolate the regime from the international financial system and reinforce that Iran’s continued support for terrorism and regional aggression will carry a steep and lasting cost.

    Today’s action is being taken pursuant to Executive Order (E.O.) 13902, which targets persons operating in Iran’s financial and petroleum sectors, and advances the President’s National Security Presidential Memorandum 2 (NSPM-2), to impose maximum pressure on Iran. This is OFAC’s eighth action in 2026 targeting Iran’s shadow banking apparatus, including Iranian banks and their rahbar front companies, exchange houses and their managers, major financiers, and the Iranian importers and exporters who rely on these financial networks to launder and repatriate revenues. Please see the Department of the Treasury’s press releases.

    but I have not gotten anything from OFAC yet – even checked the Recent Actions page.

    But the press release page already has 2 things with today’s date:

    August 7, 2026

    Treasury Sanctions Crypto Exchanges Funding Iran’s IRGC and Enabling Illicit Finance

    August 7, 2026

    Treasury Dismantles Iranian Regime’s Global Clandestine Currency Networks

    so, stay tuned? I’ll include both Treasury releases when we get the official stuff from OFAC (since my prompt includes the relevant info with the specific designations)

    —

    , , , , ,

  • June 18, 2026: Press releases from yesterday’s OFAC counter-terror designations

    United States Imposes Sanctions on Hizballah-Aligned Officials and Business Associates

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, SPOKESPERSON

    JUNE 18, 2026

    Today, the United States is designating two Hizballah-aligned Lebanese officials, as well as members of a Hizballah business network overseen by U.S.-designated Alaa Hassan Hamieh. These officials have used their influence to deliberately and systematically undermine the authority of the Lebanese state. By aligning themselves with Hizballah, a terrorist organization, they have prevented the Lebanese government from exercising full control over its territories and over its future. These activities obstruct efforts to restore a sovereign, independent Lebanon, instead entrenching a system of parallel power that keeps Lebanon weak and divided, at the expense of the entire Middle East. Additionally, we are designating more interlocutors of Alaa Hamieh and his network in Lebanon, Syria, Iraq, and Oman who raise funds, execute contracts, and operate front companies to generate revenue for Hizballah terrorists.

    Hizballah is a terrorist organization that puts Iran, not Lebanon, first. Hizballah is the single biggest obstacle to Lebanon’s recovery and future, and holds the state hostage to a permanent state of conflict. Those who continue to provide political cover and material support to Hizballah will suffer the consequences of their choices. For the sake of lasting peace in the region and Lebanese stability and prosperity, Hizballah must disarm, its infrastructure must be dismantled, and the Lebanese state must regain its control of Lebanon’s future. The United States will continue to target Hizballah’s finances and those who help the group undermine the state of Lebanon.

    Today’s action is being taken pursuant to the counterterrorism authority, Executive Order (E.O.) 13224, as amended. The U.S. Department of State designated Hizballah as a Specially Designated Global Terrorist (SDGT) pursuant to E.O. 13224 on October 31, 2001, and as a Foreign Terrorist Organization pursuant to section 219 of the Immigration and Nationality Act on October 8, 1997. More information on today’s designations can be found in Treasury’s Press Release.

    of course, the actual designations on the Recent Actions page didn’t have any press release, so… Treasury’s press release:

    PRESS RELEASES

    Treasury Targets Hizballah-Aligned Officials and Intensifies Pressure on Global Financial Network

    June 18, 2026

    WASHINGTON—Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating Hizballah-aligned Lebanese officials, as well as members of a Hizballah-associated business network overseen by Alaa Hassan Hamieh, also known as Alaa Hamieh.  The Lebanese officials designated today have used their influence to obstruct Lebanon’s peace process and delay the disarmament of Hizballah. OFAC is also expanding upon the March 20, 2026 designations of Alaa Hamieh and his business network by targeting additional interlocutors in Lebanon, Syria, Iraq, and Oman who raise funds, execute contracts, and operate front companies to generate revenue for Hizballah. 

    “Hizballah must disarm for Lebanon to achieve a secure and prosperous future,” said Secretary of the Treasury Scott Bessent. “Treasury will continue to target Hizballah’s financial networks and hold accountable those who enable the group to undermine the Lebanese state and threaten prospects for lasting peace.”

    Today’s action is being taken pursuant to the counterterrorism authority, Executive Order (E.O.) 13224, as amended.  The U.S. Department of State designated Hizballah as a Specially Designated Global Terrorist (SDGT) pursuant to E.O. 13224 on October 31, 2001, and as a Foreign Terrorist Organization pursuant to section 219 of the Immigration and Nationality Act on October 8, 1997. 

    HIZBALLAH-ALIGNED LEBANESE OFFICIALS

    Hizballah relies on a network of officials to maintain power and exert influence through all levels of the Lebanese political and security establishment.  Sleiman Antoine Frangie (Frangie) is the leader of the Lebanese Marada Movement and has used his strategic alliance with Hizballah to benefit his own political ambitions.  Frangie accepted financial support from Hizballah in exchange for supporting Hizballah’s efforts to target the parliamentary seats of reformist and independent members of parliament in Lebanese parliamentary elections.  

    Deputy Head of Hizballah’s political council Mahmoud Qamaticoordinates cash smuggling from Iran for Hizballah and advocates for Hizballah’s interests in Lebanon. 

    Sleiman Antoine Frangie is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods and services to or in support of, Hizballah.  Mahmoud Qamati is being designated pursuant to E.O. 13224, as amended, for having acted or purported to act on behalf of, directly or indirectly, Hizballah.

    ALAA HAMIEH AND MUHAMMAD AL-BAZZAL’S HIZBALLAH PROJECTS

    Alaa Hamieh and U.S.-designated Bahaa Addin Hashem

    Alaa Hamieh and U.S.-designated Bahaa Addin Hashem(Hashem) are co-owners of Lebanon-based Globe Technology Providers SARL (Globe SARL), which is the technical arm of the Hizballah-linked, Syria-based company Al-‘Ahd Company for Trade and Investment (Al-‘Ahd Company).  In early 2024, Hizballah finance team official Muhammad Al-Bazzal was instrumental in initiating Globe SARL’s contracts with the former al-Assad regime in Syria.  The al-Assad regime — a critical ally of Hizballah — agreed that U.S.-designated Hizballah finance team company G.M. Farm, represented by its local agent, al-Assad regime henchman Yasar Husayn Ibrahim’s business Al-‘Ahd Company, would supply and operate equipment for fees of nearly ten million dollars.  Profits from Globe SARL’s projects were divided between Hizballah-controlled Talaqi Group, Al-‘Ahd Company, and Globe SARL, which also runs various other projects generating revenue for the Hizballah finance team.  Alaa Hamieh owns and controls Oman-based Globe International SPC, which is a subsidiary of Globe SARL.  Globe International SPC’s bank accounts were used to process payments worth hundreds of thousands of dollars for Alaa Hamieh, including transfers related to Hizballah projects and designated companies Calllync Spolka Z Organiczona Odpowiedzialnoscia and Calllync Telekomunikacijske Storitve D.O.O. 

    Alaa Hamieh with deceased Hizballah Executive Council Leader Hashem Safieddine
    Alaa Hamieh with deceased Hizballah Executive Council Leader Hashem Safieddine

    In July 2025, Muhammad Al-Bazzal, Alaa Hamieh, and Maya Boustany, designated for her multiple roles at Alaa Hamieh’s companies, collaborated to establish an insurance company in Iraq.  The new company, Al-Shafa Administrative Services Limited (Al-Shafa), was led by Alaa Hamieh’s employee, Chief Executive Officer Wael Costanteen, and purported to focus on insurance management services.  In 2017, Alaa Hamieh founded Lebanon-based Tyke SAL, which is registered to engage in a variety of commercial and real estate activities.  In September 2023, Alaa Hamieh’s brother, Muhammad Hassan Hamieh (Muhammad Hamieh), took over Alaa Hamieh’s shares in Tyke SAL and joined the board of directors of the company.  As of December 2025, Muhammad Hamieh runs Tyke SAL. 

    Globe SARL is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, directly or indirectly, Alaa Hamieh and Hashem.  Al-‘Ahd Company is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods and services to or in support of, G.M. Farm.  Al-Shafa, Wael Costanteen, and Globe International SPC are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, directly or indirectly, Alaa Hamieh.  Tyke SAL is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, directly or indirectly, Muhammad Hamieh. 

    SANCTIONS IMPLICATIONS

    As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.  In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons. 

    Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons.  OFAC may impose civil penalties for sanctions violations on a strict liability basis.  OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions.  In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons.  The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.  Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions.  Individuals located in the U.S. or abroad who provide information about sanctions violations to FinCEN’s whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000.

    Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions.  OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.

    The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law.  The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.  For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC’s guidance on Filing a Petition for Removal from an OFAC List.

    —

    , , , ,

  • Summmary of Treasury’s Report to Congress on Innovative Tech to counter digital asset-based illicit finance

    The GENIUS Act Illicit Finance Innovation Congressional Report, released by the U.S. Treasury in March 2026, serves as a roadmap for how the government and financial institutions should use new technology to stop criminals from using digital assets (like cryptocurrency and stablecoins) for money laundering, fraud, and terrorism.

    1. The Goal: Modernizing the “Financial Police”

    The report was triggered by the GENIUS Act (enacted in 2025), which focuses on regulating stablecoins. The Treasury’s main point is that as money moves from traditional bank accounts to digital “wallets” and blockchains, the tools used to catch criminals must change. The report argues for a “technology-neutral” approach—meaning the rules should focus on what someone is doing (moving money) rather than how they are doing it (using a specific software).

    2. The Problem: New Ways to Hide Money

    The report identifies several high-risk areas where current laws are struggling to keep up:

    • DeFi (Decentralized Finance): Platforms that allow trading without a central middleman (like a bank) make it harder to verify who is participating.
    • Mixers and Tumblers: Software tools designed specifically to scramble transaction history to hide the source of funds.
    • Jurisdictional Arbitrage: Criminals moving their operations to countries with weak financial laws to avoid U.S. oversight.
    • Sanctioned States: Countries like North Korea and Russia are increasingly using digital assets to bypass global trade restrictions.

    3. The Solution: Fighting Tech with Tech

    To counter these risks, the Treasury recommends that the U.S. lean into four specific “innovative technologies”:

    • Artificial Intelligence (AI): Using machine learning to spot patterns of suspicious activity that a human might miss.
    • Blockchain Analytics: Advanced tracking software that can follow “breadcrumbs” on a public ledger to see where stolen money is going.
    • Digital Identity Systems: Modernizing how we prove who we are online (digital IDs) to make it harder for fraudsters to open fake accounts.
    • APIs (Application Programming Interfaces): Better software connections that allow banks and the government to share data about threats in real-time.

    4. Key Recommendations for Congress

    The report asks lawmakers to update the rules of the game in three major ways:

    • Clarify DeFi Rules: Congress needs to define which people or companies in a “decentralized” system are responsible for following anti-money laundering laws.
    • Create New Categories of Businesses: The law should recognize “Digital Asset Service Providers” (DASPs) as a specific type of financial institution with its own set of rules.
    • Modernize the Bank Secrecy Act: Update the 50-year-old framework that banks use to report suspicious activity so it fits the digital age.

    What This Means for Professionals

    If you work in finance, tech, or law, this report signals that “risk-based” compliance is the future. Instead of just checking boxes, companies will be expected to use sophisticated tech to monitor their own networks. The government is signaling that it won’t ban innovation, but it will require that innovation to be “policed” more effectively by the companies that create it.

    —

    ,

  • March 31, 2026 Sanctions-palooza: OFAC Updates: Counter Narcotics Designations Removals; Russia-related Designations Removals

    Counter Narcotics Designations Removals; Russia-related Designations Removals

    Treasury Press Release: Treasury Removes Narcotics and Russia-Related Entries from SDN List

    Delistings:

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

    OFAC Program: SDNTK Foreign Narcotics Kingpin Sanctions Regulations, 31 CFR part 598

    RODRIGUEZ OLIVERA, Luis (a.k.a. MORFAN RODRIGUEZ, Luis Fernando; a.k.a. RODRIGUEZ MORFIN, Luis; a.k.a. RODRIGUEZ OLIVERA, Luis Fernando), Plaza Pabellion, Zapopan, Jalisco, Mexico; Colonia Providencia, Calle Quebec, Apt. 1127, Guadalajara, Jalisco, Mexico; 4179 Colonia Miravalle, Guadalajara, Jalisco, Mexico; Sendero Las Acacias 92, Guadalajara, Guadalajara, Jalisco, Mexico; Vereda Del Canario 1, Guadalajara, Jalisco, Mexico; Puerto de Hierro, Zapopan, Jalisco, Mexico; Fresno, CA, United States; DOB: 03 Apr 1972; alt. DOB: 1960; alt. DOB: 1966; POB: Tecalitlan, Jalisco, Mexico; nationality: Mexico; citizen: Mexico (individual).

    MORFAN RODRIGUEZ, Luis Fernando (a.k.a. RODRIGUEZ MORFIN, Luis; a.k.a. RODRIGUEZ OLIVERA, Luis; a.k.a. RODRIGUEZ OLIVERA, Luis Fernando), Plaza Pabellion, Zapopan, Jalisco, Mexico; Colonia Providencia, Calle Quebec, Apt. 1127, Guadalajara, Jalisco, Mexico; 4179 Colonia Miravalle, Guadalajara, Jalisco, Mexico; Sendero Las Acacias 92, Guadalajara, Jalisco, Mexico; Vereda Del Canario 1, Guadalajara, Jalisco, Mexico; Puerto de Hierro, Zapopan, Jalisco, Mexico; Fresno, CA, United States; DOB: 03 Apr 1972; alt. DOB: 1960; alt. DOB: 1966; POB: Tecalitlan, Jalisco, Mexico; nationality: Mexico; citizen: Mexico (individual).

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

    OFAC Program: RUSSIA-EO14024 Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation

    FESCO MONERON (Cyrillic: ФЕСКО МОНЕРОН) Container Ship 7,519GRT Russia flag; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Vessel Registration Identification: IMO 9277412 (vessel) (Linked To: PSB LIZING OOO).

    FESCO MAGADAN (Cyrillic: ФЕСКО МАГАДАН) Container Ship 7,519GRT Russia flag; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Vessel Registration Identification: IMO 9287699 (vessel) (Linked To: PSB LIZING OOO).

    SV NIKOLAY (Cyrillic: СВ НИКОЛАЙ) General Cargo Ship 7,519GRT Russia flag; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Vessel Registration Identification: IMO 9538359 (vessel) (Linked To: PSB LIZING OOO).

    Source List:

    • UNITED NEWS OF INDIA, “US removes 3 Russia-flagged ships from sanctions list,” March 31, 2026.
    • Interfax, “U.S. lifts sanctions on 3 Russian seagoing cargo vessels,” March 31, 2026.
    • ACAMS, “OFAC Removes 16 Entries from SDN List,” March 31, 2026.

    Note: The Treasury press release was not on the Recent Actions web page. Gemini found it on the Treasury website.

    —

    , , , ,

  • March 20, 2026: OFAC adds to Counter Terrorism sanctions, removes from Counter-Narcotics and Russian ones

    Counter Terrorism Designations; Counter Narcotics and Russia-related Designations Removals

    Treasury Press Release: Treasury Sanctions Global Network Diverting Funds to Benefit Hizballah

    State Press Release: Sanctioning a Global Network Supporting Hizballah Financing

    Additions:

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

    OFAC Program: SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.

    AL LAKIS, Hamdan Ali

    • Address: Kab Elias Main Road, Yaktine Building, 5th Floor, Kab Elias, Bekaa 009618, Lebanon
    • DOB: 17 Jun 1971
    • POB: Mar Elias Zahle, Lebanon
    • Nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Hamdan Ali Al Lakis manages the day-to-day operations of a money exchange set up with Alaa Hassan Hamieh. This arrangement allows Hamieh to maintain total access to the business and hide from government oversight while collecting the majority of the profits.

    BOUSTANY, Maya

    • AKA: * AL-BUSTANI, Maya
      • AL-BUSTANI, Maya Shadi
    • Address: Qatar; Al-Dabieh, Mount Lebanon, Lebanon
    • DOB: 09 Sep 1981
    • POB: Al-Dabieh, Lebanon
    • Nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Female
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Maya Boustany is an associate of Alaa Hassan Hamieh and serves as the Chief Operating Officer for one of his companies. She has acted as a proxy for the Hizballah finance team to establish a front company in Iraq.

    FADEL, Raoof

    • Address: Zone 55, Street 169, Building 85, Villa 3, Doha, Qatar
    • DOB: 20 Dec 1981
    • POB: El Dammamm, Saudi Arabia
    • Nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Raoof Fadel is part of the financial network led by Alaa Hassan Hamieh. He owns and operates Seven Seas for International Trading and Logistics, a Qatar-based company used to move funds for Hizballah.

    HAMIEH, Alaa Hassan

    • Address: Zantout Street, Safi Darwich Building, 1st Floor, Dawhet El Hoss, Beirut, Lebanon; Southern Tariya, Baalbek, Lebanon
    • DOB: 25 Jan 1980
    • Nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions
    • Passport: OA110548 (Canada)
    • National ID No: 00003985449 (Lebanon)
    • Party Type: Individual
    • Linked to: HIZBALLAH

    Supplemental Information: Alaa Hassan Hamieh is a Hizballah financier and former Vice President of the Investment Development Authority of Lebanon (IDAL). He oversees a global network of companies that launder and raise funds for Hizballah’s finance team, diverting more than $100 million since 2020. He was notably involved in diverting funds from a trade agreement between Iraq and Lebanon intended for reconstruction.

    HAMIEH, Daniel

    • AKA: HAMIE, Daniel
    • Address: Wojska Polskiego 23ABC, Suwalki, Podlaskie 16-400, Poland; Lebanon
    • DOB: 30 Nov 2002
    • POB: Bialystok, Poland
    • Nationality: Poland
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Daniel Hamieh is the nephew of Alaa Hassan Hamieh. He co-owns the Poland-based entity Call Lync Spolka Z Ograniczona Odpowiedzialnoscia, which has transferred hundreds of thousands of dollars to companies affiliated with the Hizballah finance team.

    HAMIEH, Muhammad Hasan

    • AKA: HAMIYYAH, Muhammad Hasan
    • Address: Lebanon
    • DOB: 12 Sep 1983
    • POB: Tariyah, Lebanon
    • Nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Muhammad Hasan Hamieh is the brother of Alaa Hassan Hamieh. He assists in tracking funds associated with various projects operated in collaboration with Hizballah finance team members, including Muhammad Al-Bazzal and Rashid Al-Bazzal.

    HASHEM, Bahaa Addin

    • Address: Lebanon
    • DOB: 18 Nov 1982
    • POB: Damascus, Syria
    • Nationality: Syria
    • alt. nationality: Saint Kitts and Nevis
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: RE0151778 (Saint Kitts and Nevis)
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Bahaa Addin Hashem is a Syrian gray-arms dealer who co-owns several companies with Alaa Hassan Hamieh. He is the registered owner of the Slovenia-based Call Lync Telekomunikacijske Storitve D.O.O. and is also an employee of the previously designated Hizballah enterprise G.M. Farm.

    SALAMI, Mohamad Jamil

    • AKA: SALAMI, Mohamad
    • Address: Amir Bachir Street, Azarieh Building, Beirut, Lebanon
    • DOB: 17 May 1982
    • Nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Mohamad Jamil Salami is a Hizballah member within Alaa Hassan Hamieh’s network. He has been involved in telecommunications projects and a weapons systems company, and has personally transferred fundsto Hamieh.

    TARSHISHI, Hala Mohamad

    • AKA: TARCHICHI, Hala
    • Address: Lebanon
    • DOB: 26 Feb 1983
    • Nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Hala Mohamad Tarshishi serves as the secretary for Alaa Hassan Hamieh. She acts as a proxy for his companies and conducts financial transactions on his behalf to support his business network.

    WEHBE, Mohamad Hasan

    • AKA: WAHBI, Mohamed Hassan
    • Address: Ras Beirut, Lebanon
    • DOB: 08 Sep 1971
    • POB: Beirut, Lebanon
    • Nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: LR2576480 (Lebanon) expires 13 Mar 2032
    • National ID No: 000034132689 (Lebanon)
    • Party Type: Individual
    • Linked to: HAMIEH, Alaa Hassan

    Supplemental Information: Mohamad Hasan Wehbe owns and operates several Lebanon-based entities, including Seven Seas SAL Offshore and Seven Seas Group S.A.R.L., which are utilized by Alaa Hassan Hamieh for money laundering and procurement.

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

    OFAC Program: SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.

    CALL LYNC S.A.L. OFFSHORE

    • Address: Beirut, Lebanon
    • Party Type: Entity
    • Linked to: HAMIEH, Alaa Hassan

    CALL LYNC SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA

    • AKA: CALL LYNC S.P. Z.O.O.
    • Address: Wojska Polskiego 23ABC, Suwalki, Podlaskie 16-400, Poland
    • Party Type: Entity
    • Linked to: HAMIEH, Daniel

    CALL LYNC TELEKOMUNIKACIJSKE STORITVE D.O.O.

    • AKA: CALL LYNC D.O.O.
    • Address: Ljubljana, Slovenia
    • Party Type: Entity
    • Linked to: HASHEM, Bahaa Addin

    SEVEN SEAS FOR INTERNATIONAL TRADING AND LOGISTICS

    • Address: Doha, Qatar
    • Party Type: Entity
    • Linked to: FADEL, Raoof

    SEVEN SEAS GROUP S.A.R.L.

    • Address: Beirut, Lebanon
    • Party Type: Entity
    • Linked to: WEHBE, Mohamad Hasan

    SEVEN SEAS SAL OFFSHORE

    • Address: Second Floor, Airport Business Center, Airport Road, Beirut, Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 12 Jul 2012
    • Registration Number: 1806107 (Lebanon)
    • Party Type: Entity
    • Linked to: WEHBE, Mohamad Hasan

    Delistings:

    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.

    GASTELUM SERRANO, Cesar (a.k.a. “LA SENORA“), Culiacan, Sinaloa, Mexico; DOB 1961; POB Mexico; nationality Mexico; Gender Male (individual).

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

    OFAC Program: RUSSIA-EO14024 Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation”.

    KORZHAVIN, Yurii Anatolyevich, Russia; DOB 28 Sep 1957; POB Moscow, Russia; nationality Russia; GenderMale; Tax ID No. 770702814195 (Russia) (individual).

    KORZHAVINA, Lidiya Germanovna, Russia; DOB 22 May 1958; POB Moscow, Russia; nationality Russia; GenderFemale; Tax ID No. 771405312885 (Russia) (individual).

    Source List:

    Note: The Treasury Department press release is legit, but it’s not part of the Recent Actions page item (follow the link if you don’t believe me).

    —

    , , , , , , ,

  • January 30, 2026: OFAC makes updates to Iran, Counter-Terrorism, and Non-Proliferation sanctions programs

    Iran-related Designations; Counter Terrorism Designations; Non-Proliferation Designation Update and Designation Removal

    Treasury Press Release: Treasury Sanctions Iranian Regime Officials for Violent Repression and Corruption

    State Press Release: Sanctioning Iranian Government Officials for Suppression of Peaceful Protest

    Additions:

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

    • OFAC Programs:
      • [IRGC] Islamic Revolutionary Guard Corps1
      • [IFSR] Iranian Financial Sanctions Regulations
      • [IRAN-HR] Serious Human Rights Abuses by the Government of Iran

    DAMGHANI, Hamid

    • Name: Hamid Damghani2
    • DOB: 23 Sep 19733
    • Nationality: Iran4
    • Additional Sanctions Information: Subject to Secondary Sanctions5
    • Gender: Male6
    • National ID No.: 4590769603 (Iran)
    • Title: IRGC Commander for Gilan Province
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    KAMALI, Hossein Zare

    • Name: Hossein Zare Kamali7
    • DOB: 27 Jun 1961
    • POB: Mehriz, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: R57381834 (Iran) expires 01 Jul 2027
    • Title: IRGC Commander for Hamadan Province
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    KHADEMI, Majid

    • Name: Majid Khademi8
    • Address: Tehran, Iran
    • DOB: 06 Sep 1962
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 2571042165 (Iran)
    • Title: Islamic Revolutionary Guard Corps Intelligence Organization Commander
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    VALIZADEH, Ghorban Mohammad

    • AKA: VALIZADEH SHARAK, Ghorban Mohammad
    • Name: Ghorban Mohammad Valizadeh9
    • Address: Tehran, Iran
    • DOB: 23 Sep 1974
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 0872896595 (Iran)
    • Title: Islamic Revolutionary Guard Corps Commander for Tehran Province
    • Party Type: Individual
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    Supplemental Information: These individuals are Iranian officials who oversee security forces responsible for violent crackdowns on peaceful protesters.10

    • OFAC Program: [IRAN-HR] Serious Human Rights Abuses by the Government of Iran

    HAJIAN, Mehdi

    • AKA: HAJJIAN, Mehdi
    • Name: Mehdi Hajian11
    • Address: Kermanshah, Iran
    • DOB: 16 Aug 1976
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 3359178221 (Iran)
    • Title: LEF Commander for Kermanshah Province
    • Party Type: Individual
    • Linked to: LAW ENFORCEMENT FORCES OF THE ISLAMIC REPUBLIC OF IRAN

    MOMENI KALAGARI, Eskandar

    • AKA: MOMENI, Eskandar
    • Name: Eskandar Momeni Kalagari12
    • Address: Iran
    • DOB: 15 Jan 1963
    • POB: Qaem Shahr, Mazandaran, Iran
    • Nationality: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: D10016001 (Iran) expires 27 Nov 2029
    • Party Type: Individual

    Supplemental Information: Designated as part of the group of Iranian officials responsible for the suppression of peaceful protests and violent crackdowns.

    • OFAC Program: [IRAN-EO13902] Imposing Sanctions with Respect to Additional Sectors of Iran

    ZANJANI, Babak Morteza

    • Name: Babak Morteza Zanjani
    • Address: United Arab Emirates
    • DOB: 12 Mar 1974
    • POB: Tehran, Iran
    • Nationality: Iran
    • Nationality: United Arab Emirates
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Identified as an Iranian investor who embezzled billions in funds from the Iranian people.

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

    • OFAC Programs:
      • [SDGT] Global Terrorism Sanctions Regulations
      • [IFSR] Iranian Financial Sanctions Regulations
      • [IRAN-EO13902] Imposing Sanctions with Respect to Additional Sectors of Iran

    ZEDCEX EXCHANGE LTD

    • Name: Zedcex Exchange Ltd
    • Address: 71-75 Shelton Street, London WC2H 9JQ, United Kingdom
    • Website: www.zedcex.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 1388613
    • Organization Established Date: 22 Aug 2022
    • Organization Type: Financial and Insurance Activities
    • Digital Currency Address: TRX TCA9vmjsYw9MtPKEwRBtGhKFRfr4CLxJAv
    • Digital Currency Address: TRX TGsNFrgWfbGN2gX25Wcf8oTejtxtQkvmEx
    • Digital Currency Address: TRX TASWbk6X1wiTku5TMmMQYqYFvshVEtfJy8
    • Digital Currency Address: TRX TTS9o5KkpGgH8cK9LofLmMAPYb5zfQvSNa
    • Digital Currency Address: TRX TCzq6m2zxnQkrZrf8cqYcK6bbXQYAfWYKC
    • Digital Currency Address: TRX TLvuvpfBKdxddxSsJefeiGCe9eVY8HUroE
    • Digital Currency Address: TRX TNuA5CQ6LB4jTHoNrjEeQZJmcmhQuHMbQ7
    • Company Number: 14311274 (United Kingdom) issued 22 Aug 202214
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    ZEDXION EXCHANGE LTD

    • AKA: ZEDXION LIMITED
    • Name: Zedxion Exchange Ltd
    • Address: 71-75 Shelton Street, London WC2H 9JQ, United Kingdom
    • Website: http://www.zedxion.io
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 1388615
    • Organization Established Date: 17 May 2021
    • Organization Type: Financial and Insurance Activities
    • Company Number: 13404089 (United Kingdom) issued 17 May 2021
    • Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS

    Supplemental Information: These financial entities are linked to the Islamic Revolutionary Guard Corps (IRGC).

    Delistings:

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

    • OFAC Programs:
      • [NPWMD] Weapons of Mass Destruction Proliferators Sanctions Regulations
      • [IFSR] Iranian Financial Sanctions Regulations

    SOLTECH INDUSTRY CO., LTD. (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)

    “SOLTECH INDUSTRIES” (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)16

    SOLTECH INDUSTRIES COMPANY LTD. (a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)17

    “SOLTECH INDUSTRY CO.” (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)18

    “SOLTECH INDUSTRY COMPANY” (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)19

    SOLTECH INDUSTRY COMPANY, LTD (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. “SOLTECH”; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)20

    “SOLTECH” (a.k.a. SOLTECH INDUSTRIES COMPANY LTD.; a.k.a. SOLTECH INDUSTRY CO., LTD.; a.k.a. SOLTECH INDUSTRY COMPANY, LTD; a.k.a. “SOLTECH INDUSTRIES”; a.k.a. “SOLTECH INDUSTRY CO.”; a.k.a. “SOLTECH INDUSTRY COMPANY”), 1A, Fook Ying Building, 379 Kings Road, North Point, Hong Kong, China; Rm 51, 5th Floor, Britannia House, Jalan Cator, Bandar Seri Begawan BS 8811, Brunei; Additional Sanctions Information – Subject to Secondary Sanctions; Company Number NBD/4116 (Brunei)21

    Amendments:

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

    • OFAC Programs:
      • [NPWMD] Weapons of Mass Destruction Proliferators Sanctions Regulations
      • [IFSR] Iranian Financial Sanctions Regulations

    SOLTANMOHAMMADI, Mohammad

    • AKA: SELTAN MOHAMMEDI, Mohammed22
    • AKA: SULTAN MOHMADI, Mohhamad23
    • AKA: WANG, Chung Lang24
    • AKA: WANG, Chung Lung25
    • AKA: WANG, Zhong-Lang26
    • Address: Apartment # 1504, Fairooz Tower, Dubai Marina, Dubai, United Arab Emirates
    • Address: 216 Ocean Drive, Sentosa Cove, Singapore 098622, Singapore
    • DOB: 04 Nov 1960
    • POB: Hamedan, Iran
    • Nationality: Iran
    • Nationality: United Kingdom
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Passport: 518015439 (United Kingdom) expires 07 Apr 2026
    • Passport: T96397867 (Iran)
    • Passport: 038016890 (United Kingdom)
    • Passport: 093045489 (United Kingdom)
    • Passport: U11283369 (Iran)
    • National ID No.: S27602 (United Kingdom)
    • Party Type: Individual
    • Linked to: HODA TRADING

    Supplemental Information: No specific supplemental information available for this amendment.

    List of Changes:

    • Field Name: Linked To
      • Changed: SOLTECH INDUSTRY CO., LTD. to: HODA TRADING
    • Field Name: Passport
      • Deleted: 093104973 (United Kingdom)
      • Deleted: 093234017 (United Kingdom)
      • Deleted: 099156908 (United Kingdom)
      • Deleted: S2760238Z

    —

    , , , , , ,

  • December 23, 2025: Amended Syria Tri-Seal Advisory & PAARSS designation updates

    First, from today’s OFAC Notice:

    Today, the U.S. Department of State, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control, have issued an amended Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria, to reflect the repeal of the Caesar Syria Civilian Protection Act of 2019 (Caesar Act). 

    Additionally, there are PAARSS designations which have been updated:

    Amendments:

    PAARSS-related Designations

    [PAARSSR-EO13894] Promoting Accountability for Assad and Regional Stabilization Act of 2019; Executive Order 13894

    The [SYRIA-CAESAR] Program Tag has been removed from the following PAARSS-related designations:

    AL-ADHAM EXCHANGE COMPANY AKAs: AL-ADHAM FOREIGN EXCHANGE Address: May 29th Street, Saroujah, Damascus, Syria; Hisham Al-Atassi Street, Al-Salam Building, Ground Floor, Homs, Syria; Al-Assi Square, Al-Quwwatli Street, Hama, Syria; Al-Quds Street, Tartous, Syria Website: https://aladham-exchange.com.syOrganization Established Date: 16 Feb 2009 Commercial Registry Number: 15691 (Syria)

    AL-ASSAD, Samer Kamal AKAs: AL-ASAD, Samer Address: Syria DOB: 19 May 1973 POB: Qardaha, Syrianationality: Syria Gender: Male Passport: 86368 (Syria) National ID No.: 06200000449 (Syria) Type: Individual

    AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY AKAs: AL-FADEL EXCHANGE AND INTERNATIONAL TRANSFER COMPANY, AL-FADEL EXCHANGE PRIVATE JOINT STOCK COMPANY, AL-FADEL MONEY TRANSFER AND EXCHANGE PRIVATE JSC Address: Al-Fardous Street, Damascus, Syria; March 8th Street, Al-Sarraj Building, Ground Floor, Lattakia, Syria; Al-Express Street, Al-Farqan Quarter, Aleppo, Syria; Al-Mazza Highway, Damascus, Syria; Sayyida Zeynab, Damascus, Syria; Main Street, Jeremana, Damascus, Syria Website:https://alfadelex.com

    ARFADA PETROLEUM PRIVATE JOINT STOCK COMPANY AKAs: ARFADA PETROLEUM COMPANY JSC, ARVADA PETROLEUM COMPANY JSC Address: Mashroua Dummar, Lot No. 13, Building 12/2, Damascus, SyriaWebsite: https://www.arfada.com/ Organization Established Date: 24 Apr 2018 Organization Type: Support activities for petroleum and natural gas extraction Registration Number: 18394 (Syria)

    BALWI, Fadel Ma’ruf AKAs: AL-BALAWI, Fadel Address: Syria DOB: 01 Jan 1983 POB: Nubl, Syria nationality:Syria Gender: Male Passport: 2251748 (Syria) Type: Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    BALWI, Muhammad Ma’ruf AKAs: AL-BALAWI, Muhammad, AL-BALWI, Muhammad Ma’ruf Address: Sayyida Zeynab, Damascus, Syria DOB: 01 Jan 1981 POB: Nubl, Syria nationality: Syria Gender: Male Passport: 1982538 (Syria) Type: Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    BALWI, Mut’i Ma’ruf AKAs: AL-BALAWI, Mut’i, BALAWI, Mut’i, BALWI, Maarouf, BALWI, Moutee MaaroufAddress: Syria DOB: 01 Jan 1985 POB: Nubl, Syria nationality: Syria Gender: Male Passport: 2488186 (Syria) Type:Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    HAMIEH, Khaldoun Address: Syria DOB: 25 Dec 1973 nationality: Lebanon Gender: Male Passport: LR1939852 (Lebanon) Type: Individual

    JAMALEDDINE, Nazir Ahmad Mohammed AKAs: JAMAL EDDIN, Mohammed Nazer, JAMAL EDDINE, Natheer Ahmed Mohammed, JAMAL EDDINE, Nathier Ahmed Mohammed Address: Damascus, Syria DOB: 02 Jan 1962POB: Damascus, Syria nationality: Syria Gender: Male Passport: N011612445 (Syria) alt. Passport: 002-17-L022286 (Syria) National ID No.: 010-30208342 (Syria) Type: Individual

    LIMITED LIABILITY COMPANY STG LOGISTIC AKAs: OOO STG LOGISTIK, STG STROYTRANSGAZ LOGISTIC, “STG LOGISTIC” Address: 12 Universitetsky Ave, Moscow 119330, Russia; Damascus, SyriaOrganization Established Date: 04 Sep 2009 Tax ID No.: 5027148148 (Russia) Registration Number:1095027004236 (Russia)

    MAYA EXCHANGE COMPANY AKAs: MAYA FOR EXCHANGE AND INTERNATIONAL HAWALAS Address:Ground Floor, Property Number 17/9/2230, Baqi Zadeh Building, Fardus Street, Salhiyah, Damascus, Syria; First Real Estate Zone, Property Number 936, Section 2, Ground Floor, Haju Building, Abd al-Hamid al-Durubi Street, Homs, Syria; Tartus Real Estate Zone, Section 8, Property Number 3881, Revolution Street, Al-Baraniyah, Tartus, Syria; Ground Floor, Second Real Estate Zone, Sections 7-9, Property 2533, Aziziyah Falls, Baghdad Station, Aleppo, SyriaOrganization Type: Other monetary intermediation

    QADDOUR, Khalid AKAs: QADDOUR, Khaled Nasser Address: Yaafour, Damascus, Syria DOB: 23 Apr 1970 POB:Damascus, Syria nationality: Syria Gender: Male National ID No.: 01020097227 (Syria) Type: Individual Linked to:AL-ASSAD, Maher

    RAMAK DEVELOPMENT AND HUMANITARIAN PROJECTS LLC AKAs: RAMAK COMPANY FOR DEVELOPMENT AND HUMANITARIAN PROJECTS LLC Address: Rural Damascus, Syria Organization Established Date: 08 Aug 2011 Organization Type: Real estate activities with own or leased property alt. Organization Type: Construction of buildings

    SALLIZAR SHIPPING SAL Address: 1st Floor, Shuwairi Bldg., Boulevard Saib Salam, al-Masraa, Beirut Corniche, Lebanon Organization Established Date: 12 Apr 2018 Registration Number: 1024992 (Lebanon)

    TAMAYOZ LLC AKAs: EXCELLENCE LIMITED LIABILITY COMPANY Address: Damascus, Syria Organization Type: Real estate activities with own or leased property

    WINGS PRIVATE JSC AKAs: AL-AJNAHA PRIVATE JOINT STOCK COMPANY, WINGS COMPANY, WINGS PRIVATE JOINT STOCK COMPANY Address: Rural Damascus, Syria Organization Type: Real estate activities with own or leased property

    —

    , , , , , ,

  • December 19, 2025: OFAC adds Maduro family & associates to SDN List, plus updated GL and FAQ

    Based on the OFAC Notice and related press releases for December 19, 2025:

    Venezuela-related Designations; Issuance of Venezuela-related General License; Publication of Amended Venezuela-related Frequently Asked Question

    Treasury Press Release: Treasury Targets Family Members and Associates of Maduro Regime

    Additions:

    VENEZUELA-EO13850 Executive Order 13850

    CARRETERO NAPOLITANO, Roberto, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: CARRETERO NAPOLITANO, Ramon).

    CARRETERO NAPOLITANO, Vicente Luis, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: CARRETERO NAPOLITANO, Ramon).

    FLORES DE MALPICA, Eloisa, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    HURTADO PEREZ, Damaris del Carmen, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA FLORES, Iriamni, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA HURTADO, Erica Patricia, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA TORREALBA, Carlos Evelio, Venezuela; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    Supplemental Information: The Treasury Department designated these seven individuals for their roles as family members and associates helping to sustain the narco-corruption structure of the Maduro regime. Specifically, the action targets the networks of Carlos Erik Malpica Flores (a nephew of Cilia Flores and former official at PDVSA and the Venezuelan Treasury) and Panamanian businessman Ramon Carretero Napolitano. Eloisa Flores de Malpica is the mother of Carlos Erik Malpica Flores and sister of Cilia Flores. Carlos Evelio Malpica Torrealba is his father, Iriamni Malpica Flores is his sister, Damaris del Carmen Hurtado Perez is his wife, and Erica Patricia Malpica Hurtado is his adult daughter. Roberto and Vicente Luis Carretero Napolitano are immediate family members of Ramon Carretero. Malpica Flores has been previously sanctioned and linked to corruption within Venezuela’s state-run oil company, PDVSA.

    You can learn more about the sanctions process in this video: OFAC Sanctions List Search tool which explains how to verify designated individuals.

    Additionally, we have a new version of GL 5:  Venezuela-related General License 5T, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After February 3, 2026.” As usual, the date at which you can deal in the bond has been pushed out – now it’s February 3rd of next year.

    And the related Frequently Asked Question – FAQ 595 – has been updated to reflect the new GL version and the new date.

    —

    , , , , ,