Mr. Sanctions

Category: Regulatory

  • August 27, 2026: Got Wite-Out? OFAC issues new versions of 8 Venezuela General Licenses, issues 2 new FAQs, amends 2, and archives 1 – and Claude explains the changes

    Issuance of Amended Venezuela-related General Licenses and Associated Frequently Asked Questions

    Release Date

    08/27/2026

    Recent Actions Body

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 46D, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products;” Venezuela-related General License 47B, “Authorizing the Sale of U.S.-Origin Diluents to Venezuela;” Venezuela-related General License 48C, “Authorizing the Supply of Certain Items and Services to Venezuela;” Venezuela-related General License 50C, “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities;” Venezuela-related General License 51C, “Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold;” Venezuela-related General License 52B, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.;” Venezuela-related General License 54B, “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela;” and Venezuela-related General License 61A, “Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications.”

    Additionally, OFAC is issuing two new Venezuela-related Frequently Asked Questions (FAQs 1267 and 1268), amending two Venezuela-related Frequently Asked Questions (FAQs 1233 and 1244), and archiving FAQ 1260.

    Claude explains the difference:

    What’s new is that OFAC fully removed the separate governing-law requirement, the clause requiring contract terms to be “construed and interpreted in accordance with the laws of a state or other jurisdiction within the United States.” So the two conditions that used to travel together (US governing law + dispute resolution venue) have been decoupled, and only the dispute-resolution piece survives. That’s the substantive change behind your two new FAQs:

    • FAQ 1267 (new): Asks whether the amended GLs still require a choice-of-law provision. Answer: no, effective Aug 27, 2026. OFAC states the rationale as responding to “investment-related reforms made by the GOV since January 2026.” It doesn’t name Venezuela’s Hydrocarbons Law amendment specifically, so connecting the two is my inference based on outside reporting, not something OFAC states in the FAQ itself.
    • FAQ 1268 (new): Confirms the dispute-resolution-venue requirement itself is untouched, and adds a clarifying line that the requirement “relates to the jurisdiction in which dispute resolution proceedings must occur, rather than the law governing the underlying contract.”

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  • August 26, 2026: OFAC Update, Part 1: Counter-Terrorism Designations

    Counter Terrorism Designations; Issuance of Counter Terrorism General License; Issuance of Amended Russia-related General License

    Treasury Press Release: Treasury Takes Action Against Violent Far-Left Terrorist Networks

    State Press Release: Imposing Sanctions on Violent Far-Left Terrorist Groups

    State Fact Sheet: Designation of Autistici/Inventati as a Specially Designated Global Terrorist

    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

    ABDULNASSER, Zaid

    • AKA: “TAMIM, Zid”
    • Address: Germany
    • DOB: 1995
    • Nationality: Palestinian
    • Gender: Male
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: MASAR BADIL

    Supplemental Information: Treasury identifies Abdulnasser, based in Germany, as a leader of Masar Badil.

    ALSAGHEER, Rawa

    • AKA: AL-SAGHIR, Ruwaa
    • Address: Brazil
    • DOB: 1997
    • Nationality: Palestinian
    • Gender: Female
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: MASAR BADIL

    Supplemental Information: Treasury identifies Alsagheer, based in Brazil, as a leader of Masar Badil alongside Abdulnasser.

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

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

    AUTISTICI INVENTATI

    • Address: Strada Statale Abetone e del Brennero 253, San Giuliano Terme, Province of Pisa 56017, Italy
    • Website: http://www.autistici.org
    • Email Address: http://www.associazione@ai-odv.org
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 2001
    • Organization Type: Data processing, hosting and related activities

    Supplemental Information: Autistici Inventati, also known as the A/I Collective, is an Italian nonprofit founded in 2001 that runs the “Noblogs” hosting platform out of the Province of Pisa. According to State’s fact sheet, it vets every prospective user for ideological alignment before granting access to a suite of encrypted email, web hosting, and video conferencing tools reserved for left-wing groups. State puts its current footprint at roughly 16,000 mailboxes, 1,500 websites, 5,500 mailing lists, and 10,000 blogs.

    Treasury and State tie that infrastructure to a string of violent incidents. The Kurdistan Workers’ Party (PKK) has used its services. So has the anarchist network behind a wave of 2026 rail sabotage across France, Italy, Germany, and the Netherlands. The March 2026 attack on the Transalpine Pipeline, which briefly cut crude flows to Austria, Germany, and the Czech Republic, relied on A/I tools to claim credit and circulate a manifesto calling for further attacks. A separate German network used the platform to claim a January 2026 attack on Berlin’s power grid that killed one person and cut power to 45,000 households. Oregon’s Rose City Antifa, the campaign against Atlanta’s police training facility, and the “Jane’s Revenge” firebombings of crisis pregnancy centers all appear in State’s accounting as well. A/I’s channels have also carried communiqués for foreign terrorist organizations including the PFLP, Hamas, Hizballah, and the IRGC.

    MASAR BADIL

    • AKA: PALESTINIAN ALTERNATIVE REVOLUTIONARY PATH MOVEMENT
    • Address: Brazil; Germany; Canada; Belgium; Spain
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: Oct 2021
    • Organization Type: Advocacy organization
    • Linked to: SAMIDOUN PALESTINIAN PRISONER SOLIDARITY NETWORK

    Supplemental Information: Treasury describes Masar Badil, the Palestinian Alternative Revolutionary Path Movement, as inextricably linked to the Samidoun Palestinian Prisoner Solidarity Network. The United States and Canada jointly sanctioned Samidoun in October 2024 as a front for the Popular Front for the Liberation of Palestine, a Foreign Terrorist Organization since 1997. The two groups share fundraising mechanisms and overlapping Executive Committee membership, including already-sanctioned Samidoun leaders Khaled Barakat, Mohammad Khatib, and Jaldia Abubakra.

    PALESTINE ACTION

    • AKA: PALESTINE ACTION GROUP
    • Address: United Kingdom
    • Secondary Sanctions Risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 30 Jul 2020
    • Organization Type: Transnational Terrorist Group

    Supplemental Information: Treasury and State describe Palestine Action as a UK group that has carried out acts of terrorism since July 2020. Its members have broken into British defense facilities and military installations, causing millions of dollars in damage, and have injured UK law enforcement personnel. The group has also promoted its tactics on social media and encouraged copycat action abroad, including in the United States and along the U.S.-Mexico border. The UK government proscribed Palestine Action as a terrorist organization under the Terrorism Act 2000 in July 2025, and today’s designation complements that action.

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  • 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.

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  • August 24, 2026: State Department Press Release and Fact Sheet on today’s OFAC Iran Sanctions moves

    The press release:

    U.S. Implements Operation Economic Outcast Sanctioning Iran’s Military Activities, Cyber Threats, and Illicit Oil Trade

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, SPOKESPERSON

    AUGUST 24, 2026

    Today, the United States took sweeping action against multiple entities, individuals, and vessels enabling the Iranian regime’s destabilizing activities.  Such activities include attacks against U.S. forces and allies in the region, illicit weapons procurement, cyber intrusions into American infrastructure, and the movement of energy products whose sale funds terrorism globally 

    The measures target Iranian military officials responsible for procuring weapons and directing attacks against U.S. servicemembers and regional partners, Iran-based entities that gathered intelligence for targeting U.S. forces and allies, and a procurement ring supplying Iran’s military and missile programs.  They also target a regime-directed cyber group responsible for extensive intrusions into U.S. critical infrastructure.  Finally, we are targeting a sprawling group of shippers and brokers moving Iranian petroleum as well as petroleum and petrochemical products through the UAE, China, Singapore, and Europe to bankroll the U.S.-designated Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and other regime elements.

    The cyber component of today’s action was carried out in close coordination with the FBI, which announced last week indictments against eight Iranian nationals tied to a hacking campaign that compromised U.S. energy companies, defense contractors, healthcare institutions, and government offices at the local, state, and federal levels.

    Last week, the Department of State’s Rewards for Justice program offered a reward of up-to-$10 million for information on five of these individuals conducting malicious cyber activity against U.S. critical infrastructure on behalf of the Iranian government — reflecting the seriousness with which the United States treats threats to its digital infrastructure and reinforcing that those who attack American systems, wherever they are located, will be pursued and held accountable.

    The United States will continue to disrupt, expose, and dismantle Iran’s military and proliferation activities, procurement schemes, malicious cyber operations, and illicit oil trade that sustains the regime’s malign behavior.  We call on the international community to join us in holding these actors to account.

    The Department of State targets are being designated pursuant to Executive Order (E.O.) 13846, which authorizes and reimposes certain sanctions with respect to Iran, and E.O. 13949, which targets certain persons with respect to the conventional arms activities of Iran.  The Department of the Treasury targets are being designated pursuant to E.O. 13382, which targets proliferators of weapons of mass destruction and their means of delivery; E.O. 13694, as amended, which targets malicious cyber-enabled activities; E.O. 13902, which targets certain sectors of the Iranian economy, and E.O. 13224, as amended, a counterterrorism authority. For more information about today’s actions, see the RFJ website, the Department of State’s fact sheet and Treasury’s press release.

    The fact sheet:

    United States Implements Operation Economic Outcast with Sanctions Targeting Iran’s Military Activities and Procurements, and Petroleum and Petrochemical Product Traders

    FACT SHEET

    OFFICE OF THE SPOKESPERSON

    AUGUST 24, 2026

    Today, the Department of State is sanctioning numerous entities, individuals, and vessels to further expose individuals and entities that enabled strikes against U.S. forces and allies and to restrict the revenue that the Iranian regime uses to attack its neighbors, support terrorism abroad, brutally oppress its own people, and hold the global economy hostage. 

    Last week, the Department of State’s Rewards for Justice (RFJ) program offered a reward of up to $10 million for information on the key leaders of Iran’s Islamic Revolutionary Guard Corps (IRGC), including Ahmed Vahidi and Ali Abdollahi.  More information about RFJ rewards is available on the RFJ website. 

    All Department of State targets are being designated pursuant to Executive Order (E.O.) 13846, which authorizes and reimposes certain sanctions with respect to Iran, and E.O. 13949, which targets certain persons with respect to the conventional arms activities of Iran. 

    Concurrently, the Department of the Treasury is designating nearly 60 entities, individuals, and identifying vessels as blocked property.  These persons enable the Iranian regime’s illicit procurement, cyber operations, and petroleum and petrochemical product revenue generation networks. 

    Exposing Iran-based Entities and Individuals Involved in Targeting U.S. Forces During Operation Epic Fury and Military Procurement 

    Today’s action targets two Iran-based entities involved in the procurement of sensitive imagery that supported targeting of U.S. service members and partners in the region, along with seven individuals responsible for Iran’s military activities and procurement efforts, including directing the use of conventional weapons against U.S. forces and neutral neighboring states and advocating for defense partnerships with Iran’s international partners that would contravene U.S. sanctions. 

    • DADENEGAR STARTUP STUDIO (DADENEGAR) supported targeting of U.S. and partner facilities in the Middle East for the Iranian military during Operation Epic Fury. It utilized commercial Chinese satellite imagery for some of these efforts.  DADENEGAR supported Iran’s military targeting and battle damage assessment activities.  Additionally, DADENEGAR conducted an online influence operation for the Iranian government.  DADENEGAR is being designated pursuant to section 1(a)(iii) of E.O. 13949 for having engaged, or attempted to engage, in any activity that materially contributes to, or poses a risk of materially contributing to, the proliferation of arms or related materiel or items intended for military end-uses or military end-users, including any efforts to manufacture, acquire, possess, develop, transport, transfer, or use such items, by the Government of Iran (including persons owned or controlled by, or acting for or on behalf of the Government of Iran) or paramilitary organizations financially or militarily supported by the Government of Iran.  
    • IRANIAN ISLAMIC REVOLUTIONARY GUARD CORPS CYBER-ELECTRONIC COMMAND (IRGC-CEC) obtained information related to U.S. military assets and facilities that supported Iran’s military targeting during Operation Epic Fury. The IRGC-CEC is being designated pursuant to section 1(a)(iii) of E.O. 13949 for having engaged, or attempted to engage, in any activity that materially contributes to, or poses a risk of materially contributing to, the proliferation of arms or related materiel or items intended for military end-uses or military end-users, including any efforts to manufacture, acquire, possess, develop, transport, transfer, or use such items, by the Government of Iran (including persons owned or controlled by, or acting for or on behalf of the Government of Iran) or paramilitary organizations financially or militarily supported by the Government of Iran.  
    • MOHAMMAD BAQER ZOLQADR (ZOLQADR) was the Secretary of the Supreme National Security Council, Iran’s top formal decision-making body on national security and defense policy. ZOLQADR played an active role advocating for Iran’s continued support of its so-called Axis of Resistance.  ZOLQADR was designated by the UN Security Council in Annex I of UN Security Council resolution (UNSCR) 1747 (2007), reimposed on September 27, 2025, in response to Iran’s “significant non-performance” of its nuclear commitments.  ZOLQADR is being designated pursuant to section 1(a)(iii) of E.O. 13949 for having engaged, or attempted to engage, in any activity that materially contributes to, or poses a risk of materially contributing to, the proliferation of arms or related materiel or items intended for military end-uses or military end-users, including any efforts to manufacture, acquire, possess, develop, transport, transfer, or use such items, by the Government of Iran (including persons owned or controlled by, or acting for or on behalf of the Government of Iran) or paramilitary organizations financially or militarily supported by the Government of Iran.
    • ALI ABDOLLAHI (ABDOLLAHI) is the commander of Khatam ol Anbia Central Headquarters, a U.S.-sanctioned Iranian government entity responsible for joint and wartime operations. ABDOLLAHI has driven decisions related to Iran’s kinetic actions during Operation Epic Fury.  ABDOLLAHI is being designated pursuant to section 1(a)(ii) of E.O. 13949 for providing to Iran any technical training, financial resources or services, advice, other services, or assistance related to the supply, sale, transfer, manufacture, maintenance, or use of arms and related materiel described in subsection (a)(i) of E.O. 13949.
    • AHMAD VAHIDI (VAHIDI) is the Commander-in-Chief of the IRGC, which is considered the military vanguard of Iran. VAHIDI is one of the most influential individuals in Iran, both politically and militarily, driving decisions on Iran’s kinetic actions during Operation Epic Fury.  VAHIDI is being designated pursuant to section 1(a)(ii) of E.O. 13949 for providing to Iran any technical training, financial resources or services, advice, other services, or assistance related to the supply, sale, transfer, manufacture, maintenance, or use of arms and related materiel described in subsection (a)(i) of E.O. 13949.
    • SAYYED HOSEIN MAJID MUSAVI EFTEKHARI (EFTEKHARI) is the Commander of the IRGC Aerospace Force, the entity responsible for the IRGC’s unmanned aerial vehicle (UAV) program. EFTEKHARI exercised responsibility for Iran’s ballistic missile and UAV programs during Operation Epic Fury.  EFTEKHARI is being designated pursuant to section 1(a)(ii) of E.O. 13949 for providing to Iran any technical training, financial resources or services, advice, other services, or assistance related to the supply, sale, transfer, manufacture, maintenance, or use of arms and related materiel described in subsection (a)(i) of E.O. 13949.
    • SEYYED MAHDI FARAHI (FARAHI) is the Deputy Defense Minister for Industrial and Research Affairs at MODAFL. FARAHI directs the procurement of arms and related materiel and has demonstrated in-depth knowledge of various missile systems, including those that Iran has reportedly used against U.S. forces and allies during Operation Epic Fury.  FARAHI is being designated pursuant to section 1(a)(ii) of E.O. 13949 for providing to Iran any technical training, financial resources or services, advice, other services, or assistance related to the supply, sale, transfer, manufacture, maintenance, or use of arms and related materiel described in subsection (a)(i) of E.O. 13949.
    • AMIR HATAMI (HATAMI) is the Commander of the Artesh, Iran’s conventional military. HATAMI is responsible for the aspects of the conventional armaments of the Iranian armed forces and has responsibilities for the use of missiles and UAVs, including during Operation Epic Fury.  HATAMI is being designated pursuant to section 1(a)(ii) of E.O. 13949 for providing to Iran any technical training, financial resources or services, advice, other services, or assistance related to the supply, sale, transfer, manufacture, maintenance, or use of arms and related materiel described in subsection (a)(i) of E.O. 13949.
    • REZA TALAEI-NIK (TALAEI-NIK) is the spokesperson for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), the country’s main defense ministry body which functions as the central manager of the country’s military industries, procurement, and logistics. TALAEI-NIK has publicly advocated for defense partnerships with Iran’s international partners that would be in contravention of U.S. sanctions and the reimposed Iran-related UN Security Council restrictive measures and sanctions.  TALAEI-NIK is being designated pursuant to section 1(a)(i) of E.O. 13949 for engaging in activity that materially contributes to the supply, sale, or transfer, directly or indirectly, to or from Iran, or for the use in or benefit of Iran, of arms or related materiel, including spare parts.

    Continued Targeting of Iran’s Petroleum and Petrochemical Product Traders, Dark Fleet, and Maritime Service Providers

    Today, the Department of State is sanctioning multiple companies that have engaged in the illicit trade of Iranian petroleum and petrochemical products, activities that have generated millions of dollars in revenue for the Iranian regime.  Iran’s exports of petroleum, petroleum products, and petrochemical products are facilitated by shell companies and intermediaries in third countries.  These Iranian petroleum, petroleum products, and petrochemical cargos are frequently transported by shadow fleet operators, including vessel management companies that regularly engage in dark activity and other deceptive shipping practices, endangering other vessels and trade flows.  Finally, import and logistics companies, such as customs brokers and port agents, facilitate the entry of Iranian- origin commodities through customs on behalf of buyers in third countries.   Today’s action targets all the nodes of this illicit trade, and promotes accountability for the buyers, sellers, intermediaries, and service providers that help facilitate Iran’s destabilizing activities. 

    Targeting Customs Broker Involved in Facilitating the Trade of Iranian Petrochemical Products

    • PORTEASE PARTNERS LLP (PORTEASE) is an India-based customs broker that facilitated the import of multiple shipments of Iranian petrochemical products to India. INDRISMIYA ASHARAFMIYA SHEKH (INDRISMIYA) is an Indian national and a designated partner of PORTEASE. HARISH RAMCHANDRA RANGI (HARISH) is an Indian national and a designated partner of PORTEASE. 
    • PORTEASE is being designated pursuant to section 3(a)(iii) of E.O. 13846 for, on or after November 5, 2018, knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.
    • INDRISMIYA is being blocked pursuant to section 5(a)(vii) of E.O. 13846 as a principal executive officer, or a person performing similar functions and with similar authorities, of PORTEASE.
    • HARISH is being blocked pursuant to section 5(a)(vii) of E.O. 13846 as a principal executive officer, or a person performing similar functions and with similar authorities, of PORTEASE.

    Continued Targeting of Iran’s Shadow Fleet

    • CLEVER SHIPPING LIMITED (CLEVER SHIPPING) is the Hong Kong-based commercial manager of STAR PIONE (IMO: 9389019), a Barbados-flagged crude oil tanker that loaded Iranian-origin petroleum on at least six occasions between 2025 and 2026.
    • CLEVER SHIPPING is being designated pursuant to section 3(a)(ii) of E.O. 13846 for, on or after November 5, 2018, knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran. STAR PIONE is being identified as property in which CLEVER SHIPPING has an interest.

    Continued Targeting of Iranian Petroleum and Petrochemical Product Traders

    • OSHIDA PETROKIMYA URUNLERI SANAYI VE TICARET ANONIM SIRKETI (OSHIDA) is a Türkiye-based petrochemical trader, which imported approximately $1 million worth of Iranian-origin petrochemical products from January 2024 to August 2024. MOHSEN FARAHI is an Iranian national and the director of OSHIDA.
    • OSHIDA is being designated pursuant to section 3(a)(iii) of E.O. 13846 for, on or after November 5, 2018, knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.
    • FARAHI is being blocked pursuant to section 5(a)(vii) of E.O. 13846 as a principal executive officer, or a person performing similar functions and with similar authorities, of OSHIDA.
    • HUZUR PLASTIK KIMYEVI MADDELER ITHALAT IHRACAT SANAYI VE TICARET LIMITED SIRKETI (HUZUR PLASTIK) is a Türkiye-based petrochemical company that imported Iranian-origin polyethylene valued at $28 million from multiple Iran-based entities, including U.S.-designated ARYA SASOL POLYMER COMPANY, between June 2022 and May 2024. Additionally, between January and September 2024, the company supplied over $900,000 worth of shipments containing Iranian-origin petrochemical products to multiple companies in Türkiye.  CENGIZ BEKGOZ is a Turkish national and the manager of HUZUR PLASTIK.
    • HUZUR PLASTIK is being designated pursuant to section 3(a)(iii) of E.O. 13846 for, on or after November 5, 2018, knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.
    • CENGIZ BEKGOZ is being blocked pursuant to section 5(a)(vii) of E.O. 13846 as a principal executive officer, or a person performing similar functions and with similar authorities, of HUZUR PLASTIK.
    • NARMINA DADASHOVA is a Singapore national and a principal executive officer or equivalent of ALT CAPITAL PTE. LTD. (ALT CAPITAL). ALT CAPITAL was designated on May 28, 2026, pursuant to section 3(a)(iii) of E.O. 13846 for, on or after November 5, 2018, knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.  Between March and April 2024, ALT CAPITAL conducted multiple transactions for the export of approximately $900,000 worth of Iranian-origin petrochemical products.
    • NARMINA DADASHOVA is being blocked pursuant to section 5(a)(vii) of E.O. 13846 as a director, or a person performing similar functions and with similar authorities, of U.S.-designated ALT CAPITAL.
    • SADASHIVA OVERSEAS LIMITED (SADASHIVA OVERSEAS) is an India-based company that imported approximately $69 million worth of Iranian-origin petroleum products from multiple companies, including U.S.-designated BONJOURE COMMODITY F.Z.E. between February 2024 and June 2025
    • SADASHIVA OVERSEAS is being designated pursuant to section 3(a)(ii) of E.O. 13846 for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran.
    • PP SOFTTECH PRIVATE LIMITED (PP SOFTTECH) is an India-based company that imported approximately $25 million worth of Iranian-origin petroleum products between January 2024 and June 2025. PRASHANT GARG is an Indian national and a director of PP SOFTTECH.
    • PP SOFTTECH is being designated pursuant to section 3(a)(ii) of E.O. 13846 for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran.
    • PRASHANT GARG is being blocked pursuant to section 5(a)(vii) of E.O. 13846 as a principal executive officer, or a person performing similar functions and with similar authorities, of PP SOFTTECH.
    • ABHAR POLYMER COMPOUNDS CO. (ABHAR) is an Iran-based entity that exported approximately $1.7 million worth of Iranian-origin petrochemical products between January 2024 and September 2024.
    • ABHAR is being designated pursuant to section 3(a)(iii) of E.O. 13846 for, on or after November 5, 2018, knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.
    • STARPLAS KIMYA SANAYI VE TICARET ANONIM SIRKETI (STARPLAS KIMYA) is a Türkiye-based company that imported approximately $1.7 million worth of Iranian-origin petrochemical products from ABHAR between January and September 2024.
    • STARPLAS is being designated pursuant to section 3(a)(iii) of E.O. 13846 for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.
    • PRAKRUTEES INFRA IMPEX INDIA PRIVATE LIMITED (PRAKRUTEES INFRA) is an India-based company that imported Iranian-origin petroleum products valued at $25 million from multiple companies, including U.S.-designated BONJOURE COMMODITY F.Z.E., between May 2023 and February 2026.
    • PRAKRUTEES INFRA is being designated pursuant to section 3(a)(ii) of E.O. 13846 for, on or after November 5, 2018, knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran.
    • SELFPLAST PLASTIK AMBALAJ SANAYI DIS TICARET LIMITED SIRKETI (SELFPLAST) is a Türkiye-based company that imported over $4.7 million worth of Iranian-origin petrochemical products from multiple companies, including SELENIUM RESOURCES LIMITED, between January 2023 and May 2024.
    • SELFPLAST is being designated pursuant to section 3(a)(iii) of E.O. 13846 for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.
    • SELENIUM RESOURCES LIMITED (SELENIUM) is a Hong Kong-based company that exported Iranian-origin petrochemical products valued at over $22.8 million to multiple companies, including SELFPLAST, between January 2023 and September 2024.
    • SELENIUM is being designated pursuant to section 3(a)(iii) of E.O. 13846 for, on or after November 5, 2018, knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.

    Sanctions Implications 

    As a result of today’s sanctions-related actions, and in accordance with E.O.s 13949 and 13846, all property and interests in property of the sanctioned persons described above that are in the United States or in possession or control of U.S. persons are blocked and must be reported to the Department of Treasury’s Office of Foreign Assets Control (OFAC).  In addition, all 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.  

    All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt.  These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.  

    The power and integrity of U.S. government sanctions derive not only from the U.S. government’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (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. 

    Petitions for removal from the SDN List may be sent to: OFAC.Reconsideration@treasury.gov.  Petitioners may also refer to the Department of State’s Delisting Guidance page.

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  • August 24, 2026: State Department Press Release on Syria Sanctions Recission

    Rescission of Syria’s Designation as a State Sponsor of Terrorism

    PRESS STATEMENT

    MARCO RUBIO, SECRETARY OF STATE

    AUGUST 24, 2026

    Today, I authorized the formal rescission of Syria’s designation as a State Sponsor of Terrorism (SST), following the conclusion of the mandatory 45-day Congressional notification period.   I have also delisted Hay’at Tahrir al-Sham’s (HTS) designation as a Specially Designated Global Terrorist (SDGT). These actions represent another historic step by President Trump to give the Syrian people a path to prosperity.  

    In the past year the Trump Administration has taken unprecedented steps to provide sanctions relief for the benefit of the Syrian people.  The historic June 2025 Executive Order ‘Providing for the Revocation of Syria Sanctions’ accelerated the process of sanctions relief for Syria, including by terminating the Syria Sanctions Program and the national emergency with respect to Syria, and directing reviews on various Syria-related sanctions and terrorist designations.  

    These actions were all taken in recognition of the positive actions taken and further commitments by the Syrian government under President Ahmed al-Sharaa to fully distance Syria from acts of international terrorism.  In the past year, the Government of Syria has taken significant steps to counter terrorism, to include formally joining the Global Coalition to Defeat ISIS in November and conducting operations to disrupt the terror networks of ISIS, al-Qa’ida, Hizballah, and Iran-aligned groups.  Rescinding Syria’s designation as an SST and HTS’ designation as an SDGT eliminates the final major barriers for private sector investment in Syria and promotes Syria’s economic recovery and reintegration into the global economy.   

    For a summary of U.S. sanctions and export control relief for Syria to date, please refer to the Tri-Seal Advisory  [235 KB] published by U.S. Departments of Commerce, Treasury, and State.   

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  • August 24, 2026: OFAC Iran Sanctions: a new Determination, revocation of GLs F & G & other exemptions, 2 new GLs, and an OFAC Alert

    First, the Determination:

    13902_sector_determination_08242026Download

    Next, the revocation/suspension of exemptions and general licenses:

    notice_of_suspension_iran_08242026Download

    Next, General License AA (Authorizing Certain Activities Involving La Nivernaise De Raffinage SAS):

    iran_gl_aaDownload

    and General License BB (Authorizing the Wind Down of Certain Transactions Previously Authorized Under the Iranian Transactions and Sanctions Regulations):

    iran_gl_bbDownload

    and, finally, an OFAC Alert (Sanctions Risks of Iranian Demands for Strait of Hormuz Passage):

    20260821_hormuz_alertDownload

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  • 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.

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  • August 21, 2026: OFAC issues 2 new Venezuela General Licenses and one new Frequently Asked Question

    On Friday, OFAC issues Venezuela GL 61 (Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications):

    venezuela_gl61Download

    and GL 62 (Authorizing Negotiations of and Entry Into Contingent Contracts for Investment in the Telecommunications Sector of Venezuela):

    venezuela_gl62Download

    and, for good measure, FAQ 1266:

    1266. What activities does Venezuela General License (GL) 61 authorize?

    Answer

    GL 61 authorizes transactions ordinarily incident and necessary to the provision from the United States or by a U.S. person of goods, technology, software, or services for the installation, maintenance, refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela, including transactions involving the Government of Venezuela, including but not limited to the Comisión Nacional de Telecomunicaciones (CONATEL), Compania Anonima Nacional Telefonos de Venezuela (CANTV), and Movilnet.

    For purposes of GL 61, telecommunications includes data, telephone, internet connectivity, radio, television, news wire feeds, and similar services, regardless of the medium of transmission, including transmission by satellite or through submarine cables.

    Authorized transactions include:  processing payments and arranging shipping, including air freight, logistics, warehousing, insurance, and delivery services; interconnection and roaming agreements; capacity or infrastructure leases; and the laying, maintenance, repair, refurbishment, upgrade, security, operation, or support of submarine cables and other telecommunications infrastructure or equipment; and the provision, licensing, renewal, maintenance, or support of related software, systems, and services, including software updates and network-support services.  The provision of other financial services for the refurbishment, repair, upgrade, operation, or support of telecommunications in Venezuela would also be authorized to the extent ordinarily incident and necessary to the authorized telecommunications-related activity and provided that it does not involve debt swaps or other payment terms prohibited by GL 61.

    Examples of transactions authorized by GL 61 include those ordinarily incident and necessary to the provision of:

    • telecommunications equipment and network infrastructure, including broadband access equipment, components, and spare parts;
    • telecommunications capacity or infrastructure through leases, including fiber-optic pairs and satellite bandwidth;
    • international telecommunications connectivity, including IP transit;
    • telecommunications-related:
      • software, including licensing, renewals, updates, maintenance, and technical or vendor support;
      • cloud services;
      • data storage and backup systems, network monitoring and automation platforms;
      • customer billing systems; and
    • servers and other computing systems used to support telecommunications.

    Notably, GL 61 does not authorize:

    • payment terms that are not commercially reasonable, involve debt swaps or payments in gold, or are denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
    • any transaction involving a person located in or organized under the laws of Russia, Iran, North Korea, Cuba, or the People’s Republic of China, or an entity owned or controlled, directly or indirectly, by or in a joint venture with such a person;
    • the unblocking of property blocked pursuant to the Venezuela Sanctions Regulations;
    • transactions involving blocked vessels; or
    • the formation of new joint ventures or other entities in Venezuela to develop or invest in the telecommunications sector.

    Date Released

    August 21, 2026

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  • August 20, 2026: OFAC Update, Part 2: New version of Russian GL131, and 3 amended FAQs (2 Russian, 1 Cuban)

    While Claude is chugging through the massive update today (a press chart, 2 Treasury PRs, 3 State PRs, and a fact sheet), I’m going to post the other part…

    First, Russia-related General License 131I (Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities):

    russia_gl131iDownload

    And OFAC updated 2 related Russian Frequently-Asked Questions again – 1224:

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

    Answer

    On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131I, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131I expires on September 19, 2026.

    GL 131I does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131I must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.

    As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

    OFAC may revoke GL 131I at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

    Date Updated: August 20, 2026

    Date Released

    November 19, 2025

    and 1225:

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

    Answer

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128C and GL 131I. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

    • To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C to extend the existing authorization until October 29, 2026.
    • To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, GL 131H, and GL 131I, to extend the existing authorization until September 19, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128C and GL 131I expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128C and GL 131I. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128C and GL 131I authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

    Both GL 128C and GL 131I also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128C and GL 131I. Similarly, non-U.S. persons may rely upon GL 128C and GL 131I regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128C and GL 131I, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: August 20, 2026

    Date Released

    December 4, 2025

    as well as Cuba FAQ 1265:

    1265. On August 20, 2026, the Department of State designated the Ministry of Construction of Cuba (MICONS) pursuant to E.O. 14404.  Are foreign persons, including foreign financial institutions (FFIs), subject to sanctions risk for transacting with MICONS?

    Answer

    The U.S. government does not intend to target foreign persons, including FFIs, pursuant to E.O. 14404 for engaging in transactions ordinarily incident and necessary to the wind down of transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, through September 19, 2026. However, non-U.S. persons, including FFIs, should proceed with caution in any dealings with a party sanctioned under this authority. Actions to return assets to a sanctioned party or transfer them to another jurisdiction for potential use by the target could expose non-U.S. persons to significant sanctions risk.

    Foreign persons unable to wind down transactions involving MICONS, or any entity in which MICONS owns, directly or indirectly, a 50 percent or greater interest, before September 19, 2026, are encouraged to contact the OFAC Compliance Hotline.

    Persons subject to U.S. jurisdiction, including U.S. persons and entities owned or controlled by U.S. persons, should additionally note that this limited non-targeting posture does not authorize any transaction prohibited by the Cuban Assets Control Regulations (CACR), 31 CFR part 515, or any other OFAC sanctions authority. Persons subject to U.S. jurisdiction have long been prohibited from transacting with MICONS, including in connection with a non-U.S. person’s wind down of activities with MICONS, absent OFAC authorization. Relevant authorizations may include humanitarian-related transactions authorized under the CACR in subpart E of part 515 and under E.O. 14404 via General License (GL) 1.  For additional information on GL 1, see FAQ 1253. 

    Date Released

    August 20, 2026

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  • August 18, 2026: State Department Press Release on OFAC ICC designations

    Advancing the United States’ Campaign to Address the Threat Posed by the International Criminal Court 

    PRESS STATEMENT

    MARCO RUBIO, SECRETARY OF STATE

    AUGUST 18, 2026

    The Trump Administration has been clear: the International Criminal Court (ICC) is a corrupt and fatally politicized supranational court that has maliciously abused its authority and exceeded its mandate.  We will not tolerate its assault on state sovereignty.  

    In furtherance of the diplomatic campaign we launched last month to address the ICC’s abuses of power, I am designating two ICC officials – President of the ICC, Tomoko Akane of Japan, and ICC Senior Trial Lawyer, Abdoulaye Seye of Senegal – pursuant to Executive Order 14203, “Imposing Sanctions on the International Criminal Court.”  These individuals have directly engaged in efforts by the ICC to investigate, arrest, detain, or prosecute officials whose government has not consented to ICC jurisdiction.  

    The ICC has repeatedly attempted to assert authority over nationals of the United States and other countries that have not consented to its jurisdiction or ratified the Rome Statute.  This sets a dangerous precedent for all nations.   

    Our whole of government campaign to dismantle the threat posed by the ICC to national sovereignty will be sweeping and we expect more countries to join our campaign by ending their funding and participation in this politicized and unaccountable court. The ICC’s ability to target American nationals and those of other non-States Parties must end. The Trump Administration stands ready to take additional measures, if necessary, to systematically dismantle the ICC until it is incapable of threatening American sovereignty. 

    These individuals are being designated pursuant to section 1(a)(ii)(A) of Executive Order (E.O.) 14203. 

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