The legislation, which enters in force on 29 September imposes (previously announced) further sectoral sanctions on Iran, broadly corresponding to measures lifted by the UK and partners as part of the Joint Comprehensive Plan of Action.
It follows the UK complying with UN sanctions obligations relating to the snapback of UN Iran sanctions in October 2025. New legislation includes financial measures to reduce the ability of the Government of Iran to access the UK financial systems. It will also bring forward trade prohibitions targeting significant industries advancing Iran’s nuclear escalation, including the energy, metals, gold, and software sectors, and related activities such as shipping, insurance and banking. We are also expanding our powers to target Iranian vessels which enable and facilitate Iran’s nuclear programme and malign activity.
Like all sanctions measures the legislation includes carefully designed mitigations. This will include general licensing to enable the continued operation of the Shah Deniz gas field in Azerbaijan, which provides critical energy supplies to our European partners. It is a continuation of long-standing policy that aligns the UK with the EU and US, who have similar carveouts for activities related to Shah Deniz.
Written Ministerial Statement: Iran Sanctions, 8 September 2026
The Minister for the Middle East, Stephen Doughty MP, has provided a written update to parliament on Iran Sanctions measures.From:Foreign, Commonwealth & Development Office and Stephen Doughty MPPublished:8 September 2026Delivered on:8 September 2026
Today we are laying legislation which will tackle Iranian nuclear activity and other hostile Iranian activity.
The lack of transparency around Iran’s nuclear programme has long posed a serious threat to international peace and security. We have repeatedly seen Iran not act in good faith to address these concerns. For over two decades, the international community has sought clarity and assurance about the nature of Iran’s nuclear programme. Iran has expanded its nuclear programme in ways that lack any credible civilian justification. This includes Iran’s accumulation of over 400kg of uranium enriched to 60%. Iran is the only country without nuclear weapons to enrich uranium to this level.
The UK complied with its UN obligations to implement the snapback of UN Iran sanctions on 1 October 2025 when the Iran (Sanctions) (Nuclear) (EU Exit) (Amendment) Regulations 2025 came into force. The UK went further and designated 71 individuals and entities in sectors that have links to Iran’s nuclear programme, including financial institutions and energy companies.
As my predecessor set out in a written ministerial statement to the House of 13 October 2025, and also in their oral statement to the House on 13 January 2026, the UK will now introduce legislation to impose further sectoral measures on Iran. Today, I am laying in the House ‘The Iran (Sanctions) (Amendment) Regulations 2026’, through which the Government is amending both The Iran (Sanctions) Regulations 2023 and The Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019.
These Regulations introduce sectoral measures which are broadly those lifted as part of the Joint Comprehensive Plan of Action. Today’s legislation therefore doubles down on our action to constrain Iran’s nuclear ambitions.
Financial measures will further reduce the Government of Iran’s ability to access the UK financial system and raise funds in support of its nuclear programme. Trade prohibitions against Iran are expanded under this legislation to additional goods, technology and services, including those key to significant industries contributing to Iranian nuclear escalation, such as energy, software, metals, gold, and related activities such as shipping, insurance and banking. The export of additional goods and technology key to Iran’s conventional weapons and nuclear capabilities are also prohibited. In addition, to bolster our existing designations and the termination of our bilateral air services arrangements in 2024, Iranian aircraft will be prohibited from landing in the UK unless certain exemptions apply.
The legislation will further expand our powers to sanction ships – strengthening our ability to target ships enabling and facilitating Iran’s nuclear programme and malign and destabilising behaviour.
As part of the UK’s responsible approach to the use of sanctions, this legislation (like all sanctions legislation) includes carefully-designed sanctions mitigations.
This will include general licences to enable the continued operation of the Shah Deniz gas field in Azerbaijan, which provides critical energy supplies to our European partners. This is a continuation of long-standing policy and aligns us with the EU and US who have similar carveouts for activities related to Shah Deniz.
Through these measures, the Government will uphold its commitment to ensuring that Iran is never able to acquire a nuclear weapon, and will strengthen sanctions that reduce Iranian hostile capabilities.
Iran’s nuclear programme has long been a serious concern to the international community. Iran remains in significant non-compliance with their international safeguards obligations.
A negotiated outcome is the only long-term solution to the threat posed by Iran’s nuclear programme. We remain fully committed to a lasting and sustainable diplomatic solution that ensures Iran never develops a nuclear weapon.
Published 8 September 2026
when the other elements noted in the OFSI notice are published (and in force), I will publish them – but since they are not, I will hold off. If folks want to plan, they can click through and review the anticipated changes.
The following individual has been added to OFAC’s SDN List:
OFAC Programs:
SDGT Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
IFSR Iranian Financial Sanctions Regulations, 31 C.F.R. part 561
TAEEDI, Reza Mohammad
Address: Dubai, United Arab Emirates
DOB: 24 Aug 1975
Nationality: Iran
Additional Sanctions Information: Subject to Secondary Sanctions
Gender: Male
Passport: P6602606
Alt. Passport: E96037407
National ID No.: 784-1975-3624749-3 (United Arab Emirates)
Party Type: Individual
Linked to: Bank Melli Iran
Supplemental Information: Taeedi is the general manager of Bank Melli Iran’s Dubai branch. Treasury says that branch has moved billions of dollars through accounts tied to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), letting the IRGC-QF and its parent organization move funds into and out of Iran and helping fund Iran-aligned proxies, including in Iraq. State’s parallel statement describes Bank Melli more broadly as a financial hub for Iran’s armed forces, naming both the IRGC-QF and the Ministry of Defense and Armed Forces Logistics as beneficiaries. OFAC designated Taeedi under E.O. 13224, as amended, for acting on Bank Melli’s behalf.
The following entity has been added to OFAC’s SDN List:
OFAC Program: IRAN-EO13902 Executive Order 13902
KAMENG TRADING LIMITED
Address:
Room 701, Unit 108, 7/F, Tower B, New Mandarin Plaza, 14 Science Museum Road, Tsim Sha Tsui, Kowloon, Hong Kong, China
Unit 89, 3F, Yau Lee Centre, No. 45, Hoi Yuen Rd, Kwun Tong, Hong Kong, China
Organization Established Date: 24 Jul 2024
Business Registration Number: 76846373 (Hong Kong)
Supplemental Information: Treasury ties Kameng Trading Limited to Pedram Pirouzan Exchange House, also known as Opal Exchange, an already-designated Iranian exchange house that used the Hong Kong company to launder money for Iran. State’s statement likewise describes the firm as a Hong Kong-based company that helped already-designated Iranian individuals and entities access the international financial system. OFAC designated Kameng Trading Limited under E.O. 13902 for operating in the financial sector of the Iranian economy.
and here is the NPRM (Notice of Proposed Rulemaking) of the Section 311 designation proposed by FinCEN:
Regulations Amending the Special Economic Measures (Iran) Regulations
Whereas the Governor in Council is of the opinion that the actions of the Islamic Republic of Iran constitute a grave breach of international peace and security that has resulted or is likely to result in a serious international crisis;
Therefore, Her Excellency the Governor General in Council, on the recommendation of the Minister of Foreign Affairs, makes the annexed Regulations Amending the Special Economic Measures (Iran) Regulations under paragraph 4(1)(a)a and subsections 4(1.1)b, (2)c and (3) of the Special Economic Measures Actd.
a S.C. 2022, c. 10, s. 438(1)
b S.C. 2017, c. 21, s. 17(2)
c S.C. 2023, c. 26, ss. 254(2) to (4)
d S.C. 1992, c. 17
Amendment
1 Part 2 of Schedule 1 to the Special Economic Measures (Iran) Regulations1 is amended by adding the following in numerical order:
Ali Abdollahi (born in 1959) (also known as Ali Abdollahi Aliabadi)
Ebrahim Zolfaghari
Ebrahim Azizi (born on June 22, 1963)
Hamid Hosseini
Shahram Irani (born in 1967)
Application Before Publication
2 For the purpose of paragraph 11(2)(a) of the Statutory Instruments Act, these Regulations apply according to their terms before they are published in the Canada Gazette.
Coming into Force
3 These Regulations come into force on the day on which they are registered.
1 SOR/2010-165
Mr. Sanctions’ Note: Why bother listing parties if all you’re going to provide is the name? How do you expect people to resolve matches? Or is this just performative? Just sayin’
Speak to the following: The Federal Register vs. the OFAC website: which one is legally operative, and what about time gaps between the two?
The response:
The Federal Register is legally operative for OFAC actions that require notice-and-publication; the OFAC website is not a legal instrument.
The distinction turns on the type of action. For designations under most sanctions programs, OFAC’s legal authority to add a party to the SDN List derives from the underlying statute and executive order, and the designation becomes effective when the Director (or Secretary) signs the determination, not when it appears anywhere. OFAC then publishes the SDN List update on its website, typically the same day, and follows with a Federal Register notice, sometimes days or weeks later.
For rules that carry legal force in their own right, the Federal Register is authoritative. Amendments to the sanctions regulations in Title 31 CFR, general licenses that OFAC chooses to codify, and formal rulemakings take legal effect on the date and terms stated in the Federal Register. The Federal Register text is the official version; if the website and the published notice ever diverged, the Federal Register controls.
On the time gaps: the practical answer for compliance purposes is that OFAC treats a designation as effective from the moment of the action, and the SDN List posting on the website is the operational trigger the industry screens against. The Federal Register notice is a legal formality that documents the action and satisfies publication requirements, but the absence of a same-day Federal Register notice does not delay the legal effect of a designation. A party added to the SDN List on Tuesday is blocked as of Tuesday, even if the corresponding Federal Register notice does not run until the following week. The prohibition attaches to the U.S. person’s dealings with blocked property, and OFAC’s position is that the obligation exists once the property interest is blocked, independent of publication timing.
Two nuances worth flagging. First, some due-process and constructive-notice questions have been litigated, and courts have generally accepted that public availability of the SDN List provides adequate notice, which is why the website posting matters practically even though it is not the legal instrument. Second, the effective date stated in a Federal Register notice may differ from the website posting date; where a specific legal deadline or wind-down period runs from an effective date, read that date from the Federal Register text rather than inferring it from when the website was updated.
If you want, I can pull the specific statutory publication requirements (for example, the IEEPA and APA provisions and any program-specific notice language) to tighten the citations.
and amended related Frequently Asked Questions 1224:
1224. What negotiations does Russia-related General License 131H 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) 131H, 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 131H expires on August 22, 2026.
GL 131H 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 131H 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 131H 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.
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 131H. 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, and GL 131H, to extend the existing authorization until August 22, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.
GL 128C and GL 131H 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 131H. 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 131H 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 131H 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 131H. Similarly, non-U.S. persons may rely upon GL 128C and GL 131H 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 131H, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.
1239. Where can I find the account information to make authorized payments to the Foreign Government Deposit Funds deposit account, as specified in Executive Order 14373?
Answer
To obtain payment account information for payments to the Foreign Government Deposit Funds deposit account established consistent with Executive Order (E.O.) 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People,” and referenced in certain Venezuela General Licenses, depositors must first email the official point of contact for the deposit account at: DepositorInquiries@state.gov. Potential depositors that fail to contact this email inbox and provide the requested transaction details may have their deposits rejected. Potential depositors should be prepared to provide all relevant transaction details, including the following, as appropriate:
Full legal names and addresses of corporate depositor and all contract parties (provide subsidiary information, as applicable);
Detailed description of the underlying contract or obligation, including the purpose and nature of the payment (include information on the type of product and amount purchased and/or sold);
Date of sale and copies of the corresponding invoice(s), contract number(s), and any relevant reference identifiers;
Total payment amount, currency, and proposed payment date(s);
Identification of the license authorizing the transaction;
Copies of any other transaction record(s) to validate the deposit; and
Primary point of contact for any follow-up questions, including name, title, telephone number, and email address.
Once the Department of State has provided payment account information and the deposit has been made and accepted, the depositor will receive a confirmation email acknowledging the deposit, which can be used to inform all contract parties involved in the transaction.
Date Updated: July 24, 2026
Date Released
March 4, 2026
Finally, OFAC issued a new final rule:
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adopting a final rule to update website and contact information in certain parts of the Code of Federal Regulations (CFR). Additionally, OFAC is amending one CFR part to update general licenses authorizing payments for legal services from funds originating outside the United States to replace the reporting requirement in the general license with a recordkeeping requirement and correcting typographical errors in two CFR parts. OFAC is also updating a part of 31 CFR chapter V to correct an erroneous cross-reference.
Here is a plain-language summary of the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (S.I. 2026/443), which comes into force on 13 May 2026.
What Is This Document?
This is the official Explanatory Memorandum — essentially the government’s own plain-English explanation — for a package of amendments to 36 different UK sanctions regimes. It was prepared by the Foreign, Commonwealth & Development Office (FCDO). Think of it as a housekeeping and strengthening exercise: the government is not creating new sanctions programs, but is tightening, clarifying, and modernizing the rules across the board.
The Key Changes, In Plain Terms
1. New “End-Use Controls” on Exports — The Most Significant Change
The regulations introduce a prohibition on UK exports of UK-sanctioned goods to a non-sanctioned third country where the government has determined there is a high risk that the goods will ultimately be diverted to a sanctioned jurisdiction.
What this means in practice: Previously, if a UK business exported goods to, say, a country in Central Asia, and the UK government warned that those goods might end up in Russia, the business could legally proceed anyway. The previous policy was merely to engage relevant businesses and highlight the risk of diversion, which did not sufficiently mitigate the risk because a significant proportion of exporters chose to continue with the export even when they were not able to provide evidence that the risks had been mitigated.
Under the new rules, once an exporter has been formally “informed” by the Secretary of State for Business and Trade of the diversion risk, they will be required to obtain an export licence before proceeding. The government will assess each application on a case-by-case basis and can refuse the licence if the diversion risk is not adequately mitigated.
Why now? The greatest risk of diversion is currently to Russia. Despite UK bilateral trade in goods with Russia being down 97% compared with 2021, Russia and other sanctioned destinations are still managing to obtain items indirectly from the UK and allied nations. This measure responds directly to a government review published in May 2025 that recommended introducing exactly this kind of control.
This applies across all UK sanctions regimes that include trade restrictions.
2. Currency Change: Euros → Pounds Sterling for Reporting Thresholds
The regulations update the definitions of “high value dealer” and “art market participant” within sanctions reporting requirements, so that monetary thresholds are expressed in pounds sterling rather than euros.
What this means: Businesses such as high-end art dealers, jewellers, and luxury goods retailers who accept large cash payments have reporting obligations under both money laundering and sanctions rules. Those thresholds were previously set in euros (a legacy of EU membership). They are now being converted to pounds, aligning sanctions rules with the updated Money Laundering Regulations. This removes unnecessary complexity for firms subject to reporting requirements and supports clearer, more coherent regulatory expectations.
3. Licensing Notices Can Now Be Sent Electronically Without Prior Consent
Previously, sanctions regulations stipulated that electronic notices relating to licences could only be issued with the recipient’s prior consent. The regulations modernise these provisions by confirming that licensing authorities may issue notices electronically without prior consent.
What this means: OFSI (the Office of Financial Sanctions Implementation, the UK’s sanctions licensing body) can now communicate with businesses by email as a matter of course, without first having to get prior consent that email is acceptable. A minor but practical modernisation.
4. Broader Licensing for Pre-Existing Obligations (“Prior Obligations”)
The regulations update the prior obligations licensing ground, which enables payments or transfers to satisfy obligations that arose before a person was designated under financial sanctions. The previous drafting was narrow, preventing the licensing of some legitimate pre-existing obligations and creating uncertainty for businesses and individuals.
What this means: When someone gets added to the sanctions list, businesses they had prior contracts with sometimes need a licence to complete or settle those existing obligations (e.g., to pay a bill that predates the designation). The old rules were too restrictive, making it hard to get such licences approved. The amendment broadens the licensing ground so that under UK autonomous regimes, prior obligations may be met using any funds and by any person, including owned or controlled entities, enabling a wider range of legitimate prior obligations to be licensed while maintaining appropriate safeguards against sanctions circumvention.
Note: this flexibility applies to UK-only (“autonomous”) sanctions regimes. Where UN Security Council resolutions are involved, the rules remain more restricted to comply with international obligations.
5. Clarity on Treasury Debt Payments Through Long Payment Chains
The regulations clarify that the existing exception for payments relating to UK government debt (Treasury debt) applies to all transfers of funds made as part of the payment chain, not just to direct payments from HM Treasury.
What this means: Some UK government debt (such as gilts) may be held by sanctioned persons. There was ambiguity about whether intermediaries in a payment chain — banks passing payments along — were protected by the exception when making such payments. The amendment makes clear that the protection covers every link in the chain.
6. Technical and Housekeeping Fixes
Three further changes are purely technical:
Zimbabwe correction: A previous set of amendments incorrectly referred to “the Treasury” instead of “the Secretary of State” in Zimbabwe sanctions designation procedures. This is corrected to restore consistency across all UK sanctions regulations.
Russia and North Korea ship specification: Language in the Russia and DPRK sanctions regulations about the procedure for designating specific ships is being updated to reflect what was already enacted in the Economic Crime Act 2022, purely for clarity.
Sentencing provisions: Outdated wording about maximum prison sentences for customs-related sanctions offences is being removed. The Finance Act 2024 changed the relevant sentencing framework, making existing wording in sanctions regulations redundant. Sanctions offences of this nature will remain subject to a 10-year maximum imprisonment period.
Who Is Affected?
The regulations apply to the whole of the United Kingdom and also to conduct by UK persons where that conduct is wholly or partly outside the UK. A “UK person” includes both UK nationals and companies incorporated under UK law.
The most practically significant impact is on exporters of goods to third countries who may need to be alert to end-use diversion risks. The estimated annual net cost to business is expected to be £0.1 million, with only a small number of additional exports expected to require licences. The government estimates the annual cost to the public sector (licensing and enforcement) at £1.4 million.
Bottom Line
This is a broad but largely technical update to the UK’s sanctions framework. The one genuinely new and substantive measure is the end-use export control — exporters of sanctioned goods to third countries can no longer simply ignore government warnings about diversion risk. Once officially notified of that risk, they must obtain a licence or stop the export. Everything else is clarification, modernisation, and consistency-tidying across a large number of existing sanctions regimes.
Changes to UK sanctions regulations – overview for firms
We are writing to give you notice of changes made to the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. The regulations have now come into force.
What’s changed
Changed relevant firms reporting from euros to pounds
Across all UK sanctions regulations, the definitions of high value dealers and art market participants within therelevant firms regulations are updated so that monetary thresholds are expressed in pounds sterling (£) rather than euros (€). In particular, the €10,000 threshold is being replaced with a £10,000 threshold.
This aligns sanctions reporting obligations with upcoming changes to those in the UK money laundering regulations, so firms are not reporting in two different currencies.
Electronic notices for licences
The law has been updated to confirm that OFSI and other authorities can send notices for licences electronically without needing consent for this approach. This reflects how communications already work and removes an outdated technical requirement.
HM Treasury debt exception
A clarification that the exception for Treasury debt applies to all transfers of funds across the entire payment chain, including intermediaries.
Updates to the prior obligations licensing ground
The SI broadens the prior obligations licensing ground, giving OFSI greater flexibility to license legitimate pre-designation obligations in appropriate cases while maintaining safeguards against sanctions circumvention.
137. If I am a HVD carrying out a transaction over the value of £10,000 via card transaction, am I exempt from reporting requirements?
If you are a HVD, the relevant firm reporting requirement applies only when you make/ receive a payment (or payments) in cash of at least £10,000. This therefore does not include payments via bank transfer or digital payments.
Amended on: 12 May 2026
138. If I am an AMP carrying out a transaction over the value of £10,000 via card transaction, am I exempt from reporting requirements?
If you are an AMP, the reporting requirement applies regardless of how the transaction (or series of linked transactions) is made, where the transaction has a value of £10,000 or more.
Amended on: 12 May 2026
and the new one:
185. The Prior Obligations licensing ground has been amended by The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026. What has changed in practice?
The prior obligations licensing ground enables payments or transfers to satisfy obligations that arose before a person was designated under financial sanctions. The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 amended this ground so that it is now applicable to a broader range of scenarios.
In practice, this expands the range of situations in which OFSI may consider licensing payments to satisfy prior obligations, subject to a case-by-case assessment. The change comes into force from 12 May 2026.
Under the amended ground:
It is no longer a condition that the funds or economic resources used to satisfy a prior obligation must be frozen under UK sanctions.
The limitations on whose funds or economic resources may be used (generally, those belonging to the DP or owned or controlled entity who owes the relevant prior obligation) have also been amended.
For DPs under UK autonomous sanctions, those limitations have been removed.
For UN DPs, where prior obligations licensing grounds apply, those limitations have been amended to allow the prior obligations of owned or controlled entities to be satisfied using the funds or economic resources of the DP, or of other owned or controlled entities. The assets of owned or controlled entities may also be used to satisfy prior obligations of the DP, as was the case previously.
Other limitations may apply, so it is important to check a specific regime to understand what may be permitted. For example, some regime-specific amendments have been made to the Iran Nuclear, Libya and DPRK regimes. Likewise, some regimes like Afghanistan do not have a prior obligation ground at all.
The changes do not mean that all payments relating to prior obligations will be permitted. OFSI retains discretion to refuse to grant a licence which falls within the relevant prior obligations ground even when the conditions are met, or to licence only a proportion of that obligation. For more information on OFSI’s licensing processes, please refer to our guidance.
Proclamation 8693, officially titled Suspension of Entry of Aliens Subject to United Nations Security Council Travel Bans and International Emergency Economic Powers Act Sanctions, was issued by President Obama on July 24, 2011, and published in the Federal Register on July 27. If you have read any OFAC-related Executive Order issued after that date, you have almost certainly seen a sentence saying that blocked persons “shall be treated as persons covered by section 1 of Proclamation 8693.” That reference is doing meaningful legal work, and it is worth understanding exactly what it means.
What Section 1 Does
Section 1 is the operative heart of the Proclamation. Issued under the President’s authority in Section 212(f) of the Immigration and Nationality Act (INA) — which gives the President broad power to suspend entry of any class of foreign nationals whenever their entry would be detrimental to national interests — it suspends entry into the United States, as either immigrants or nonimmigrants, of two categories of people:
(a) Any alien who meets the criteria for a travel ban imposed by a UN Security Council resolution listed in Annex A to the Proclamation; and
(b) Any alien whose property and interests in property have been blocked by a IEEPA-based Executive Order listed in Annex B to the Proclamation.
In plain English: if you are on the OFAC SDN List because your assets have been frozen under an IEEPA-based Executive Order, you are also barred from entering the United States under Proclamation 8693. The financial sanction and the travel ban become a package deal. The State Department’s Foreign Affairs Manual (9 FAM 302.14) makes this link explicit, noting that PP8693 suspends entry of applicants designated under IEEPA, and that OFAC’s SDN List is the operative mechanism for identifying such persons.
What the Other Sections Do
The remaining sections provide the administrative infrastructure around Section 1.
Section 2 gives the Secretary of State, or a designee, sole discretion to identify which persons are actually covered by Section 1, and to establish the procedures for doing so.
Section 3 assigns overall implementation responsibility to the Secretary of State, in consultation with the Secretary of the Treasury and the Secretary of Homeland Security.
Section 4 is the waiver provision: Section 1 does not apply where the Secretary of State determines that a particular person’s entry would not be contrary to US interests. In practice this provides important flexibility, including for law enforcement objectives where allowing travel may serve US interests. The Secretary must consult DHS on matters within DHS’s admissibility authority.
Section 5 preserves US obligations under applicable international agreements — an important carve-out, since the UN Headquarters Agreement sometimes requires the United States to permit entry of individuals who would otherwise be barred.
Section 6 is the standard no-private-right-of-action clause: the Proclamation creates no enforceable legal rights or benefits against the US government for any party.
Section 7 states that the Proclamation is effective immediately and remains in force until the Secretary of State determines it is no longer necessary and publishes that determination in the Federal Register. Unusually, there is no expiration date — it runs indefinitely until actively terminated.
Before the Proclamation: How Were Travel Bans Handled?
Before 2011, there was no single consolidated mechanism linking IEEPA-based sanctions designations to entry suspension across all programs. The tools that existed operated in a fragmented, program-by-program way.
The underlying legal authority — INA 212(f) — has always existed and gives the President broad power to suspend entry of foreign nationals. Presidents used it for specific purposes before 2011: for example, Proclamation 7750 (2004) suspended entry of persons engaged in or benefiting from corruption, and earlier proclamations targeted specific country affiliations or conduct. But none of these created a horizontal mechanism linking all IEEPA designations to travel ban consequences as a class.
For IEEPA-based sanctions programs, the approach before 2011 was inconsistent. Some IEEPA Executive Orders included their own entry suspension provisions directly within the order itself, invoking INA 212(f) on a program-specific basis. But at least some older programs — including some established in the 1990s — did not include such language. The Congressional Research Service has noted, for example, that Proclamation 8693 was issued to suspend entry of persons sanctioned under E.O. 12978 (the 1995 narcotics trafficking order), implying that order lacked a sufficient standalone entry suspension mechanism. This left a gap: a person could have their US-based assets frozen but face no formal presidential proclamation barring their entry.
For UN Security Council travel bans, the situation was similarly unsystematic. Before the Proclamation, giving domestic effect to UNSC travel ban obligations in the US immigration context depended on State Department guidance and consular practice rather than a standing presidential proclamation. Proclamation 8693 remedied that by creating a formal, standing legal instrument to implement UNSC Chapter VII travel ban obligations in US immigration law.
How Was the Proclamation Made Applicable to Pre-2011 Executive Orders?
The Proclamation addressed the pre-existing gap through its two annexes. Annex A listed the then-current UNSC resolutions imposing travel bans. Annex B listed the IEEPA-based Executive Orders then in existence, bringing all persons already blocked under those programs within the Proclamation’s entry suspension framework on the day it issued.
For Executive Orders issued after July 24, 2011, the mechanism is different and has become standardized: each new IEEPA-based EO includes a provision stating that blocked persons “shall be treated as persons covered by section 1 of Proclamation 8693.” This “refer-out” technique plugs each new sanctions program into the Proclamation’s administrative infrastructure — the Secretary of State’s identification authority, the waiver process, the international obligations carve-out — without each EO having to recreate it from scratch.
The Proclamation’s scope has also been extended dynamically: some subsequent EOs include language providing that new UNSC resolutions “shall be treated as resolutions listed in Annex A of Proclamation 8693,” meaning the Proclamation’s UNSC travel ban coverage grows as the Security Council acts, without requiring a new proclamation each time.
The result is a durable, cross-administration framework. Proclamation 8693 has been cited and relied upon in Executive Orders issued under the Obama, Trump, and Biden administrations, and into the present. Because it remains in force until the Secretary of State affirmatively terminates it, it functions as standing infrastructure rather than a time-limited instrument — which is precisely why you see it cited in virtually every IEEPA-based sanctions order issued in the years since.
And here is Claude’s source list and check for accuracy:
Sources
Proclamation 8693, full text — American Presidency Project, UC Santa Barbara (presidency.ucsb.edu/node/290727)
State Department Foreign Affairs Manual, 9 FAM 302.14 (fam.state.gov) — INA 212(f) ineligibility and PP8693 operational guidance
Congressional Research Service, IF10909, U.S. Sanctions: Targeting International Illicit Drug Production and Trafficking (congress.gov)
Executive Order 13726 (Libya expansion, April 2016) — OFAC/govinfo
Executive Order 13818 (Global Magnitsky, December 2017) — American Presidency Project
Executive Order 13849 (CAATSA implementation, September 2018) — American Presidency Project
Executive Order 13660 (Ukraine/Russia, March 2014) — govinfo/OFAC
Executive Order 13606 (Iran/Syria abusive technology, April 2012) — IRP/FAS
Executive Order 13608 (Foreign Sanctions Evaders, May 2012) — Obama White House archives
E.O. 14203 (2025) — OFAC PDF, confirming continued use of Proclamation 8693 reference formula
Executive Order 14115 (West Bank, February 2024) — American Presidency Project and White House
Accuracy Check
Well-supported by sources
Date, title, and publication. Confirmed directly in the Proclamation text: issued July 24, 2011; the American Presidency Project notes it was released by the Press Secretary on July 25 and published in the Federal Register on July 27.
Legal authority (INA 212(f)). Confirmed verbatim in the Proclamation’s preamble: “including section 212(f) of the Immigration and Nationality Act of 1952, as amended (8 U.S.C. 1182(f)), and section 301 of title 3, United States Code.”
The two categories in Section 1 (UNSC Annex A / IEEPA EOs Annex B). Confirmed exactly in the Proclamation text.
All sections 2 through 7. Confirmed verbatim in the Proclamation text.
State Dept FAM operational link. Confirmed in 9 FAM 302.14: “PP8693 also suspends entry of applicants designated under IEEPA: OFAC implements and enforces IEEPA sanctions. Designated individuals and organizations are listed on OFAC’s searchable SDN list.”
Proclamation 7750 (2004) as a pre-existing INA 212(f) proclamation. Confirmed in 9 FAM 302.14, which lists PP7750 alongside PP8693 as separate proclamations.
Post-2011 “refer-out” formula. Confirmed across dozens of EOs from three administrations. The formula “shall be treated as persons covered by section 1 of Proclamation 8693” appears in orders covering Ukraine, Libya, Nicaragua, North Korea, Venezuela, Global Magnitsky, CAATSA, the West Bank, and many others.
Annex A expansion via subsequent EOs. Confirmed: the Libya expansion EO (E.O. 13726, 2016) explicitly states “United Nations Security Council Resolution 2174 shall be treated as a Resolution listed in Annex A of Proclamation 8693.”
Continued use across administrations through 2025. Confirmed by citation in E.O. 14203 (2025 OFAC PDF).
E.O. 12978 lacking standalone entry suspension. Confirmed by inference from the CRS report, which states that Proclamation 8693 was issued “to suspend U.S. entry of foreign individuals sanctioned under E.O. 12978” — implying the 1995 order did not already have adequate entry suspension coverage of its own.
Inferential but reasonable
“Some older IEEPA EOs did not include entry suspension language.” The claim is supported by the CRS note about E.O. 12978, and by the fact that the Proclamation was created at all — if every IEEPA EO already had adequate entry suspension provisions, a consolidated proclamation would have been unnecessary. That said, I did not retrieve the full text of every pre-2011 IEEPA EO to verify this comprehensively. The claim is well-grounded but not exhaustively sourced.
UNSC travel bans implemented through “State Department guidance and consular practice” before 2011. Supported by the Proclamation’s preamble, which frames it as necessary to carry out US obligations under the UN Charter. But the specific mechanisms the State Department used before 2011 are not detailed in the sources retrieved. This is a reasonable inference, not a sourced factual claim.
Things not verified from retrieved sources
The specific list of EOs in Annex B. I retrieved the Proclamation text but not the full text of its annexes as published in the Federal Register on July 27, 2011. The claim that Annex B listed the IEEPA-based EOs then in existence is correct in structure but the specific list was not verified. Readers who need the precise original list should consult 76 Fed. Reg. 44751 (July 27, 2011).
Nothing in the main response rises to the level of a factual error.
The main areas of uncertainty are (1) the comprehensiveness of the pre-2011 gap (well-supported but not exhaustively verified) and (2) the exact contents of Annex B (structurally correct but not retrieved). The core analysis — what the Proclamation does, what each section means, how it plugs into the IEEPA framework, and how subsequent EOs reference it — is solidly sourced throughout.
Note: The Consent Agreement and Order documents were both not machine-readable, but Claude says the Proposed Charging Letter is more detailed anyhow.
GE Aerospace’s $36 Million Export Violation Settlement — Plain-Language Summary
What Happened?
On April 17, 2026, the U.S. Department of State announced that GE Aerospace (the jet-engine arm of General Electric) agreed to pay $36 million to settle 116 violations of U.S. arms export law. The violations took place over a roughly six-year window, from April 2018 through late 2024.
The relevant law is called ITAR — the International Traffic in Arms Regulations. Think of it as the strict rulebook that governs who American defense companies can share military technology with, and how. Violating ITAR is serious: it can harm national security and, in theory, expose a company to penalties exceeding $1.27 million per violation.
The Four Categories of Violations
1. Sending Sensitive Military Data to China (the most serious)
China is on America’s “do not share” list for arms and military technology. Despite this, GE had three separate incidentsof sending controlled technical data to China without authorization:
In 2018, an employee traveling to China carried a company laptop containing data related to F-35, F-16, F-15, and U-2 aircraft engines — and then left the laptop unattended with Chinese university officials for 90 minutes.
In 2021, an employee emailed a technical drawing of a component from the F118 military engine to a Chinese supplier, mistakenly thinking it was governed by a less-restrictive export rule (Commerce Department rules, rather than ITAR).
In 2023, GE shipped maintenance manuals for the F110 engine to Singapore on three occasions — but routed the packages through China, which itself is prohibited. Nobody had configured the shipping account to flag that as a problem.
The U.S. government determined that at least one of these incidents — the F118 engine drawing — actually provided China with useful military information.
2. Mismanaging Export Licenses and Agreements (the largest category — 103 charges)
GE held many government-approved licenses and agreements covering what military technology it could share with foreign partners, and under what conditions. It repeatedly failed to follow the fine print. Examples include:
Shipping repaired military components to the UK Ministry of Defense when the UK MoD wasn’t listed as an authorized recipient on the relevant agreement.
Allowing Japanese partners to pass military engine components to 31 unauthorized sub-suppliers over five years, because GE didn’t properly verify who was in the chain.
Sending technical data to suppliers in Mexico that went beyond what the license actually permitted.
Using a license exemption to ship turbine blade castings to Canada 30 times when a specific government condition required obtaining separate licenses for each shipment — and then failing to track the quantities properly.
Having a Swedish partner share engine maintenance data with an unauthorized entity in South Africa.
Failing to notify Congress of certain defense exports to Sweden, as required by law.
Repeatedly failing to submit required paperwork — things like purchase orders, amendment notifications, and lists of parties to agreements — on time or at all.
The root causes cited repeatedly: outdated internal procedures (some not updated in over 10 years), inadequate training, and insufficient oversight of foreign partners.
3. Exporting Defense Hardware Without Authorization (4 charges)
A wrong engine combustion liner (for the F404-400) was accidentally shipped to Sweden because commercial paperwork got mixed up between two different items.
15 machined chassis for the F-35 aircraft were temporarily exported to Israel across three shipments because an employee misclassified them under the wrong export control regime.
4. Failing to Update Its Government Registration (3 charges)
GE repeatedly failed to report material changes to its registration statement with the government’s defense trade regulator, as required within five days of any such change. This kind of administrative failure can obscure the government’s visibility into who a company is and what it’s doing.
The Settlement Terms
GE Aerospace will pay a civil penalty of $36 million. The Department of State agreed to suspend $18 million of that amount on the condition that those funds are used for remedial compliance improvements instead. For at least 24 months, GE must also engage an external Special Compliance Officer to oversee its compliance program, and must submit to at least one independent external audit. The full consent agreement runs for 36 months.
Why Wasn’t the Penalty Larger?
The maximum theoretical penalty for 116 violations would be enormous. The penalty was reduced significantly because:
GE voluntarily disclosed all 116 violations itself — it found the problems and reported them, rather than waiting to be caught.
GE fully cooperated with the government’s review.
GE had already started fixing its compliance program before the settlement.
That said, the government also noted aggravating factors: some of the exports involved Significant Military Equipment, violations were systemic across multiple business units, and the China incidents caused real national security harm.
Key Takeaways for Non-Expert Professionals
Self-disclosure matters enormously. GE’s decision to report its own violations — all 116 of them — likely saved the company hundreds of millions of dollars in potential penalties and avoided debarment from government contracting.
Compliance programs need maintenance. A recurring theme here is procedures that hadn’t been updated in a decade. Regulations change; compliance infrastructure has to keep pace.
You’re responsible for your partners’ compliance. Many violations occurred not at GE directly, but through foreign partners and sublicensees. Under ITAR, the U.S. license-holder is responsible for ensuring the whole chain follows the rules.
China is a red line. Any unauthorized sharing of military-related technical data with China — even routing a package through a Chinese airport — is treated as a serious aggravated violation.
Paperwork isn’t optional. A surprisingly large number of the 116 charges were essentially administrative failures: late filings, missing notifications, wrong forms. These are avoidable with proper systems.
The U.S. Department of State has concluded an administrative settlement with General Electric Company (GE Aerospace) to resolve 116 violations of the Arms Export Control Act (AECA), 22 U.S.C. § 2751 et seq., and the International Traffic in Arms Regulations (ITAR), 22 C.F.R. parts 120-130. The Department of State and GE Aerospace reached this settlement following an extensive compliance review by the Office of Defense Trade Controls Compliance in the Department’s Bureau of Political-Military Affairs.
The administrative settlement between the Department of State and GE Aerospace, concluded pursuant to ITAR § 128.11, addresses multiple categories of ITAR violations, including GE Aerospace’s unauthorized exports of technical data to the People’s Republic of China; violations of terms, conditions, and provisos of several Directorate of Defense Trade Controls authorizations involving various countries; unauthorized exports of defense articles to two countries; and failure to report material changes to its ITAR registration.
GE Aerospace voluntarily disclosed all the alleged violations, a substantial portion of which predate 2023. GE Aerospace also fully cooperated with the Department’s review of this matter and has implemented numerous improvements to its ITAR compliance program since the conduct at issue.
Under the terms of the 36-month Consent Agreement, GE Aerospace will pay a civil penalty of $36 million. The Department has agreed to suspend $18 million of this amount on the condition that the funds will be used for the Department-approved Consent Agreement’s remedial compliance measures to strengthen GE Aerospace’s compliance program. In addition, for an initial period of at least 24 months, GE Aerospace will engage an external Special Compliance Officer to oversee the Consent Agreement, which will also require at least one external audit of its ITAR compliance program and implementation of additional compliance measures.
This settlement demonstrates the Department’s role in furthering the national security and foreign policy of the United States by controlling the export of defense articles. The settlement also highlights the importance of exporting defense articles pursuant only to appropriate authorization from the Department.
