Category: Iran

  • My prompt to Claude (yes, it was a tad snarky):

    So… other than publicity, and maybe some secondary sanctions exposure, what was the value, if any, of that update? VTB was already subject to an asset freeze, no? explain in language for the common public

    Claude’s initial response, which I took issue with:

    You’re right about the core of it. VTB’s money was already frozen. Nothing about how an American bank handles a VTB hit changed on Sunday. Blocked is blocked, and there is no such thing as more blocked. If the only audience were US institutions, this update would be paperwork.

    The audience is not US institutions.

    The new tag changes which rulebook foreign banks apply. Russia sanctions and Iran sanctions are not two flavors of the same thing to a bank in Dubai, Istanbul, Mumbai or Shanghai. The Russia rules that expose foreign banks to US penalties are discretionary. Treasury may act against a foreign bank that handles significant business for a sanctioned Russian entity, and in practice it has acted sparingly, often with a warning first. The Iran rules are older, partly written by Congress rather than the President, and carry mandatory triggers. Foreign bank boards have long memories about what happened to institutions that got caught on the wrong side of Iran sanctions in the 2010s, and the fines involved.

    There is a second layer that has nothing to do with US law. Many non-US banks write their own internal policies so that any Iran connection is a hard stop, while Russia exposure gets a case-by-case review. Adding an Iran tag to VTB can therefore trip a stricter internal rule automatically at institutions that had been carefully doing limited Russia business. That is my read from how these policies are typically drafted, not something Treasury said.

    The designation also outlives a Russia deal. This is the part I would put first if I were writing it for a general reader. There is real talk of the Ukraine war ending and of Russia sanctions being unwound as part of a settlement. If that happens, VTB’s Russia designations come off. The Iran designation would not, because it rests on different conduct under a different authority. Think of a condemned building. A second violation notice does not make it more condemned, but if the first notice is withdrawn, the second one still keeps the doors locked. Treasury has bought itself a lock that a Russia peace deal does not open.

    And it puts the accusation on the public record. Until this week, a foreign bank could plausibly say it had no idea VTB was running correspondent accounts for sanctioned Iranian banks or moving frozen Iranian assets. Now that claim is on a US government page with VTB’s name on it. Nobody gets to be surprised anymore, and “we didn’t know” stops being available as a defense.

    One smaller thing that matters to people who run screening systems. OFAC took 21 of VTB’s old names, things like plain “VNESHTORGBANK,” and moved them from “used to be called this” to “also called this.” Some screening setups treat former names as lower priority or filter them out. Those 21 names just came back to full strength, and no press release explains why.

    So the honest summary is that this update does very little to VTB’s money and quite a lot to VTB’s remaining business relationships and to the government’s negotiating position. Which is roughly what you would expect from a campaign whose stated goal is isolation rather than seizure.

    My follow-up:

    well, if you were already defying the US Russia sanctions, how likely is it that this would change your behavior? Is it just because the President is more focused on Iran now than Russia? And would it really change the behavior of Chinese firms?

    And the response:

    Your first question mostly answers itself, and it exposes something soft in what I told you earlier.

    Anyone still clearing business for VTB in September 2026 has already made peace with being outside the US financial system. That population is self-selected for indifference. Adding a tag to a party you were already willing to be caught dealing with is not a new deterrent, it is the same deterrent restated. The banks that could be moved by this are the ones with US correspondent accounts they still want to keep, and those banks mostly exited VTB in 2022. So the group sitting between “already gone” and “already defiant” is thin.

    I also overstated one thing. I said the Iran rules carry mandatory triggers where the Russia ones are discretionary. That is true of the statutory Iran provisions, CISADA and IFCA and the NDAA correspondent-account section, but it is not true of what OFAC actually invoked here. Treasury’s own release says OFAC “can prohibit or impose strict conditions on” a foreign bank’s correspondent account. That is permissive language. The legal difference between the Russia exposure and the new Iran exposure is narrower than I made it sound. What is genuinely different is reputational, not statutory.

    On whether this is about presidential attention, largely yes, and I would put it more bluntly than I did. Treasury is running an Iran campaign that needs visible targets while it is simultaneously negotiating over Russia. Hitting VTB under a Russia authority would cut across the negotiation. Hitting the same bank under an Iran authority produces the headline without disturbing that track. The choice of authority is doing diplomatic work as much as legal work. The durability point I raised stands, since an Iran designation survives a Russia settlement, but I should be clear that is a benefit to Treasury’s future position rather than a cost imposed on VTB today.

    Chinese firms are the weakest part of the case. The large state banks pulled back from VTB years ago and have run conservative Iran policies since the last decade. Nothing here reaches them because they already left. The institutions that do handle sanctioned trade are small regional banks with no dollar business to lose, and the precedent for how that plays out is Bank of Kunlun, which the US designated in 2012 over Iran and which China then simply used as the designated channel. Cutting a bank off from a system it does not use is not much of a penalty. Add that a growing share of this trade settles in renminbi through CIPS, and the lever you are pulling is attached to nothing.

    Where I think there is real value, and it is plumbing rather than deterrence, is that a designation under an Iran authority creates a predicate for designating the people who help VTB with its Iran business. Those orders generally include a materially-assisted prong, though I have not pulled the text of 13902 to confirm the specific wording. If that is right, the update is less a punishment of VTB than a hook for whoever gets named next.

    so, maybe not Much Ado About Nothing, but more like Much Ado About Something Possibly in the Future…. meh.

    , , , ,
  • Iran-related Designation; Issuance of Amended Venezuela-related General License and Frequently Asked Question

    Treasury Press Release: Operation Economic Outcast Sanctions Major Bank Helping Iran Evade Sanctions

    State Press Release: U.S. Sanctions VTB Bank for Aiding Iran’s Sanctions Evasion

    Amendments:

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

    • OFAC Programs:
      • [UKRAINE-EO13662]  Executive Order 13662
      • [IRAN-EO13902]  Executive Order 13902
      • [RUSSIA-EO14024]  Executive Order 14024

    VTB BANK PUBLIC JOINT STOCK COMPANY (Cyrillic: БАНК ВТБ ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО)

    • AKA:
      • BANK FOR FOREIGN TRADE OF RSFSR
      • BANK OF FOREIGN TRADE OF THE RUSSIAN FEDERATION
      • BANK VNESHEI TORGOVLI OAO
      • BANK VNESHNEI TORGOVLI ROSSISKOI FEDERATSII AS A PRIVATE JOINT STOCK COMPANY
      • BANK VNESHNEI TORGOVLI RSFSR
      • BANK VNESHNEY TORGOVLI JOINT STOCK COMPANY
      • BANK VNESHNEY TORGOVLI OPEN JOINT STOCK COMPANY
      • BANK VNESHNEY TORGOVLI ROSSIYSKOY FEDERATSII CLOSED JOINT STOCK COMPANY
      • BANK VTB OAO
      • BANK VTB OPEN JOINT STOCK COMPANY
      • BANK VTB PAO
      • BANK VTB PUBLICHNOE AKTSIONERNOE OBSHCHESTVO
      • CJSC BANK FOR FOREIGN TRADE OF THE RUSSIAN FEDERATION
      • JSC VTB BANK
      • OAO BANK VTB
      • OAO VNESHTORGBANK
      • OJSC CJSC BANK FOR FOREIGN TRADE
      • RUSSIAN VNESHTORGBANK
      • VNESHTORGBANK
      • VNESHTORGBANK OF RSFSR
      • VNESHTORGBANK ROSSII CLOSED JOINT STOCK COMPANY
      • VTB BANK
      • VTB BANK OAO
      • VTB BANK OPEN JOINT STOCK COMPANY
      • VTB BANK PAO
      • VTB BANK PJSC (Cyrillic: БАНК ВТБ ПАО)
      • VTB BANK PJSC SHANGHAI BRANCH
      • "JSC VTB BANK NEW DELHI BRANCH"
    • Address:
      • 29, Bolshaya Morskaya str., St. Petersburg 190000, Russia
      • 37 Plyushchikha ul., Moscow 119121, Russia
      • 43, Vorontsovskaya str., Moscow 109044, Russia
      • 11 litera, per. Degtyarny, St. Petersburg 191144, Russia
      • 11, lit A, Degtyarnyy pereulok, St. Petersburg 191144, Russia
      • 43, bld.1, Vorontsovskaya str., Moscow 109147, Russia
      • Bashnya Zapad, Kompleks Federatsiya, 12, nab. Presnenskaya, Moscow 123317, Russia
      • str. 1, 43, ul. Vorontsovskaya, Moscow 109147, Russia
      • Vorontsovskaya Str 43, Moscow 109147, Russia
      • The Taj Mahal Hotel, Lobby Mezzanine Floor 1, Mansingh Road, New Delhi 110001, India
      • 1266 Nanjing Xilu Street, Jingan District, Shanghai 200040, China
      • 18 BC, CITIC Building, 19 Jianguomenwai Dajie, Beijing 100004, China
      • Tehran, Iran
    • SWIFT/BIC: VTBRRUMM
    • Website: http://www.vtb.com
    • alt. Website: http://www.vtb.ru
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • BIK (RU): 044030707
    • alt. BIK (RU): 044525187
    • Executive Order 13662 Directive Determination: Subject to Directive 1
    • Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209
    • alt. Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Organization Established Date: 17 Oct 1990
    • Target Type: Financial Institution
    • Registration ID: 1027739609391 (Russia)
    • Tax ID No.: 7702070139 (Russia)
    • Government Gazette Number: 00032520 (Russia)
    • License: 1000 (Russia)
    • Legal Entity Number: 253400V1H6ART1UQ0N98
    • For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives

    Supplemental Information: OFAC designated VTB Bank under E.O. 13902 for operating in the financial sector of the Iranian economy, as part of Operation Economic Outcast. Treasury states that the bank opened offices in Iran in recent years to formalize closer banking coordination with the Iranian regime and expand trade between the two countries, and that over the past three years it established correspondent banking relationships with sanctioned Iranian financial institutions. Treasury further states that VTB began taking steps to increase its presence in Tehran in January 2025, has taken steps to move billions of dollars in frozen Iranian assets, and created a national-currency settlement system running through correspondent accounts denominated in Iranian rials and Russian rubles, with the goal of increasing bilateral trade. State’s parallel statement describes the same conduct, citing offices opened in Iran, banking ties built with sanctioned Iranian financial institutions, and work to move billions of dollars in Iranian assets.

    The entry now carries three program tags, one for each authority under which VTB has been designated. Treasury recounts that the bank was designated on February 24, 2022 under E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, the Government of Russia, and for operating in the financial services sector of the Russian Federation economy, and again on January 15, 2025 under E.O. 13662 for operating in that same sector. That second designation was part of a wider January 2025 action in which OFAC re-designated financial services, energy, and defense sector entities under E.O. 13662, a step that subjects foreign persons who knowingly facilitate significant transactions for those entities to mandatory secondary sanctions under CAATSA. Treasury describes VTB as now among the most comprehensively sanctioned financial institutions in the world, and warns that foreign financial institutions that continue to deal with the bank following this designation face greater sanctions risk than before and should cut off those relationships immediately. Operation Economic Outcast was announced by Secretary of the Treasury Scott Bessent on August 24, 2026 and dubbed “Economic D-Day”; today’s action follows recent Treasury actions against banks in Turkey and the UAE.

    List of Changes:

    • Field Name: AKA
      • Changed: f.k.a. to: a.k.a. for BANK FOR FOREIGN TRADE OF RSFSR
      • Changed: f.k.a. to: a.k.a. for BANK OF FOREIGN TRADE OF THE RUSSIAN FEDERATION
      • Changed: f.k.a. to: a.k.a. for BANK VNESHEI TORGOVLI OAO
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEI TORGOVLI ROSSISKOI FEDERATSII AS A PRIVATE JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEI TORGOVLI RSFSR
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEY TORGOVLI JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEY TORGOVLI OPEN JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEY TORGOVLI ROSSIYSKOY FEDERATSII CLOSED JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for BANK VTB OAO
      • Changed: f.k.a. to: a.k.a. for BANK VTB OPEN JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for CJSC BANK FOR FOREIGN TRADE OF THE RUSSIAN FEDERATION
      • Changed: f.k.a. to: a.k.a. for JSC VTB BANK
      • Changed: f.k.a. to: a.k.a. for OAO BANK VTB
      • Changed: f.k.a. to: a.k.a. for OAO VNESHTORGBANK
      • Changed: f.k.a. to: a.k.a. for OJSC CJSC BANK FOR FOREIGN TRADE
      • Changed: f.k.a. to: a.k.a. for RUSSIAN VNESHTORGBANK
      • Changed: f.k.a. to: a.k.a. for VNESHTORGBANK
      • Changed: f.k.a. to: a.k.a. for VNESHTORGBANK OF RSFSR
      • Changed: f.k.a. to: a.k.a. for VNESHTORGBANK ROSSII CLOSED JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for VTB BANK OAO
      • Changed: f.k.a. to: a.k.a. for VTB BANK OPEN JOINT STOCK COMPANY
    • Field Name: Address
      • Added: Tehran, Iran
    • Field Name: Additional Sanctions Information
      • Added: Subject to Secondary Sanctions
    • Field Name: OFAC Program Tags
      • Added: [IRAN-EO13902]

    The following changes have been made to OFAC’s Sectoral Sanctions Identifications List:

    • OFAC Programs:
      • [UKRAINE-EO13662]  Executive Order 13662
      • [IRAN-EO13902]  Executive Order 13902
      • [RUSSIA-EO14024]  Executive Order 14024

    VTB BANK PUBLIC JOINT STOCK COMPANY (Cyrillic: БАНК ВТБ ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО)

    • AKA:
      • BANK FOR FOREIGN TRADE OF RSFSR
      • BANK OF FOREIGN TRADE OF THE RUSSIAN FEDERATION
      • BANK VNESHEI TORGOVLI OAO
      • BANK VNESHNEI TORGOVLI ROSSISKOI FEDERATSII AS A PRIVATE JOINT STOCK COMPANY
      • BANK VNESHNEI TORGOVLI RSFSR
      • BANK VNESHNEY TORGOVLI JOINT STOCK COMPANY
      • BANK VNESHNEY TORGOVLI OPEN JOINT STOCK COMPANY
      • BANK VNESHNEY TORGOVLI ROSSIYSKOY FEDERATSII CLOSED JOINT STOCK COMPANY
      • BANK VTB OAO
      • BANK VTB OPEN JOINT STOCK COMPANY
      • BANK VTB PAO
      • BANK VTB PUBLICHNOE AKTSIONERNOE OBSHCHESTVO
      • CJSC BANK FOR FOREIGN TRADE OF THE RUSSIAN FEDERATION
      • JSC VTB BANK
      • OAO BANK VTB
      • OAO VNESHTORGBANK
      • OJSC CJSC BANK FOR FOREIGN TRADE
      • RUSSIAN VNESHTORGBANK
      • VNESHTORGBANK
      • VNESHTORGBANK OF RSFSR
      • VNESHTORGBANK ROSSII CLOSED JOINT STOCK COMPANY
      • VTB BANK
      • VTB BANK OAO
      • VTB BANK OPEN JOINT STOCK COMPANY
      • VTB BANK PAO
      • VTB BANK PJSC (Cyrillic: БАНК ВТБ ПАО)
      • VTB BANK PJSC SHANGHAI BRANCH
      • "JSC VTB BANK NEW DELHI BRANCH"
    • Address:
      • 29, Bolshaya Morskaya str., St. Petersburg 190000, Russia
      • 37 Plyushchikha ul., Moscow 119121, Russia
      • 43, Vorontsovskaya str., Moscow 109044, Russia
      • 11 litera, per. Degtyarny, St. Petersburg 191144, Russia
      • 11, lit A, Degtyarnyy pereulok, St. Petersburg 191144, Russia
      • 43, bld.1, Vorontsovskaya str., Moscow 109147, Russia
      • Bashnya Zapad, Kompleks Federatsiya, 12, nab. Presnenskaya, Moscow 123317, Russia
      • str. 1, 43, ul. Vorontsovskaya, Moscow 109147, Russia
      • Vorontsovskaya Str 43, Moscow 109147, Russia
      • The Taj Mahal Hotel, Lobby Mezzanine Floor 1, Mansingh Road, New Delhi 110001, India
      • 1266 Nanjing Xilu Street, Jingan District, Shanghai 200040, China
      • 18 BC, CITIC Building, 19 Jianguomenwai Dajie, Beijing 100004, China
      • Tehran, Iran
    • SWIFT/BIC: VTBRRUMM
    • Website: http://www.vtb.com
    • alt. Website: http://www.vtb.ru
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • BIK (RU): 044030707
    • alt. BIK (RU): 044525187
    • Executive Order 13662 Directive Determination: Subject to Directive 1
    • Secondary sanctions risk: Ukraine-/Russia-Related Sanctions Regulations, 31 CFR 589.201 and/or 589.209
    • alt. Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Organization Established Date: 17 Oct 1990
    • Target Type: Financial Institution
    • Registration ID: 1027739609391 (Russia)
    • Tax ID No.: 7702070139 (Russia)
    • Government Gazette Number: 00032520 (Russia)
    • License: 1000 (Russia)
    • Legal Entity Number: 253400V1H6ART1UQ0N98
    • For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives

    Supplemental Information: VTB Bank has been carried on the SSI List since 2014, when OFAC determined it to be subject to Directive 1 under E.O. 13662, which restricts dealings in new debt and new equity of Russian financial services sector entities. Because the bank has been fully blocked since February 24, 2022 under E.O. 14024, the SSI entry has for several years recorded a restriction narrower than the one that actually governs dealings with it.

    OFAC applied today’s Iran-related change to the SSI record in identical form. The old and new SSI listings match the corresponding SDN listings word for word, down to the same Tehran address, the same secondary sanctions notation, the same 21 alias qualifier changes, and the same added [IRAN-EO13902] tag. Firms that load the SSI List as a separate file should expect the same field-level changes there as on the SDN side. One data point worth checking against internal reference tables is the tag itself. OFAC’s own Program Tag Definitions page assigns [IRAN-EO13902] to the SDN List and does not name the SSI List among the lists on which that tag appears.

    List of Changes:

    • Field Name: AKA
      • Changed: f.k.a. to: a.k.a. for BANK FOR FOREIGN TRADE OF RSFSR
      • Changed: f.k.a. to: a.k.a. for BANK OF FOREIGN TRADE OF THE RUSSIAN FEDERATION
      • Changed: f.k.a. to: a.k.a. for BANK VNESHEI TORGOVLI OAO
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEI TORGOVLI ROSSISKOI FEDERATSII AS A PRIVATE JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEI TORGOVLI RSFSR
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEY TORGOVLI JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEY TORGOVLI OPEN JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for BANK VNESHNEY TORGOVLI ROSSIYSKOY FEDERATSII CLOSED JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for BANK VTB OAO
      • Changed: f.k.a. to: a.k.a. for BANK VTB OPEN JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for CJSC BANK FOR FOREIGN TRADE OF THE RUSSIAN FEDERATION
      • Changed: f.k.a. to: a.k.a. for JSC VTB BANK
      • Changed: f.k.a. to: a.k.a. for OAO BANK VTB
      • Changed: f.k.a. to: a.k.a. for OAO VNESHTORGBANK
      • Changed: f.k.a. to: a.k.a. for OJSC CJSC BANK FOR FOREIGN TRADE
      • Changed: f.k.a. to: a.k.a. for RUSSIAN VNESHTORGBANK
      • Changed: f.k.a. to: a.k.a. for VNESHTORGBANK
      • Changed: f.k.a. to: a.k.a. for VNESHTORGBANK OF RSFSR
      • Changed: f.k.a. to: a.k.a. for VNESHTORGBANK ROSSII CLOSED JOINT STOCK COMPANY
      • Changed: f.k.a. to: a.k.a. for VTB BANK OAO
      • Changed: f.k.a. to: a.k.a. for VTB BANK OPEN JOINT STOCK COMPANY
    • Field Name: Address
      • Added: Tehran, Iran
    • Field Name: Additional Sanctions Information
      • Added: Subject to Secondary Sanctions
    • Field Name: OFAC Program Tags
      • Added: [IRAN-EO13902]

    Sources

    , ,
  • What Happened

    An individual U.S. lawful permanent resident, whom OFAC identifies only as “U.S. Person-1,” has agreed to pay $1,427,230 to settle 39 apparent violations of U.S. sanctions on Iran. Between June 2019 and July 2021, U.S. Person-1 advised the management of one of Iran’s leading software companies, had Iranian dividends paid into their U.S. bank accounts, and bought real estate in Iran. OFAC investigated and resolved the case together with the FBI’s Los Angeles Field Office, through its Orange County Resident Agency.

    The relationship dates to 1987, when U.S. Person-1, then living in Iran, co-founded an Iranian software company that OFAC calls Iranian Company-1. After that company became publicly listed in Iran in 2011, U.S. Person-1 co-founded a second Iranian company, a holding company OFAC calls Iranian Company-2, to keep their ownership stake in the first.

    Iranian Company-1 has since become one of Iran’s leading software providers. Its products cover finance, administration, human resources, logistics, and management for industries central to Iran’s economy, among them petrochemicals, pharmaceuticals, construction, and agriculture. Its customers also include government agencies, universities, research centers, and state-owned enterprises.

    U.S. Person-1 kept up their ties to both companies for many years. Between July 2019 and October 2020, they took part in 19 virtual meetings with senior personnel of the two companies. The other participants included directors and officers of Iranian Company-1, among them its Chief Executive Officer (who had co-founded the company with U.S. Person-1), the Chairman of its Board of Directors, and an employee who served as Board Secretary.

    The meetings covered a wide range of company business, from corporate transactions and asset management to sales, marketing, accounting, human resources, corporate governance, and overall strategy. U.S. Person-1 drafted the agenda for some of the meetings and contributed substantive advice, analysis, and information throughout. OFAC treated this participation as the provision of management consulting and advisory services to the Iranian companies.

    Separately, between June 2019 and August 2020, U.S. Person-1 had their dividends from the Iranian companies wired into U.S. banks on 16 occasions. The transfers passed through banks in third countries such as Türkiye, the United Arab Emirates, and Singapore before reaching accounts in U.S. Person-1’s name. In total, U.S. Person-1 received $713,615 in dividend payments.

    In or after 2021, U.S. Person-1 used the proceeds of other dividend payments to buy four properties in Iran for relatives living there. In 2022, they gave up their ownership interest in the Iranian companies.

    U.S. Person-1 was aware of U.S. sanctions on Iran the whole time. In 2000, while an executive of Iranian Company-1 in Iran, they co-wrote an article in a leading newspaper about Iran’s digital revolution and the challenges the sanctions program posed for Iran’s information technology sector.

    OFAC sent U.S. Person-1 an administrative subpoena in January 2025, and the initial response was incomplete. In July 2025, OFAC issued a second subpoena, citing the gaps in the first response. U.S. Person-1 then provided a complete response.

    Altogether, OFAC grouped the conduct into three kinds of apparent violations. U.S. Person-1 provided management consulting and advisory services to Iran 19 times. On 16 occasions, they caused U.S. banks to indirectly export financial services to Iran by processing Iranian-origin dividends. They also bought real property in Iran with Iranian-origin dividends four times.

    OFAC cited three provisions of the Iranian Transactions and Sanctions Regulations (ITSR) for this conduct. Section 560.203 prohibits causing a violation of any of the ITSR’s other prohibitions, as well as evasion, attempted violations, and conspiracies. Section 560.204 bars the export of goods, technology, or services to Iran from the United States or by a U.S. person. Section 560.207 prohibits new investment in Iran by U.S. persons.

    The release appears to pair the first two types of conduct with the wrong provisions. It lists the consulting, the dividends, and the property purchases in that order, then cites Sections 560.203, 560.204, and 560.207 “respectively,” which would tie the consulting to Section 560.203 and the dividends to Section 560.204. The fit runs the other way. A U.S. person advising Iranian companies is exporting services to Iran, which is what Section 560.204 prohibits, while causing U.S. banks to export financial services falls under Section 560.203’s ban on causing violations. The property purchases line up correctly with Section 560.207.

    The Penalty

    OFAC found that the violations were egregious and that U.S. Person-1 had not voluntarily disclosed them – a combination that puts a case in the most serious of the four categories OFAC uses to set a starting penalty.

    Under OFAC’s Economic Sanctions Enforcement Guidelines (31 C.F.R. Part 501, Appendix A), that category produced a base penalty of $14,730,300 for this case. OFAC treated all 39 violations together as a single egregious case, so the release doesn’t break the base penalty down by type of violation.

    The release calls this figure the “applicable schedule amount,” which appears to be a drafting error. Under the Enforcement Guidelines, the schedule amount is the starting point for non-egregious cases that weren’t voluntarily disclosed. For an egregious case like this one, the starting point is the statutory maximum, which under IEEPA is currently $377,700 per violation, or twice the transaction value if that is greater. Multiplying $377,700 by the 39 violations gives exactly $14,730,300. Nor could the figure be a schedule amount, since the schedule reaches $377,700 only for transactions of $200,000 or more, and the 16 dividend payments, which totaled $713,615, can’t all have been that large.

    The violations took place between 2019 and 2021, when the IEEPA maximum was lower, but using today’s figure is correct. Since the Federal Civil Penalties Inflation Adjustment Act was amended in 2015, each inflation adjustment applies to penalties assessed after it takes effect, even when the underlying violation happened earlier, as long as the violation occurred after November 2, 2015.

    The final settlement of $1,427,230, roughly a tenth of the base penalty, reflects OFAC’s weighing of the General Factors in its Enforcement Guidelines.

    Aggravating factors

    • U.S. Person-1 violated U.S. sanctions willfully and over a period of years. They knew Iran was under sanctions and that their activities there were prohibited. Even so, after becoming a U.S. lawful permanent resident, they kept a significant ownership stake in both Iranian companies, advised the companies on their Iranian operations, and carried out financial and commercial activity in Iran from the United States.
      • General Factor A, Willful or Reckless Violation of Law: This factor asks whether a person acted knowing the conduct was against U.S. law, and whether the violations formed a pattern or were isolated. Both counted against U.S. Person-1, whose conduct was deliberate and continued over several years across several types of activity.
    • U.S. Person-1 had actual knowledge of each part of the conduct. By taking part in the meetings, they knew they were advising companies organized and located in Iran, and as a co-founder of Iranian Company-1, they knew the work related to services performed inside Iran. They also knew the dividends were Iranian in origin, including the money paid into their U.S. accounts and the money used to buy property in Iran.
      • General Factor B, Awareness of Conduct at Issue: The more a person actually knew about the conduct behind a violation, the stronger OFAC’s response. Here the knowledge was firsthand, not a matter of warning signs someone should have caught.
    • U.S. Person-1’s services undermined the goals of the Iran sanctions by giving an economic benefit to Iran’s largest software company and, indirectly, to the many private and public sector organizations it serves. Iranian Company-1’s software supports enterprise resource planning for national and regional government bodies, universities, research centers, and state-owned enterprises.
      • General Factor C, Harm to Sanctions Program Objectives: This factor measures the economic benefit that conduct gives a sanctioned country. Here the benefit reached beyond a single company into Iranian government agencies and state-owned enterprises.
    • U.S. Person-1 is a sophisticated businessperson who spent decades working in Iran’s information technology sector, and they were aware of how U.S. sanctions affected that sector.
      • General Factor D, Individual Characteristics: OFAC weighs a person’s commercial sophistication and experience. A long career in the same industry whose sanctions problems U.S. Person-1 had written about counted against them.
    • U.S. Person-1’s cooperation with OFAC was unsatisfactory at first. They cooperated adequately and answered OFAC’s questions only after OFAC issued a second subpoena.
      • General Factor G, Cooperation with OFAC: This factor looks at whether a person provides all relevant information and responds promptly to requests. An incomplete response that took a second subpoena to correct fell short on both counts.

    Mitigating factors

    • U.S. Person-1 had not been the subject of any OFAC enforcement action in the five years before the earliest transaction at issue.
      • General Factor D, Individual Characteristics: A person’s sanctions history over that five-year window is part of this factor. A clean record generally qualifies as a “first violation,” which can reduce the base penalty by up to 25 percent.
    • U.S. Person-1 stopped the conduct before receiving OFAC’s subpoena, and had given up their shares in the Iranian companies years before learning of OFAC’s investigation.
      • General Factor F, Remedial Response: This factor considers whether a person stopped the conduct at issue. U.S. Person-1 had already ended the conduct years before OFAC made contact.
    • OFAC considered U.S. Person-1’s inability to pay a larger settlement, which they proved to OFAC’s satisfaction with extensive and detailed supporting documentation.
      • General Factor D, Individual Characteristics: This factor includes a person’s overall financial condition. Here that condition limited how large a settlement U.S. Person-1 could pay.

    What are the Takeaways?

    OFAC’s prohibitions apply to all U.S. persons, and that includes lawful permanent residents (green card holders). Like most OFAC programs, the Iran sanctions program defines a U.S. person to include any U.S. citizen or permanent resident, wherever they are located (31 C.F.R. § 560.314). When U.S. Person-1 moved to the United States, they took on the same compliance obligations as any other U.S. person.

    Keeping up business relationships with people in Iran is risky. The Iran prohibitions are broad and generally bar any direct or indirect dealings, including providing or receiving personal services. Unless OFAC has issued a license, a U.S. person who helps manage the affairs of a business in Iran, or in any other sanctioned jurisdiction, is almost certain to violate sanctions.

    Cooperating promptly and fully with an OFAC investigation matters. OFAC considers how well a subject cooperates when it decides how to resolve a case and how large a penalty or settlement should be. Timely, thorough cooperation shows that the subject takes their sanctions compliance obligations seriously. It also saves OFAC time and resources by letting it finish the investigation efficiently.

    Cooperation that falls short carries two risks. The subject can lose the mitigation credit that good cooperation would have earned, and can also face separate penalties under OFAC’s Reporting, Procedures and Penalties Regulations (31 C.F.R. Part 501).

    Other resources

    OFAC’s May 2019 publication, A Framework for OFAC Compliance Commitments, gives the agency’s view of the essential components of a sanctions compliance program. It is aimed at organizations subject to U.S. jurisdiction, and at foreign companies that do business in or with the United States or U.S. persons, or that use goods or services exported from the United States. The Framework also explains how OFAC may factor those components into its evaluation of apparent violations and its settlements, and an appendix analyzes some of the root causes of apparent violations that OFAC has identified in its investigations.

    OFAC’s website offers other resources for sanctions implementation and compliance, including guidance for specific industries, instructional videos, answers to frequently asked questions, and tools for searching OFAC’s sanctions lists.

    The rules for the civil penalties process are in the regulations for each sanctions program, the Reporting, Procedures and Penalties Regulations (31 C.F.R. Part 501), and the Enforcement Guidelines (31 C.F.R. Part 501, Appendix A). OFAC keeps these references, along with recent civil penalties and enforcement information, on its civil penalties and enforcement page.

    Separately, Treasury’s Financial Crimes Enforcement Network (FinCEN) runs a whistleblower incentive program covering violations of OFAC-administered sanctions, other violations of the International Emergency Economic Powers Act, and violations of the Bank Secrecy Act. Whistleblowers in the United States or abroad may be eligible for an award if their information leads to a successful enforcement action with monetary penalties over $1,000,000. The program covers information about potential violations in any commercial sector.

    and here is the text of the enforcement release:

    , ,
  • Licensing Policy Update under Operation Economic Outcast

    OFAC’s Iran-related specific licensing policy has been modified in furtherance of the U.S. Department of the Treasury-led Operation Economic Outcast. Effective immediately, OFAC is considering Iran-related specific license applications with a presumption of denial except as required by law or in certain circumstances, such as risk to life, limb, or environmental safety. Applicants are encouraged to subscribe to OFAC Recent Actions for further updates.

    The modified policy document:

    , ,
  • Iran-related and Counter Terrorism Designations; Licensing Policy Update under Operation Economic Outcast; Settlement Agreement between OFAC and an Individual

    Treasury Press Release: Operation Economic Outcast Strikes Iran’s Global Terrorist Proxy Network

    State Press Release: U.S. Takes Action Against Iran’s Terrorist Proxies

    Additions:

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

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

    AL ABADA, Khaldoon Naser Maryoosh

    • AKA:
      • AL-ABADA, Khaldun Nasir Mariush
      • AL-‘IBADA, Khaldun Nasir Mariyush
    • Address: Iraq
    • DOB: 04 Jan 1980
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: B23554644 (Iraq) expires 18 Jan 2033
    • Party Type: individual
    • Linked to: AIN AL IRAQ FOR PROTECTION SYSTEMS TECHNOLOGY AND AUDIO, VISUAL, AND COMMUNICATIONS SOLUTIONS COMPANY LTD

    Supplemental Information: Treasury identifies Al-Abada as a representative of Ain Al-Iraq, a procurement company affiliated with Iraq’s Popular Mobilization Commission (PMC), the body that governs the Popular Mobilization Forces (PMF). He coordinates the PMC’s acquisition of foreign defense equipment and components and also advises the PMC as a consultant. OFAC designated him under E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Ain Al-Iraq.

    Treasury describes both the PMF and the PMC as heavily dominated by Iran-aligned militias, such as Kata’ib Hizballah (KH), that operate at the direction of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). State’s parallel statement presents the day’s actions as exposing how far the IRGC-QF has co-opted the PMF.

    AL AMERI, Abdullah Nadhim Luaibi

    • AKA: AL AMIRI, Abdallah Nazim Luaybi
    • Address: Iraq
    • DOB: 29 Jul 1975
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: A19542583 (Iraq) expires 22 Mar 2030
    • Party Type: individual
    • Linked to: AL-MAKSUSI, Sayyid Salah Mahdi Hantush

    Supplemental Information: Treasury describes Al Ameri as a UAE-based Iraqi arms dealer who founded Iraq-based Al-Brouj For General Contracting Company Ltd and serves as its chief executive officer. Through Al-Brouj he supplies goods and services to the PMC, including what Treasury calls likely unlawful procurement of equipment with military applications. He also uses the company to support Iraqi military organizations that operate under IRGC-QF direction, for example by maintaining Russian-provided helicopters.

    OFAC designated Al Ameri under 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, Salah Mahdi Hantush al-Maksusi. Al-Maksusi is a former KH official who heads the PMC’s Directorate of Technical Equipment (DTE). OFAC designated him in 2012 for his involvement in KH attacks on U.S. and coalition forces in Iraq.

    Treasury calls Al Ameri UAE-based, yet his listing gives Iraq as his only address, so address data alone will not place him in the UAE. The release also spells al-Maksusi’s given name two ways, Salah and Saleh. The Linked To field uses Sayyid Salah Mahdi Hantush.

    AL-DHUHAIBAWI, Hussein Ahmed Hussein

    • Address: Iraq
    • DOB: 15 Sep 1984
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: A14283389 (Iraq) expires 06 Oct 2026
    • Party Type: individual
    • Linked to: KATA’IB HIZBALLAH

    Supplemental Information: Treasury identifies Al-Dhuhaibawi as one of three active KH members designated alongside senior KH commander Ali Hasan Farhan Al-Lami. OFAC designated all four under E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, KH. The passport in his listing expires on October 6, 2026, less than a month after the designation.

    The State Department designated KH as a Specially Designated Global Terrorist and as a Foreign Terrorist Organization on June 24, 2009. Treasury describes KH as the most influential faction within the PMF, with members in PMC leadership posts that oversee the PMF’s intelligence, missiles, anti-armor and special forces directorates. That influence makes KH a major beneficiary of the more than $2.6 billion in annual Iraqi government funding allocated to the PMF.

    Treasury also cites the May 16, 2026 arrest of a senior KH commander for attempting to arrange the bombing of a New York synagogue and of other Jewish institutions in Los Angeles and Scottsdale. According to Treasury, KH and other Iran-aligned militia groups in Iraq have carried out hundreds of attacks on U.S. and Coalition forces in Iraq and across the region since February 2026.

    AL-HRAISHAWI, Karrar Mohammed Qasim

    • Address: Iraq
    • DOB: 11 Sep 2000
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: A19392691 (Iraq) expires 19 Dec 2029
    • Party Type: individual
    • Linked to: KATA’IB HIZBALLAH

    Supplemental Information: Treasury identifies Al-Hraishawi as an active KH member. He was designated with Al-Lami, Al-Dhuhaibawi and Al-Shaikhli on the same basis, for acting for or on behalf of KH. Born on September 11, 2000, he is the youngest person designated in this action.

    AL-LAMI, Ali Hasan Farhan

    • Address: Iraq
    • DOB: 18 Dec 1983
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: A11690581 (Iraq) expires 06 Jan 2025
    • Party Type: individual
    • Linked to: KATA’IB HIZBALLAH

    Supplemental Information: Treasury identifies Al-Lami as a senior KH commander, the most senior of the four KH figures designated in this action, and OFAC designated him under E.O. 13224, as amended, for acting for or on behalf of KH.

    The passport number in his listing expired on January 6, 2025, well before the designation. OFAC routinely keeps expired travel documents in its listings, so screening on document numbers that discards expired identifiers would miss this one.

    AL-MAKANSI, Amir

    • AKA: MAKANSI, Amir
    • Addresses:
      • Turkey
      • Syria
    • DOB: 01 Jan 1984
    • POB: Aleppo, Syria
    • nationality: Syria
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: individual
    • Linked to: ZAHER EL DINE, Hamdi

    Supplemental Information: Treasury says that Al-Makansi, acting at the direction of U.S.-designated Hizballah financier Hamdi Zaher El Dine, operates a Syria-based gold exchange company that also has offices in Istanbul. The exchange deals mainly in gold. It also uses Lebanese exchange houses to change currency for Hamdi in large denomination bills that, according to Treasury, the Lebanese exchange sector knows to be frequently sourced to Hizballah. Treasury does not name the gold exchange company, and it is not among the entities designated in this action.

    OFAC designated Al-Makansi under 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, Hamdi. OFAC first designated Hamdi on January 28, 2016, as a Hizballah-affiliated money launderer, together with Mohamad Noureddine. Treasury now describes Hamdi as directing and operating several Lebanese gold and cash exchanges through family members and close associates in order to evade sanctions, without appearing in the legal structure of those exchange houses himself.

    AL-SHAIKHLI, Mohamed Ameen Fadhil Ali

    • Address: Iraq
    • DOB: 03 Mar 1987
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: A5885383 (Iraq) expires 05 Jul 2019
    • Party Type: individual
    • Linked to: KATA’IB HIZBALLAH

    Supplemental Information: Treasury identifies Al-Shaikhli as an active KH member, designated with the other three KH figures for acting for or on behalf of KH. The passport in his listing expired on July 5, 2019. With seven digits after the letter prefix, the number is also one digit shorter than every other Iraqi passport number in this action, and nothing in the release explains the difference.

    AL-TAMEEMI, Abbas Jawad Kadhim

    • AKA:
      • AL-TAMIMI, Abbas Jawad Kazim
      • “GOOGLE, Mahdi”
    • Address: Iraq
    • DOB: 14 Dec 1983
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: A14930282 (Iraq) expires 12 Jan 2027
    • Party Type: individual
    • Linked to: AL-MAKSUSI, Sayyid Salah Mahdi Hantush

    Supplemental Information: Treasury identifies Al-Tameemi as a senior official in the PMC’s Directorate of Technical Equipment, the directorate al-Maksusi heads. He gives the PMC strategic guidance and technical advice on foreign military purchases and is regarded as a defense equipment expert within the PMC and among Iran-aligned militia groups. Treasury says his position and his support services to the PMC enable critical financial and military support to reach the IRGC-QF. OFAC designated him under E.O. 13224, as amended, for materially assisting, sponsoring, or providing support to al-Maksusi.

    His weak alias, “GOOGLE, Mahdi,” deserves attention from anyone whose screening configuration includes weak aliases, since its surname element is also the name of a technology company that turns up constantly in payment and trade text.

    HAMIEH, Abdallah

    • AKA:
      • HAMEYE, Abdallah
      • HAMIYAH, Abdallah
    • Address: Shamstar, Baalbek and Hermel, Lebanon
    • DOB: 27 Oct 1983
    • nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: RL1347720 (Lebanon) expires 22 Jul 2013
    • National ID No.: 000038207763 (Lebanon)
    • Party Type: individual
    • Linked to: HIZBALLAH

    Supplemental Information: Treasury says the IRGC-QF uses front companies to move funds from Iranian oil sales to exchange houses in the region. IRGC-QF members in Lebanon then work with Hizballah financial officials to receive the money in Lebanon through several Lebanese money exchangers, including Hamieh and Hussein Ibrahim, and U.S.-designated Mohamad Noureddine has also been involved in these transfers. Treasury calls this group of businessmen and money changers a significant channel for moving money from the IRGC-QF to Hizballah.

    According to Treasury, Hamieh and Ibrahim transferred hundreds of millions of dollars from the IRGC-QF to Hizballah between May and September 2025. Hizballah uses the money to buy weapons, manufacture equipment and pay its members’ salaries. OFAC designated Hamieh under 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, Hizballah.

    The Lebanese passport in his listing expired on July 22, 2013, which makes the national ID number the more useful identifier.

    IBRAHIM, Hussein

    • Address: Baalbek-Hermel Province, Lebanon
    • DOB: 08 May 1986
    • POB: Nabi Chit, Lebanon
    • nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: LR3713545 (Lebanon) expires 27 Sep 2033
    • National ID No.: 000033040500 (Lebanon)
    • Party Type: individual
    • Linked to: HIZBALLAH

    Supplemental Information: Ibrahim is the second of the two money exchangers Treasury names in the channel carrying IRGC-QF money to Hizballah, and OFAC designated him on the same material support basis as Hamieh.

    His listing has no aliases, and Hussein Ibrahim is a very common name combination across the Arabic-speaking world. Screening teams should expect false positive volume on this one and lean on his date and place of birth, passport and national ID number to resolve alerts.

    WEHBE, Ghaith Hussein

    • AKA:
      • WAHIBI, Ghayth Husayn
      • “WARTH”
    • Address: Lebanon
    • DOB: 17 Dec 1985
    • nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • National ID No.: 000025122133 (Lebanon)
    • Party Type: individual
    • Linked to: HIZBALLAH

    Supplemental Information: Treasury describes Wehbe as a Hizballah money courier. Once IRGC-QF money reached Lebanon, U.S.-designated Hizballah member Ossama Jaber worked with Wehbe to collect it in person from the cash exchangers on behalf of Hizballah financial officials. OFAC designated Wehbe under E.O. 13224, as amended, for material support to Hizballah.

    His listing carries no passport, which leaves the Lebanese national ID number as its only document identifier.

    ZAHRELDINE, Mervat Jamil

    • AKA:
      • ZAHR EDDINE, Mirvat
      • ZAHREDDINE, Marwa Jamil
      • ZAHREDDINE, Mervat Jamil
    • Address: Airport Road Karim Bldg. 7th Floor, Ghobeiry, Baabda, Lebanon
    • DOB: 01 Jan 1991
    • nationality: Lebanon
    • Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: RL2779753 (Lebanon)
    • Party Type: individual
    • Linked to: ZAHER EL DINE, Hamdi

    Supplemental Information: Treasury identifies Zahreldine as Hamdi Zaher El Dine’s sister. She works on his behalf at two of the exchange houses he directs, holding a position at Yousef Ibrahim Mansour and Partner for Exchange (YIM Exchange) and power of attorney at Gold Pro SARL, both designated in this action. OFAC designated her under E.O. 13224, as amended, for material support to Hamdi.

    The family name appears in at least five romanizations in this action alone: Zaher El Dine in the Linked To fields, Zahreldine, Zahr Eddine and Zahreddine in her own listing, and Zaher El Din in the Gold Pro address. Her aliases also include Marwa, a different given name from Mervat and Mirvat, so name matching tuned only to her primary name is likely to miss variants.

    OFAC Program: [IRAN-EO13902]  Executive Order 13902

    AL-MANDALAWI, Abdulhasan Ali Akbar Namdar

    • AKA:
      • NAMDAR, Abdulhasan
      • NAMDAR, Abdulhasan Ali Akbar
    • Address: Dubai, United Arab Emirates
    • DOB: 08 Jul 1965
    • alt. DOB: 1978
    • nationality: Iraq
    • alt. nationality: Canada
    • Gender: Male
    • Passport: A17942936 (Iraq) expires 14 Feb 2029
    • alt. Passport: HN146500 (Canada) expires 25 Oct 2026
    • Party Type: individual
    • Linked to: SHAMS AND BAHR TRADING COMPANY L.L.C.

    Supplemental Information: Treasury says Shams & Bahr Trading Company, a Dubai-based hawala, is also owned by Abdulhasan, whom the release names as Abdulhasan Ali A. Namdar Al-Mandalawi. OFAC designated him under E.O. 13902 for having acted or purported to act for or on behalf of, directly or indirectly, Shams & Bahr.

    His listing carries two dates of birth 13 years apart, and an alternative Canadian nationality backed by a Canadian passport that expires on October 25, 2026. That passport gives this listing a Canadian connection that no other listing in this action has.

    AL-MANDALAWI, Majid Ali Akbar Namdar

    • AKA: AL-KURDI, Majid ‘Ali Akbar
    • Address: Dubai, United Arab Emirates
    • DOB: 20 Jul 1972
    • nationality: Iraq
    • alt. nationality: Turkey
    • Gender: Male
    • Passport: U22423385 (Turkey) expires 04 Oct 2029
    • alt. Passport: B08552683 (Iraq) expires 14 Feb 2032
    • Party Type: individual
    • Linked to: SHAMS AND BAHR TRADING COMPANY L.L.C.

    Supplemental Information: Treasury says Majid Al-Mandalawi uses a variety of Iraqi private banks to move funds through his hawala, Shams & Bahr, a Dubai-based exchange that has been used to send millions of dollars from Iraq to Iran by way of the UAE. OFAC designated him under E.O. 13902 on the same basis as Abdulhasan, for acting for or on behalf of Shams & Bahr. His primary listed passport is Turkish, with an Iraqi passport as the alternate.

    The two Al-Mandalawi listings share the name elements Ali Akbar Namdar, and Treasury ties both men to Shams & Bahr. Neither the release nor the listings state a family relationship between them.

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

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

    AIN AL IRAQ FOR PROTECTION SYSTEMS TECHNOLOGY AND AUDIO, VISUAL, AND COMMUNICATIONS SOLUTIONS COMPANY LTD

    • AKA:
      • AYN AL-IRAQ COMPANY
      • EIN AL-IRAQ COMPANY
      • EYE OF IRAQ COMPANY
    • Address: Baghdad, Iraq
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 12 Apr 2010
    • Company Number: 48457 (Iraq)
    • Registration Number: 75493 (Iraq)
    • Linked to: AL-MAKSUSI, Sayyid Salah Mahdi Hantush

    Supplemental Information: Treasury describes Ain Al-Iraq as a PMC-affiliated procurement company that has supported the PMC as well as IRGC-QF-controlled networks and affiliated individuals in Iraq. According to Treasury, the Iraqi government has used the company in dealings among Iraq, Russia, Iran and China to acquire defense components, dealings that formed part of larger public corruption and sanctions evasion schemes in Iraq. The company has also been used, through its sanctions evasion networks, in an attempted purchase of U.S. defense articles. OFAC designated Ain Al-Iraq under E.O. 13224, as amended, for material support to al-Maksusi.

    The release renders the name as Ain Al-Iraq For Protecting Technology and Audio, Visual, and Communications Solutions Company Ltd, which replaces “Protection Systems” with “Protecting” and so does not match the listed primary name. “Ain” means eye in Arabic, which accounts for the EYE OF IRAQ alias.

    AL BROUJ FOR GENERAL CONTRACTING COMPANY

    • AKA: AL-BROJ COMPANY FOR CONTRACTING, GENERAL TRADING, TRANSPORTATION LTD
    • Address: Baghdad, Iraq
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Company Number: 3219747 (Iraq)
    • Linked to: AL AMERI, Abdullah Nadhim Luaibi

    Supplemental Information: Al-Brouj is Al Ameri’s Iraq-based company, through which Treasury says he supplies goods and services to the PMC, including likely unlawful procurement of equipment with military applications, and maintains Russian-provided helicopters for Iraqi military organizations operating under IRGC-QF direction. OFAC designated Al-Brouj under E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Al Ameri.

    The release uses the name Al-Brouj For General Contracting Company Ltd. The listed primary name omits “Ltd,” and the alias spells the name Al-Broj.

    GOLD PRO SARL

    • Address: Zaher El Din Property, Downtown Port, Beirut, Lebanon
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.
    • Identification Number: 45432 (Lebanon)
    • Linked to: ZAHER EL DINE, Hamdi

    Supplemental Information: Mervat Jamil Zahreldine holds power of attorney at Gold Pro on behalf of her brother, Hamdi Zaher El Dine. Treasury notes that Gold Pro is not licensed by the Central Bank of Lebanon to import gold, and says Hamdi uses hawalas to buy gold in Dubai and couriers to carry it into Lebanon. OFAC designated Gold Pro under E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Hamdi. The company’s listed address, Zaher El Din Property, carries a form of the family’s name.

    The Gold Pro and YIM Exchange listings carry only the E.O. 13224 section 1(b) secondary sanctions risk line. They lack the Additional Sanctions Information line referencing the Hizballah Financial Sanctions Regulations, which appears on Al-Makansi and Zahreldine, who are linked to the same person, and on the three individuals linked directly to Hizballah. The release does not explain the difference, so the presence or absence of that line should not be treated as a reliable marker of Hizballah exposure.

    YOUSEF IBRAHIM MANSOUR AND PARTNER FOR EXCHANGE

    • AKA:
      • YOUSSEF IBRAHIM MANSOUR AND CO. FOR EXCHANGE
      • YOUSSEF IBRAHIM MANSOUR FOR EXCHANGE
      • “YIM EXCHANGE”
    • Addresses:
      • Shtaura, Bekaa, Lebanon
      • Zahle, Lebanon
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 08 May 2006
    • Organization Type: Other monetary intermediation
    • Commercial Registry Number: 4000751 (Lebanon)
    • Linked to: ZAHER EL DINE, Hamdi

    Supplemental Information: Zahreldine holds a position at YIM Exchange on her brother’s behalf. Treasury says Hamdi directs family members who either work in, or are part of the legal structure of, several Lebanese exchange houses, while staying out of that legal structure himself. OFAC designated YIM Exchange under E.O. 13224, as amended, on the same owned, controlled or directed by basis as Gold Pro.

    The release refers to the company only by its weak alias, YIM Exchange. The primary name spells the given name Yousef, while both strong aliases use Youssef.

    OFAC Program: [IRAN-EO13902]  Executive Order 13902

    SHAMS AND BAHR TRADING COMPANY L.L.C.

    • AKA:
      • SHAMS & BAHR TRADING COMPANY L.L.C.
      • SHAMS AND BAHIR
      • SHAMS WA BAHR
      • SUN & SEA GENERAL TRADING CO LLC
      • SUN SEA GENERAL TRADING LLC
      • “SON AND SEA COMPANY”
    • Addresses:
      • PO Box 81033, Al Riqa Street, 3, Dubai, United Arab Emirates
      • 69, Al Rigga Rd, Al Muraqqabat, Deira, Dubai, United Arab Emirates
      • Exhibition No 3, Al Muraqqabat, Deira, Dubai, United Arab Emirates
    • Website: http://www.shamsandbahr.ae
    • alt. Website: http://www.shamsbahr.com
    • Organization Established Date: 19 Mar 2001
    • Organization Type: Other monetary intermediation
    • Commercial Registry Number: 56218 (United Arab Emirates)
    • Business Registration Number: 524921 (United Arab Emirates)

    Supplemental Information: Treasury describes Shams & Bahr as a Dubai-based exchange that Majid Al-Mandalawi operates as a hawala, moving money through a variety of Iraqi private banks, and says it has been used to remit millions of dollars from Iraq to Iran by way of the UAE. The company is also owned by Abdulhasan Al-Mandalawi. OFAC designated it under E.O. 13902 for operating in the financial sector of the Iranian economy.

    The release includes a short explainer on hawala, which Treasury describes as an informal value transfer system that operates outside the regulated financial sector and relies on trust, personal relationships and longstanding community networks. Hawala is not inherently illicit. Treasury notes, however, that it appeals to people trying to evade sanctions because transactions often take place without the true names of the sender or recipient, do not pass through traditional banking networks, and may involve little or no recordkeeping.

    Shams wa bahr means “sun and sea” in Arabic, which accounts for the SUN & SEA and SUN SEA aliases. The weak alias “SON AND SEA COMPANY” looks like a phonetic misrendering of the same name, and Al Riqa Street and Al Rigga Rd in the first two addresses appear to be two romanizations of the same Dubai street.

    Sources

    , , ,
  • UK Gov logo, 50% resolution.png

    Yesterday, September 8th, the Iran (Sanctions) (Amendment) Regulations 2026 (The Iran (Sanctions) (Amendment) Regulations 2026) was laid in Parliament.

    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.

    Key resources relating to the new legislation:

    The Ministerial Statement:

    Written statement to Parliament

    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

    Stephen Doughty MP

    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.

  • Iran-related Designations; Counter Terrorism Designations; Updates to Iran-related General Licenses; Issuance of Counter Terrorism General License

    Treasury Press Release: Treasury Grounds Iranian Airlines with Sweeping Sanctions Action

    State Press Release: Operation Economic Outcast Grounds Iran’s Aviation Sector

    Additions:

    The following individual has been added to OFAC’s SDN List:

    • OFAC Programs:
      • [SDGT]  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
      • [IFSR]  Iranian Financial Sanctions Regulations, 31 CFR part 561

    MAHRAN, Ibrahim Ali Mohamed Mohamed

    • AKA: IBRAHIM, Mahran
    • Address: United Arab Emirates
    • DOB: 01 Mar 1986
    • POB: Menia, Egypt
    • Nationality: Egypt
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: A28699752 (Egypt) expires 15 Aug 2028
    • Party Type: Individual
    • Linked to: ECT AVIATION SUPPORT LLC

    Supplemental Information: A UAE-based Egyptian national, Mahran is the chief executive officer, managing director, founder and owner of UAE-based ECT Aviation Support LLC, and has been the director of UK-based ECT Aviation Support LTD since that company was formed. Treasury designated him under E.O. 13224, as amended, for being a leader or official of ECT Aviation Support LLC.

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

    • OFAC Programs:
      • [SDGT]  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
      • [IFSR]  Iranian Financial Sanctions Regulations, 31 CFR part 561

    AEROBRAVO AIRPLANE MANAGEMENT AND OPERATION LLC

    • Address: Dubai, United Arab Emirates
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 22 Nov 2022
    • Commercial Registry Number: 1879178 (United Arab Emirates)
    • License: 1108996 (United Arab Emirates)
    • Chamber of Commerce Number: 430703 (United Arab Emirates)
    • Linked to: ECT AVIATION SUPPORT LLC

    Supplemental Information: Aerobravo has acted as the operator for aircraft owned by ECT Aviation Support LLC. Treasury designated it under 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, ECT Aviation Support LLC.

    ECT AVIATION SUPPORT LLC

    • Address: Sharjah, United Arab Emirates
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 30 May 2019
    • License: 1906247 (United Arab Emirates)
    • Registration Number: 11599882 (United Arab Emirates)
    • Linked to: MAHAN AIR

    Supplemental Information: In summer 2026, Mahan Air took delivery of at least three B-777 aircraft that were diverted through the United Arab Emirates and Oman. Each aircraft came out of a retired fleet and then passed through ECT Aviation Support LLC, where it received a temporary registration, on a route that closely tracked earlier Mahan Air sanctions evasion operations. The company is owned by Ibrahim Ali Mohamed Mohamed Mahran, who also serves as its chief executive officer, managing director and founder. Treasury designated it under 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, Mahan Air.

    ECT AVIATION SUPPORT LTD

    • Address: 115 London Road, Morden, London SM4 5HP, United Kingdom
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 21 Feb 2024
    • Company Number: 15510916 (United Kingdom)
    • Linked to: MAHRAN, Ibrahim Ali Mohamed Mohamed

    Supplemental Information: The UK arm of the ECT Aviation Support group is wholly owned by UAE-based ECT Aviation Support LLC, which in turn is owned by Mahran. Mahran has served as its director since the company was established. Treasury designated it under E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mahran.

    ICARGO SDN BHD

    • AKA: SCHEDULE FEEDERS SDN BHD
    • Addresses:
      • 9-7 Level 7, Jalan USJ 9/5Q, Subang Business Centre, Subang Jaya, Selangor 47620, Malaysia
      • Lot 202-3, 2nd Floor, Customer Services Centre, Klas Cargo Complex, Kuala Lumpur International Airport, Kampung Kota Klias, Selangor 64000, Malaysia
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 04 Mar 2011
    • Registration Number: 201101006881 (Malaysia)
    • Linked to: MAHAN AIR

    Supplemental Information: Icargo has served as a general sales agent for Mahan Air and has coordinated the shipment of U.S.-origin parts to Iran on the airline’s behalf. Treasury designated it under 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, Mahan Air.

    MES CARGO TRANSPORTATION TOURISM AND FOREIGN TRADE LIMITED COMPANY

    • AKA:
      • MEHMET SARP CARGO
      • MES KARGO TASIMACILIK TURIZM VE DIS TICARET LIMITED SIRKETI
    • Latin Script Name: MES KARGO TAŞIMACILIK TURİZM VE DIŞ TİCARET LİMİTED ŞİRKETİ
    • Address: Hera Clup A Blok K:3, Ozdemir Sokak No:45-46, Ataturk Mahallesi, Esenyurt, Istanbul 34522, Turkey
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 25 Aug 2003
    • Chamber of Commerce Number: 503896 (Turkey)
    • Central Registration System Number: 0619038513700014 (Turkey)
    • Linked to: MAHAN AIR

    Supplemental Information: The Türkiye-based company serves as a general sales agent for Mahan Air and has coordinated shipments on the airline’s behalf. Treasury designated it under 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, Mahan Air.

    S SISTEM LOJISTIK HIZMETLER ANONIM SIRKETI

    • AKA: S SISTEM LOGISTICS SERVICES JOINT STOCK COMPANY
    • Latin Script Name: S SİSTEM LOJİSTİK HİZMETLERİ ANONİM ŞİRKETİ
    • Address: Nuri Demirag Caddesi No 49, Yenikoy Mahallesi, Turkoba, Istanbul 34277, Turkey
    • Website: https://www.ssistem.com
    • alt. Website: http://www.ssistem.com.tr
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 1984
    • Tax ID No.: 7730026303 (Turkey)
    • Registration Number: 203409-0 (Turkey)
    • Linked to: MAHAN AIR

    Supplemental Information: The Türkiye-based logistics company has coordinated shipments on behalf of Mahan Air, including unmanned aerial vehicle components and industrial equipment destined for Iran. Treasury designated it under 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, Mahan Air.

    SKY PHOENIX HAVA YOLLARI TASIMACILIGI TICARET LIMITED SIRKETI

    • AKA: SKY PHOENIX AIRWAYS TRANSPORTATION TRADING COMPANY LIMITED
    • Latin Script Name: SKY PHOENIX HAVA YOLLARI TAŞIMACILIĞI TİCARET LİMİTED ŞİRKETİ
    • Address: Izmir, Izmir, Turkey
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 29 Jul 2024
    • Tax ID No.: 7721674192 (Turkey)
    • Business Registration Number: 257494 (Turkey)
    • Registration Number: 2307531 (Turkey)
    • Linked to: MAHAN AIR

    Supplemental Information: Sky Phoenix acted alongside ECT Aviation Support LLC as an intermediary in the scheme that transferred at least three U.S.-origin B-777 aircraft to Mahan Air through the United Arab Emirates and Oman in summer 2026. Treasury designated it under 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, Mahan Air.

    TOUR INVEST LLC

    • AKA:
      • LIMITED LIABILITY COMPANY TOUR INVEST
      • TOUR INVEST TOO
      • TUR INVEST TOO
    • Address: 128, Kv. 1, Ulitsa Makataeva, Almaty, Almaty, Kazakhstan
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 18 Mar 2014
    • Government Gazette Number: 52557574 (Kazakhstan)
    • Business Number: 140340016400 (Kazakhstan)
    • Linked to: MAHAN AIR

    Supplemental Information: The Kazakhstan-based company has served as a general sales agent for Mahan Air. Treasury designated it under 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, Mahan Air.

    • OFAC Programs:
      • [IFSR]  Iranian Financial Sanctions Regulations, 31 CFR part 561
      • [IRAN-EO13902]  Executive Order 13902

    AIR SHIRAZ

    • Address: Shiraz, Iran
    • Website: https://airshiraz.com/
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2025
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    ASA JET AIRLINE

    • Address: Tehran, Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2022
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    ATA AIRLINES COMPANY

    • Addresses:
      • No. 8, Corner of Yas Alley, Shahid Nafisi Boulevard, Ekbatan, Shahrak, Tehran, Iran
      • Armin Building, Uphill from Negin Park, Golpark Square, North Tavanir Street, Tabriz, Iran
    • Website: http://www.ataair.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 17 Dec 2008
    • Organization Type: Passenger air transport
    • National ID No.: 10200336102 (Iran)
    • Registration Number: 25533 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    ATLAS AVIATION GROUP

    • AKA: ATLAS AIR PLUS
    • Address: Kish, Iran
    • Website: atlasairplus.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 1995
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    AVA AIRLINES

    • Address: Tehran, Iran
    • Website: https://avaair.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2024
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    CHABAHAR AIRLINES COMPANY

    • AKA:
      • CHABAHAR AIR
      • CHABAHAR AIRLINES
      • CHABAHAR AVIATION COMPANY
    • Address: Tis Complex Booth 214, Vahdat Street, North Vahdt Street, Azad Zone Neighborhood, Chabahar 9971766162, Iran
    • Website: http://www.chabaharairlines.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 1999
    • Organization Type: Passenger air transport
    • Registration Number: 478 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    ERWAN AIRLINE COMPANY

    • AKA:
      • AIR1AIR COMPANY
      • ARVAN AIRLINES
      • ERWAN AIRLINES
      • “AIR1”
    • Address: Shahid Lashkari Highway Bypass, Meraj Building, Azadi Square, Special Road, Shahid Filasfi, Tehran, Iran
    • Website: http://www.air1air.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2018
    • Organization Type: Passenger air transport
    • Registration Number: 48074 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    FLY KISH AIRLINES

    • Address: Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2024
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    FLY PERSIA AIRLINES

    • AKA:
      • FLY PERSIA
      • FLY PERSIA PRIVATE DANA AIRLINES
      • FLY PERSIA PRIVATE JOINT STOCK COMPANY
    • Address: Shahid Sattari Expressway, Flypersia Building No. 2, South Parvaneh Street, West Ferdows Boulevard, Tehran, Iran
    • Website: http://www.flypersia.aero
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2018
    • Organization Type: Passenger air transport
    • Registration Number: 47349 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    IRAN AIR TOUR

    • AKA:
      • IRAN AIR TOURS COMPANY
      • IRAN AIRTOUR AIRLINE
      • IRAN AIRTOUR AIRLINES
    • Addresses:
      • Tehran, Iran
      • Mashhad, Iran
      • Tabriz, Iran
    • Website: http://www.iranairtour.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 1972
    • Organization Type: Passenger air transport
    • National ID No.: 10100596646 (Iran)
    • Registration Number: 16691 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector. The carrier was founded as a subsidiary of Iran Air, itself an SDN since November 2018, and was put through Iran’s Article 44 privatization program in 2011. Published accounts disagree on whether Iran Air retained an ownership interest afterward, so screening teams evaluating 50 Percent Rule exposure should not assume the parent link was severed. Note also that OFAC’s entry gives an establishment date of 1972, while industry sources generally give 1973.

    IRAN ASEMAN AIRLINES

    • AKA: ASEMAN AIR SERVICES
    • Address: Ground Floor, No. 0, Airport Road, Amir Sarlashghar Shahid Hossein Lashgari Highway, Airport, Central District, Tehran, Tehran 1387833731, Iran
    • Website: http://www.iaa.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 10 Apr 1980
    • Organization Type: Passenger air transport
    • National ID No.: 10100871720 (Iran)
    • Registration ID: 41798 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    JSKY AIRLINES

    • AKA: “J SKY”
    • Addresses:
      • Tehran, Iran
      • Isfahan, Iran
    • Website: jskyair.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2019
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    KARUN AIRLINES COMPANY

    • AKA: KAROON AIRLINES
    • Addresses:
      • Shahid Nafisi Boulevard, No. 11, Shahrak, Ekbatan Phase 1, Tehran, Iran
      • Unit 1, First Floor, No. 11, Abdolrahman Nafisi Street, Second Alley, Bimeh, Tehran 1393784181, Iran
    • Website: http://www.karunair.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 14 Mar 1993
    • Organization Type: Passenger air transport
    • National ID No.: 10101402182 (Iran)
    • Registration ID: 96157 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    KISH AIRLINES

    • AKA: KISH AIR
    • Addresses:
      • Kish Air Central Building, First Floor, Ekbatan Town, Phase I, Shahid Nafisi Boulevard, Tehran 1393853113, Iran
      • Kish Island, Hormozgan, Iran
    • Website: http://www.kishairlines.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 1989
    • Organization Type: Passenger air transport
    • National ID No.: 10861524973 (Iran)
    • Registration Number: 854 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    LAD AIRWAYS

    • AKA: LAD AIRLINE SERVICES
    • Address: Iran
    • Website: ladairways.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2024
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    MEHR AIRWAYS

    • Address: Tehran, Iran
    • Website: mehrairways.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2025
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    NASIM AIR

    • Address: Esfahan, Iran
    • Website: nasimairlines.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2015
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    PARS OGHYANOUS KISH COMPANY

    • AKA:
      • PARS AIR
      • PARS AIRLINES
    • Address: Meraj Education Center Building, Azadi Square, Karaj Special Road, Corner of Philosophical Street, Tehran 557111397, Iran
    • Website: http://www.parsair.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2017
    • Organization Type: Passenger air transport
    • Registration Number: 12386 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    QESHM AIR

    • AKA:
      • QESHM AIR AIRLINE
      • QESHM AIRLINES
      • “QESHM AVIATION COMPANY”
    • Address: No. 12 Riahi Avenue, Shahid Lashkari Highway, Tehran 1245659878, Iran
    • Website: http://www.qeshm-air.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 1993
    • Organization Type: Passenger air transport
    • National ID No.: 10800049144 (Iran)
    • Registration Number: 494 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector. Screening teams should keep this entry distinct from Qeshm Fars Air, a separate cargo carrier that OFAC designated in January 2019 as owned or controlled by Mahan Air and for supporting the IRGC-Qods Force. The two names are close enough to generate matches against each other.

    RAIMON AIRWAYS

    • Address: Tehran, Iran
    • Website: raimonair.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2025
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    SAHA AIRLINES

    • AKA:
      • ARMED FORCES AIR TRANSPORT SERVICE
      • SAHA AIRLINES PJSC
      • SERVICE ERTEBAATAAT-E HAVAAEE ARTESH
    • Address: Tehran, Iran
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 01 Jan 1989
    • Organization Type: Passenger air transport
    • alt. Organization Type: Freight air transport
    • Registration Number: 6327 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector. Saha is the one carrier in this group whose military ownership is visible on the face of the SDN entry: its alternate names translate to the armed forces’ air transport service, and public reporting describes it as wholly owned by the Islamic Republic of Iran Air Force. The EU and Switzerland listed it in October 2024 over the transfer of Iranian-made unmanned aerial vehicles and related technology to Russia.

    SEPEHRAN AIRLINES

    • AKA: FLYSEPEHRAN
    • Addresses:
      • Shiraz, Iran
      • No. 71, Corner of Shahid Khadem Alley, Nafisi Blvd, Ekbatan, Tehran, Iran
    • Website: http://www.sepehranairlines.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2015
    • Organization Type: Passenger air transport
    • National ID No.: 10320623230 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    SOROUSH AIR

    • Address: Tehran, Iran
    • Website: soroushair.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2025
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    TABAN AIRLINES

    • Address: Tehran, Iran
    • Website: taban.aero
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2005
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    TOOS AIRLINES

    • AKA:
      • TOOS AIRLINE
      • TOOS PARSIAN KISH AIRLINES COMPANY
    • Addresses:
      • Mashhad, Iran
      • Kish, Iran
      • Tehran, Iran
    • Website: toosairline.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2020
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    VARESH AIRLINES

    • Addresses:
      • Sari, Iran
      • Tehran, Iran
    • Website: vareshairline.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2018
    • Organization Type: Passenger air transport

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    ZAGROS AIRLINES

    • AKA: ZAGROS AIRLINE CO
    • Addresses:
      • No. 1, Zagros Airlines Building, Third Alley, Riahi St, Karaj Special Road, Tehran 1391713415, Iran
      • Abadan, Iran
    • Website: http://www.zagrosairlines.com
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 28 Aug 2005
    • Organization Type: Passenger air transport
    • National ID No.: 10861921581 (Iran)
    • Registration Number: 1008 (Iran)

    Supplemental Information: Named by Treasury among the 27 Iranian airlines designated under E.O. 13902 for operating in the aviation sector of the Iranian economy, following OFAC’s August 24, 2026 determination that E.O. 13902 applies to that sector.

    Sources

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  • The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is implementing the following actions with regard to its Iran sanctions programs:

    Counter-Terrorism GL 37:

    The Suspension Notice:

    Iran GL J-1:

    Iran GL DD:

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  • U.S. Sanctions Dismantle the Iranian Regime’s Revenue Streams

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, SPOKESMAN
    OFFICE OF THE SPOKESPERSON

    SEPTEMBER 4, 2026

    The United States remains committed to cutting off the Iranian regime’s access to the international financial system and the resources it uses to destabilize the region and threaten U.S. interests and partners. Today’s U.S. Department of the Treasury sanctions on Türkiye-based Golden Global Bank mark the latest step in Operation Economic Outcast, a whole-of-government effort to sever the networks that allow the regime to launder funds, evade sanctions, and finance its terrorist proxies across the Middle East.

    This action sends a clear message to financial institutions worldwide: facilitating Iran’s illicit financial activity carries serious consequences. This demonstrates the Trump Administration’s commitment to eliminating resources the regime uses to threaten regional stability, support terrorism, and advance its military capabilities.

    The United States will continue to use every diplomatic and economic tool at its disposal to isolate the Iranian regime until it abandons its support for terrorism and its destabilizing activities in the region. We urge the international community to join this effort and ensure no institution serves as a financial lifeline for a regime that threatens peace and security.

    Today’s action is being taken pursuant to Executive Order (E.O.) 13902, which targets the financial sector of Iran’s economy and advances Operation Economic Outcast—a campaign to completely isolate the regime from the financial lifelines that sustain its malign behavior. Please see the Department of the Treasury’s Press Release.

  • Iran-related Designations; Issuance of Iran-related General License

    Treasury Press Release: Treasury Severs Iranian Regime’s Financial Lifelines in Türkiye

    Additions:

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

    OFAC Program: [IRAN-EO13902]  Executive Order 13902

    GOLDEN GLOBAL PORTFOY YONETIMI ANONIM SIRKETI (Latin: GOLDEN GLOBAL PORTFÖY YÖNETİMİ ANONİM ŞİRKETİ)

    • Address: Astoria D:21, N: 127A Esentepe Mahallesi, Buyukdere Caddesi, Sisli, Istanbul, Turkey
    • Website: https://goldenglobalportfoy.com.tr/
    • Organization Established Date: 15 Jan 2025
    • Organization Type: Financial and Insurance Activities
    • Tax ID No.: 3961688364 (Turkey)
    • Legal Entity Number: 789000J1YGZ3PLCXMQ38
    • Registration Number: 1063899 (Turkey)
    • Linked to: GOLDEN GLOBAL YATIRIM BANKASI ANONIM SIRKETI

    Supplemental Information: Treasury designated this entity, a subsidiary of Golden Global Bank, for being owned or controlled by, or having acted or purported to act for or on behalf of, the bank. Treasury’s press release ties Golden Global Bank to a scheme enabling Iran’s “rahbar” network to move oil revenue earned from sales to China into Turkey, where it could then be converted to cash and gold by rahbar money exchangers.

    GOLDEN GLOBAL VARLIK KIRALAMA ANONIM SIRKETI (Latin: GOLDEN GLOBAL VARLIK KİRALAMA ANONİM ŞİRKETİ)

    • Address: Astoria Blok IC Kapi No 17, N: 127 B-17 Esentepe Mahallesi, Buyukdere Caddesi, Sisli, Istanbul, Turkey
    • Website: https://goldenglobalvks.com.tr/
    • Organization Established Date: 01 Aug 2022
    • Organization Type: Financial and Insurance Activities
    • Tax ID No.: 3961486674 (Turkey)
    • Legal Entity Number: 789000S50A0J8E8FKE55
    • Registration Number: 396200 (Turkey)
    • Linked to: GOLDEN GLOBAL YATIRIM BANKASI ANONIM SIRKETI

    Supplemental Information: Treasury designated this entity, a subsidiary of Golden Global Bank, for being owned or controlled by, or having acted or purported to act for or on behalf of, the bank. Treasury’s press release ties Golden Global Bank to a scheme enabling Iran’s “rahbar” network to move oil revenue earned from sales to China into Turkey, where it could then be converted to cash and gold by rahbar money exchangers.

    GOLDEN GLOBAL YATIRIM BANKASI ANONIM SIRKETI (Latin: GOLDEN GLOBAL YATIRIM BANKASI ANONİM ŞİRKETİ)

    • AKA: GOLDEN GLOBAL INVESTMENT BANK
    • Address: N:127 B-17 Esentepe Mahallesi, Buyukdere Caddesi, Sisli, Istanbul 34394, Turkey
    • SWIFT/BIC: GOGYTRIS
    • Website: http://www.goldenglobalbank.com.tr
    • Organization Established Date: 15 Oct 2019
    • Target Type: Financial Institution
    • Tax ID No.: 3961233191 (Turkey)
    • Legal Entity Number: 789000LV7F75LALJ3F52
    • Registration Number: 213202 (Turkey)

    Supplemental Information: Treasury’s press release describes Golden Global Bank as a Turkish financial institution established to give Iran’s “rahbar” network of oil-revenue facilitators a route to convert oil proceeds from Chinese buyers into cash and gold once the funds reached Turkey. The bank knowingly offered correspondent banking services to Iranian financial institutions, letting transactions flow through accounts controlled by the IRGC-Qods Force and its proxies, including accounts tied to Turkish businessman Sitki Ayan and his companies – a network OFAC designated in 2022 for moving hundreds of millions of dollars connected to IRGC-Qods Force oil sales. Treasury says the bank facilitated tens of millions of dollars in transactions for the IRGC-Qods Force and gave the Iranian regime correspondent banking access it used to move funds internationally. The designation is part of Operation Economic Outcast, the sanctions campaign Secretary Bessent announced on August 24, 2026 to sever Iran’s remaining economic lifelines and that Treasury says will keep expanding secondary sanctions exposure for those still doing business with the regime.

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