Notice of Changes to the Consolidated List – 6 June 2026
DFAT updated the Consolidated List on 6 June 2026 to reflect the following changes:
- The addition of three persons subject to targeted financial sanctions as per the Charter of the United Nations (Listed Persons and Entities) Amendment (No. 2) Instrument 2026.
The updated Consolidated List can be downloaded from the following page: Consolidated List | Australian Government Department of Foreign Affairs and Trade.
Guidance on how to interpret the Consolidated List can be found here: Guide to Australia’s Consolidated List | Australian Government Department of Foreign Affairs and Trade
If you have any queries, please contact the Australian Sanctions Office atsanctions@dfat.gov.au.
Australian Sanctions Office
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Australian Sanctions Office | Regulatory and Legal Policy Division
Department of Foreign Affairs and Trade
Category: Terrorism
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Iran-related Designations; Counter Terrorism Designations Updates
Treasury Press Release: Economic Fury Targets Iranian LPG Smuggling and Shadow Banking Networks
State Press Release: Sanctions to Strangle Iran’s Energy Smuggling and Illicit Financial Networks
Additions:
The following individuals have been added to OFAC’s SDN List:
OFAC Program: [IRAN-EO13902] Executive Order 13902
GERAMIAN NIK, Mehrdad (Arabic: مهرداد گرامیان نیک)
- AKA: GRAMIAN NIK, Mehrdad
- Address: Tehran, Iran
- DOB: 24 Aug 1964
- POB: Tehran, Iran
- Nationality: Iran
- Alt. nationality: Dominica
- Additional Sanctions Information – Subject to Secondary Sanctions
- Gender: Male
- Passport: V52959771 (Iran)
- Alt. Passport: I73046943 (Iran)
- Alt. Passport: RA051286 (Dominica)
- National ID No.: 0041253825 (Iran)
- Party Type: Individual
- Linked to: MEHRDAD GERAMIAN NIK AND PARTNERS COMPANY
Supplemental Information: Co-operates the family-run exchange house Mehrdad Geramian Nik and Partners Company (Geramian Exchange) alongside Romina Geramian Nik. Geramian Exchange has entered into contracts with sanctioned Iranian banks Bank Tejarat, Bank Mellat, and Bank Pasargad, and over the last several years facilitated transactions moving hundreds of millions of dollars in foreign currency on behalf of those banks. As of early 2026, Geramian Exchange held tens of millions of dollars’ worth of foreign currency on behalf of its sanctioned Iranian bank customers. Like many of his peers, Mehrdad Geramian Nik maintains foreign citizenship in Dominica, reportedly obtained through a citizenship-by-investment program, which enables Iran’s shadow banking actors to travel overseas, establish new companies, and access international banking networks.
GERAMIAN NIK, Romina (Arabic: رومینا گرامیان نیک)
- AKA: GRAMIAN NIK, Rumina
- Address: Tehran, Iran
- DOB: 09 May 1989
- POB: Shemiran, Iran
- Nationality: Iran
- Additional Sanctions Information – Subject to Secondary Sanctions
- Gender: Female
- National ID No.: 0440054621 (Iran)
- Party Type: Individual
- Linked to: MEHRDAD GERAMIAN NIK AND PARTNERS COMPANY
Supplemental Information: Co-operates the family-run Geramian Exchange alongside Mehrdad Geramian Nik.
MIHANDOUST, Mohammad Shakol
- AKA:
- SHAKOOR, Haji Muhammad
- SHAKOOR, Muhammad
- Addresses:
- United Arab Emirates
- Turkey
- DOB: 24 Nov 1982
- POB: Chabar, Iran
- Nationality: Turkey
- Gender: Male
- Passport: U23085392 (Turkey) expires 31 Jan 2030
- Alt. Passport: U33171256 (Turkey) expires 20 Feb 2034
- National ID No.: 18986951490 (Turkey)
- Party Type: Individual
Supplemental Information: A Turkish national also known as Haji Shakoor, Mihandoust operates a network of UAE-based front companies (Butani Trading LLC, Dundlod Trading FZE, and ADH Energy FZE) alongside Afghani national Sarbaz Abdul Zada, responsible for exporting millions of barrels of Iranian LPG to end users across South and East Asia, often falsely identifying it as Omani LPG to evade sanctions. Mihandoust owns and operates China-based Shanghai Qianye Energy Co., Ltd. In March 2026, ADH Energy FZE was used to sell and export millions of barrels of Iranian LPG to end users in Bangladesh. Mihandoust and Zada rely on Iran’s shadow fleet of vessels to illicitly transport Iranian LPG to foreign markets.
ZADA, Sarbaz Abdul
- AKA: BIN HAJJI MOLLA NUR, Sarbaz Abdul Zada (Arabic: سرباز عبدل بن حاجي مولانور)
- Address: United Arab Emirates
- DOB: 01 Jan 1977
- Nationality: Afghanistan
- Gender: Male
- National ID No.: 122146116 (United Arab Emirates) expires 16 May 2032
- Identification Number: 784-1977-2690971-2 (United Arab Emirates)
- Party Type: Individual
Supplemental Information: An Afghani national, Zada operates a network of UAE-based front companies alongside Turkish national Mohammad Shakol Mihandoust, responsible for exporting millions of barrels of Iranian LPG to end users in South and East Asia, often falsely labeled as Omani LPG to evade sanctions. Zada has also used UAE-based Sahel Star Oil and Gas Company LLC to ship Iranian LPG. Zada and Mihandoust rely on Iran’s shadow fleet of vessels to illicitly transport Iranian LPG to foreign markets.
The following entities have been added to OFAC’s SDN List:
OFAC Program: [IRAN-EO13902] Executive Order 13902
ADAMAS SHIPPING INC
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 21 Jun 2023
- Identification Number: IMO 6420321
- Business Registration Number: 120582 (Marshall Islands)
Supplemental Information: Owns, manages, and operates the Panama-flagged LPG tanker GAS LAGOON (IMO 9386304), which has transported millions of barrels of Iranian LPG since 2023.
ADH ENERGY FZE
- Address: P5-ELOB, Office No E2-122G-10, Hamriyah Free Zone, Sharjah, United Arab Emirates
- Website: http://www.adhenergyfze.com
- Organization Established Date: 23 Jan 2025
- Business Registration Number: 38672 (United Arab Emirates)
Supplemental Information: A UAE-based front company operating in furtherance of Zada and Mihandoust’s Iranian LPG smuggling scheme. In March 2026, ADH Energy FZE was used to sell and export millions of barrels of Iranian LPG to end users in Bangladesh.
BLACK GOLD TRADE CORPORATION
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 21 Aug 2024
- Identification Number: IMO 0042360
- Business Registration Number: 127595 (Marshall Islands)
Supplemental Information: Owns the Panama-flagged LPG tanker MILE (IMO 8910897), which has transported millions of barrels of Iranian LPG since 2024.
BLUE SEA MARINE INCORPORATED AND FAATEH MARITIME INCORPORATED
- AKA: BLUE SEA MARINE INCORPORATED & FAATEH MARITIME INCORPORATED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 2024
- Identification Number: IMO 0081438
Supplemental Information: Owns, manages, and operates the St. Kitts and Nevis-flagged LPG tanker AMIR GAS (IMO 9167409), which has transported hundreds of thousands of barrels of Iranian LPG since 2025.
BUTANI TRADING LLC
- Address: Office No 481-02-SM1, Port Saeed, Deira, Dubai, United Arab Emirates
- Organization Established Date: 21 Jun 2023
- Commercial Registry Number: 2012881 (United Arab Emirates)
- License: 1201861 (United Arab Emirates)
- Chamber of Commerce Number: 468432 (United Arab Emirates)
Supplemental Information: A UAE-based front company operating in furtherance of Zada and Mihandoust’s scheme. Has shipped tens of thousands of metric tons of Iranian LPG, worth tens of millions of dollars, to South Asia. In early 2025, used the MILE to ship over half a million barrels of Iranian-origin LPG to end users in Bangladesh.
DUNDLOD TRADING FZE
- Address: P6-ELOB, Office No. E2-121 F-55, Hamriyah Free Zone, Sharjah, United Arab Emirates
- Organization Established Date: 06 Jan 2025
- Business Registration Number: 38618 (United Arab Emirates)
Supplemental Information: A UAE-based front company. In October 2025, delivered 22,000 metric tons of LPG to Bangladesh worth approximately $10.5 million USD using the LPG SEVAN. In May 2025, also delivered multiple shipments of LPG to Bangladesh using the GAS ZEINA, which has transported Iranian-origin LPG to Bangladesh since 2024.
ECOSEAS MARITIME LIMITED
- Address: 80 Broad Street, Monrovia, Liberia
- Organization Established Date: 2020
- Identification Number: IMO 6158030
Supplemental Information: Owns the Panama-flagged LPG tanker GLENDALE (IMO 9139945), which has transported millions of barrels of Iranian LPG since 2020.
GAS GMS LIMITED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 31 May 2023
- Identification Number: IMO 6413451
- Business Registration Number: 120290 (Marshall Islands)
Supplemental Information: Owns the Panama-flagged LPG tanker GAZ GMS (IMO 9131539), which has transported hundreds of thousands of barrels of Iranian LPG since 2023.
LIMRA GAS LIMITED
- Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
- Organization Established Date: 11 Apr 2023
- Identification Number: IMO 6400813
- Business Registration Number: 119426 (Marshall Islands)
Supplemental Information: Owns, manages, and operates the Palau-flagged LPG tanker MD 23 (IMO 9158240), which has transported hundreds of thousands of barrels of Iranian LPG since 2023.
MEHRDAD GERAMIAN NIK AND PARTNERS COMPANY (Arabic: شرکت مهرداد گرامیان نیک و شرکا)
- AKA: MEHRDAD GERAMIAN NIK AND PARTNERS EXCHANGE
- Address: No. 25, Ground Floor, Rose Commercial and Administrative Complex, Opposite the Central Bank, Mirdamad Boulevard, Tehran, Tehran, Iran
- Additional Sanctions Information – Subject to Secondary Sanctions
- Organization Established Date: 22 Feb 2011
- National ID No.: 10320482405 (Iran)
- Registration Number: 397342 (Iran)
Supplemental Information: An Iran-based exchange house (Geramian Exchange) that has entered into contracts with sanctioned Iranian banks Bank Tejarat, Bank Mellat, and Bank Pasargad. Over the last several years, facilitated transactions moving hundreds of millions of dollars in foreign currency on behalf of those banks, and as of early 2026 held tens of millions of dollars’ worth of foreign currency on behalf of its sanctioned Iranian bank customers. OFAC has previously taken actions to dismantle Iran’s network of brokers, including against Radin Exchange, Arz Iran Exchange, Opal Exchange, and Amin Exchange. Iran’s foreign exchange system relies heavily on selected brokers and rahbar companies, which use overseas shell and front companies to conceal Iranian connections, bypass sanctions, and move funds through accounts typically held outside Iran.
SAHEL STAR OIL AND GAS COMPANY LLC (Arabic: شركة ساحل ستار للنفط والغاز الطبيعي)
- Address: Office No 3108-3109, Parcel Plot 346-485, Bur Dubai, Dubai, United Arab Emirates
- Organization Established Date: 17 Oct 2021
- License: 993937 (United Arab Emirates)
- Business Registration Number: 11766762 (United Arab Emirates)
- Linked to: ZADA, Sarbaz Abdul
Supplemental Information: A UAE-based company that Sarbaz Abdul Zada has used to ship Iranian LPG.
SHANGHAI QIANYE ENERGY CO., LTD. (Chinese Simplified: 上海千烨能源科技有限公司)
- Address: Room 2701B, No. 99 Xianxia Road, Shanghai 200050, China
- Organization Established Date: 12 Jul 2023
- Commercial Registry Number: 310000401066334 (China)
- Unified Social Credit Code (USCC): 91310000MACNLJYM25 (China)
- Linked to: MIHANDOUST, Mohammad Shakol
Supplemental Information: A China-based entity owned and operated by Mohammad Shakol Mihandoust.
The following vessels have been added to OFAC’s SDN List:
OFAC Program: [IRAN-EO13902] Executive Order 13902
AMIR GAS (V4WK5)
- Vessel Type: LPG Tanker
- Vessel Flag: St. Kitts and Nevis
- Vessel Year of Build: 1998
- Vessel Registration Identification: IMO 9167409
- MMSI: 314550001
- Party Type: Vessel
- Linked to: BLUE SEA MARINE INCORPORATED AND FAATEH MARITIME INCORPORATED
Supplemental Information: The St. Kitts and Nevis-flagged LPG tanker AMIR GAS has transported hundreds of thousands of barrels of Iranian LPG since 2025.
GAS LAGOON (3E4737)
- Vessel Type: LPG Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 2008
- Vessel Registration Identification: IMO 9386304
- MMSI: 352002989
- Party Type: Vessel
- Linked to: ADAMAS SHIPPING INC
Supplemental Information: The Panama-flagged LPG tanker GAS LAGOON has transported millions of barrels of Iranian LPG since 2023.
GAZ GMS (3E4634)
- Vessel Type: LPG Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 1997
- Vessel Registration Identification: IMO 9131539
- MMSI: 352002853
- Party Type: Vessel
- Linked to: GAS GMS LIMITED
Supplemental Information: The Panama-flagged LPG tanker GAZ GMS has transported hundreds of thousands of barrels of Iranian LPG since 2023.
GLENDALE (3FFP9)
- Vessel Type: LPG Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 1996
- Vessel Registration Identification: IMO 9139945
- MMSI: 356634000
- Party Type: Vessel
- Linked to: ECOSEAS MARITIME LIMITED
Supplemental Information: The Panama-flagged LPG tanker GLENDALE has transported millions of barrels of Iranian LPG since 2020.
MD 23 (T8A5356)
- Vessel Type: LPG Tanker
- Vessel Flag: Palau
- Vessel Year of Build: 1998
- Vessel Registration Identification: IMO 9158240
- MMSI: 511101848
- Party Type: Vessel
- Linked to: LIMRA GAS LIMITED
Supplemental Information: The Palau-flagged LPG tanker MD 23 has transported hundreds of thousands of barrels of Iranian LPG since 2023.
MILE (3E4726)
- Vessel Type: LPG Tanker
- Vessel Flag: Panama
- Vessel Year of Build: 1991
- Vessel Registration Identification: IMO 8910897
- MMSI: 352002974
- Party Type: Vessel
- Linked to: BLACK GOLD TRADE CORPORATION
Supplemental Information: The Panama-flagged LPG tanker MILE has transported millions of barrels of Iranian LPG since 2024. In early 2025, Butani Trading LLC used the MILE to ship over half a million barrels of Iranian-origin LPG to end users in Bangladesh.
Amendments:
The following changes have been made to OFAC’s SDN List:
- OFAC Programs:
- [FTO] Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594; Executive Order 13224
COMANDO VERMELHO
- AKA: “RED COMMAND”
- Address: Brazil
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Type: Transnational Terrorist Group
- Target Type: Criminal Organization
List of Changes:
- Program Tags:
- Added: [FTO]
- OFAC Programs:
- [FTO] Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594; Executive Order 13224
- [ILLICIT-DRUGS-EO14059] Executive Order 14059
PRIMEIRO COMANDO DA CAPITAL
- AKA:
- “FIRST CAPITAL COMMAND”
- “PCC”
- Address: Brazil
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Type: Transnational Terrorist Group
- Target Type: Criminal Organization
List of Changes:
- Program Tags:
- Added: [FTO]
-
Had to wait for Claude to do its magic…
Counter Terrorism and Iran-related Designations; Democratic Republic of the Congo-related Designations; Issuance of Iran-related Frequently Asked Question
Treasury Press Release: Economic Fury Targets Iran’s Largest Digital Asset Exchange for Terror Finance and Sanctions Evasion
Treasury Press Release: Treasury Sanctions Rebel Commanders Driving Conflict in the Democratic Republic of the Congo
State Press Release: Targeting Iran’s Digital Asset Exchanges for Terror Finance and Sanctions Evasion
State Press Release: United States Sanctions Armed Group Leaders in Eastern Democratic Republic of the Congo
In addition to the SDN list updates below, OFAC issued a new Iran-related Frequently Asked Question: FAQ 1257.
Additions:
The following individuals have been added to OFAC’s SDN List:
OFAC Program: SDGT Specially Designated Global Terrorist — Designated pursuant to Executive Order 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten to Commit, or Support Terrorism,” as amended by Executive Order 13886 of September 9, 2019. Administered under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.
AGHAMIR MOHAMMAD ALI, Seyed Mohammad
- AKA:
- AGHAMIR, Mohammad
- KHARRAZI, Mohammad
- Address: Tehran, Iran
- DOB: 1992
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked to: NOBITEX
Supplemental Information: Seyed Mohammad Aghamir Mohammad Ali (known as Mohammad Aghamir) is a co-founder and blockchain lead at Nobitex, Iran’s largest digital asset exchange. He is a member of the Kharrazi family. OFAC designated him pursuant to Executive Order 13224, as amended, for being a leader or official of Nobitex.
AGHAMIR MOHAMMAD ALI, Seyed Mohammad Ali
- AKA:
- AGHAMIR, Ali
- AHMAD HOSSEIN, Ali
- KHARRAZI, Ali
- Address: Iran
- DOB: 23 Aug 1986
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked to: NOBITEX
Supplemental Information: Seyed Mohammad Ali Aghamir Mohammad Ali (known as Ali Aghamir) is a co-founder of Nobitex and a member of the Kharrazi family, which is part of former Supreme Leader Khamenei’s inner circle. OFAC designated him pursuant to Executive Order 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, Nobitex.
KHOEE, Seyed Ali
- AKA: KHOUEI, Ali
- Address: Iran
- DOB: 02 May 1989
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked to: NOBITEX
Supplemental Information: Seyed Ali Khoee is the current CEO of Nobitex and previously served as the company’s director of product and marketing. OFAC designated Khoee pursuant to Executive Order 13224, as amended, for being a leader or official of Nobitex.
OFAC Program: DRCONGO Democratic Republic of the Congo — Designated pursuant to Executive Order 13413, “Blocking Property of Certain Persons Contributing to the Conflict in the Democratic Republic of the Congo,” of October 27, 2006, as amended by Executive Order 13671 of July 8, 2014. Administered under the Democratic Republic of the Congo Sanctions Regulations, 31 C.F.R. part 547.
KUBWAYO, Gustave
- AKA:
- “SIRKOFF”
- “SIRKOOF”
- Address: North Kivu, Congo, Democratic Republic of the
- DOB: 1969
- POB: Rwanda
- Nationality: Rwanda
- Gender: Male
- Party Type: Individual
Supplemental Information: Gustave Kubwayo, commonly known as “Colonel Sirkoof,” is an FDLR commander and the leader of the Commando de Recherche et d’Action en Profondeur, an FDLR intelligence and special operations unit. He also led an FDLR operational command structure in North Kivu’s Nyiragongo territory that formed in 2022, after M23 attacks forced the FDLR to geographically disperse. The Democratic Forces for the Liberation of Rwanda (FDLR) formed in 2000 from the remnants of the ex-Rwandan Armed Forces and extremist militias that fled Rwanda following the 1994 genocide. FDLR has waged a campaign of ethnically motivated violence against civilians, including summary killings, forced recruitment of children, and sexual violence; OFAC designated the group on January 3, 2013. OFAC designated Kubwayo pursuant to E.O. 13413, as amended by E.O. 13671, for being a leader of FDLR, an entity whose property and interests in property are blocked pursuant to E.O. 13413.
NZENZE, John Imani
- AKA: “IDI, Imani Nzenze”
- Address: North Kivu, Congo, Democratic Republic of the
- DOB: 06 Aug 1978
- Nationality: Congo, Democratic Republic of the; alt. Rwanda
- Citizen: Congo, Democratic Republic of the; alt. Rwanda
- Gender: Male
- National ID No.: 1197880137555327 (Rwanda)
- Party Type: Individual
Supplemental Information: John Imani Nzenze is an M23 commander and M23’s chief of intelligence. He is regarded as one of the closest collaborators and confidants of Sultani Makenga, the U.S.- and UN-sanctioned overall military commander of M23. Nzenze has been an M23 leader since the group’s first rebellion (2012–2013), when he led M23 attacks on Congolese military positions. M23 is a Rwanda-backed armed group that occupies large portions of North and South Kivu provinces in the DRC; its military campaigns have claimed thousands of civilian lives and resulted in a mass displacement crisis. OFAC designated Nzenze pursuant to E.O. 13413, as amended by E.O. 13671, for being a leader of M23, an entity whose property and interests in property are blocked pursuant to E.O. 13413.
OFAC Programs:
- SDGT Specially Designated Global Terrorist — Designated pursuant to Executive Order 13224, as amended by Executive Order 13886. Administered under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.
- IRAN-EO13902 Iran – Executive Order 13902 — Designated pursuant to Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran,” of January 10, 2020, targeting persons operating in the construction, mining, manufacturing, textiles, financial, or other sectors of the Iranian economy as determined by the Secretary of the Treasury.
RAD, Amir Hossein
- AKA:
- RAD, Amir
- RAD, Amirhossein
- Address: Qazvin, Iran
- DOB: 21 Mar 1986
- Nationality: Iran
- Email Address: radamir@gmail.com
- alt. Email Address: arad@nobitex.ir
- Additional Sanctions Information: Subject to Secondary Sanctions
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Phone Number: 989121810513
- National ID No.: 4324461872 (Iran)
- Party Type: Individual
Supplemental Information: Amir Hossein Rad is Nobitex’s chairman, co-founder, and former CEO. In June 2025, he helped Nobitex reconstitute its operations following a $90 million hack of the company on June 18, 2025; the company had previously enabled the Iranian regime to evade sanctions and transfer wealth out of the country. OFAC designated Rad pursuant to Executive Order 13224, as amended, for being a leader or official of Nobitex, and pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.
The following entities have been added to OFAC’s SDN List:
OFAC Programs:
- IRAN Iran Sanctions — Persons designated pursuant to various Iran-related executive orders and statutory authorities. Administered in part under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560.
- IRAN-EO13902 Iran – Executive Order 13902 — Designated pursuant to Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran,” of January 10, 2020, targeting persons operating in the construction, mining, manufacturing, textiles, financial, or other sectors of the Iranian economy.
BITPIN
- AKA: SANA AYMAN MUBADALA
- Address: Unit 2, Floor 1, Viana (Alizadeh) Trade Complex Building No. 42, Shahid Fatehi Blvd., Sharghayegh Alley, Anzali Free Zone, Bandar Anzali, Gilan 4333155170, Iran
- Website: bitpin.ir
- Additional Sanctions Information: Subject to Secondary Sanctions
- Organization Established Date: 2020
- Organization Type: Financial and Insurance Activities
- Company Number: 14009960142 (Iran)
Supplemental Information: Bitpin is an Iranian digital asset exchange that received 10 percent of all Iranian digital asset inflows in 2025. It has processed millions of dollars in transactions, including transactions linked to the IRGC. Bitpin’s investors have reportedly been linked to Iranian efforts to evade U.S. sanctions. OFAC designated Bitpin pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.
RAMZINEX
- AKA: RAMZINEH ELECTRONIC COMMERCE INNOVATION COMPANY
- Address: Unit 901, 9th Floor, Sharif Technology Tower, No. 28, Shahid Hamid Salahi Blvd, Azadeh Street, Timori, Tehran, Iran
- Website: https://ramzinex.com/
- Additional Sanctions Information: Subject to Secondary Sanctions
- Organization Established Date: 2018
- Organization Type: Financial and Insurance Activities
- Company Number: 14009372096 (Iran)
Supplemental Information: Ramzinex is a digital asset exchange based in Tehran, founded in 2018. It has processed over $2.45 billion in transactions, including transactions linked to the IRGC and a financial institution backed by the Iranian government, and has been used for sanctions evasion. OFAC designated Ramzinex pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.
WALLEX
- AKA:
- KHALGH SARVAT SARZAMIN PARSEH
- KHALQ THARWAT SARZAMIN PARSEH COMPANY
- Address: North Unit, Fourth Floor, No. 231, Mirzai Shirazi Street, Shahoda Street, Abbasabad-Andisheh, Tehran 1586753411, Iran
- Website: https://wallex.ir/
- Additional Sanctions Information: Subject to Secondary Sanctions
- Organization Established Date: 2019
- Organization Type: Financial and Insurance Activities
- Company Number: 14010030821 (Iran)
Supplemental Information: Wallex is Iran’s second-largest digital asset exchange by volume and received 12 percent of all Iranian digital asset inflows in 2025. It has facilitated numerous transactions linked to the IRGC. OFAC designated Wallex pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.
OFAC Programs:
- IRAN Iran Sanctions — Persons designated pursuant to various Iran-related executive orders and statutory authorities. Administered in part under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560.
- SDGT Specially Designated Global Terrorist — Designated pursuant to Executive Order 13224, as amended by Executive Order 13886. Administered under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.
- IRAN-EO13902 Iran – Executive Order 13902 — Designated pursuant to Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran,” of January 10, 2020, targeting persons operating in the construction, mining, manufacturing, textiles, financial, or other sectors of the Iranian economy.
NOBITEX
- AKA: RAHKAR FANAVARI NOOYAN
- Address: Unit 1002, Floor 10, Sharif Technology Tower, Akbari Corner, Salehi Boulevard, Tarasht, Tehran, Iran
- Website: nobitex.ir
- Additional Sanctions Information: Subject to Secondary Sanctions
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Type: Financial and Insurance Activities
- Company Number: 1400769571 (Iran)
Supplemental Information: Nobitex is Iran’s largest digital asset exchange. In 2025, it processed more than 50 percent of all Iranian digital asset inflows, facilitating payments tied to Iran’s terrorist activities, sanctions evasion efforts, and IRGC-linked transactions, including transactions for wallets associated with IRGC-affiliated ransomware actors. Nobitex helped the Central Bank of Iran access hundreds of millions of dollars in stablecoins used to prop up the plummeting value of the Iranian rial, while enabling regime insiders to access international digital asset exchanges and evade sanctions across multiple jurisdictions. Two of Nobitex’s co-founders are close associates of former Supreme Leader Khamenei’s family. Nobitex also reportedly enables the Iranian government to conduct warrantless surveillance of Iranian civilians. Following the commencement of U.S. combat operations in Iran, Nobitex played a role in protecting and moving assets and funds out of the country to shield regime wealth, even during internet blackouts. OFAC designated Nobitex pursuant to Executive Order 13224, as amended, for materially assisting, sponsoring, or providing financial, material, or technological support to the IRGC, and pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.
- AKA:
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Counter Terrorism Designations; Issuance of Amended Iran-related Frequently Asked Question
Treasury Press Release: Economic Fury Targets Iranian Network Defrauding U.S. Firms to Supply Tehran’s Military
State Press Release: Sanctioning Iranian-Affiliated Fraud Network Targeting American Companies
State Press Release: Terrorist Designation of Comando Vermelho and Primeiro Comando da Capital
Note: This update also includes the issuance of one amended Iran-related Frequently Asked Question, FAQ 1249.
Additions:
The following individuals have been added to OFAC’s SDN List:
- OFAC Programs:
- SDGT Specially Designated Global Terrorist — designations pursuant to Executive Order 13224, as amended by Executive Order 13886, targeting terrorists, terrorist organizations, and those who provide support to acts of terrorism.
- IFSR Iranian Financial Sanctions Regulations — designations under 31 C.F.R. Part 561, implementing financial sanctions applicable to Iran’s financial sector and creating secondary sanctions risk for foreign financial institutions that conduct significant transactions with designated persons.
AKHTARIAN, Sayyed Payam
- AKA: AKHTARIAN, Payam
- Address: Tehran, Iran
- DOB: 28 Aug 1984
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 0068490585 (Iran)
- Party Type: Individual
- Linked To: SORENA HUSHMAND SAMANEH COMPANY
Supplemental Information: Per the Treasury press release, Akhtarian served as a sales manager at Sorena Hushmand Samaneh Company and helped Sepehr facilitate the transfer of U.S.-origin products to Iran.
BAGHERI, Hoda Baradaran
- AKA: BAGHERI, Hoda
- Address: Tehran, Iran
- DOB: 15 Sep 1984
- Nationality: Iran
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 0074993305 (Iran)
- Birth Certificate Number: 7616 (Iran)
- Party Type: Individual
- Linked To: SORENA HUSHMAND SAMANEH COMPANY
Supplemental Information: Per the Treasury press release, Bagheri served as a sales manager at Sorena Hushmand Samaneh Company and helped Sepehr facilitate the transfer of U.S.-origin products to Iran.
DAREHSHIRI, Mohammadali Mansour
- AKA:
- DAREH SHIRI, Mohammadali Mohammad
- DAREHSHIRI, Mansour
- DAREHSHIRI, Mohammad Ali
- DARREH SHIRI, Mohammed Ali
- Address: Tehran, Iran; United Arab Emirates
- DOB: 27 Jul 1964
- POB: Yazd, Iran
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: N61034949 (Iran) expires 06 Dec 2027
- National ID No.: 4430983704 (Iran)
- Birth Certificate Number: 2377 (Iran)
- Party Type: Individual
- Linked To: SEPEHR, Ali Majd
Supplemental Information: Per the Treasury press release, Darehshiri acted as an intermediary for Sepehr and Sorena, paying U.S. freight forwarders on Sepehr’s behalf to store and ship fraudulently procured goods from the United States to the UAE. Darehshiri founded and controls Green Light Computer Co LLC, a Dubai-based company he used alongside another Dubai-based front company, Al Kawther Neon LLC, to facilitate receipt of shipments and arrange their re-export from the UAE to Iran. Darehshiri also separately procured export-controlled network security equipment, computer hardware, and product and software licenses for Sepehr and Sorena in Iran.
REZAEI, Farzaneh
- AKA: REZAI, Farzaneh
- Address: Tehran, Iran
- DOB: 07 Oct 1975
- Nationality: Iran
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 0072615125 (Iran)
- Birth Certificate Number: 4712 (Iran)
- Party Type: Individual
- Linked To: SORENA HUSHMAND SAMANEH COMPANY
Supplemental Information: Per the Treasury press release, Rezaei served as a sales manager at Sorena Hushmand Samaneh Company and helped Sepehr facilitate the transfer of U.S.-origin products to Iran.
SARMADI, Roudabeh
- AKA: SARMADI, Rudabeh
- Address: Tehran, Iran
- DOB: 11 Nov 1983
- POB: Tehran, Iran
- Nationality: Iran
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 0070144011 (Iran)
- Birth Certificate Number: 13019 (Iran)
- Party Type: Individual
- Linked To: SORENA HUSHMAND SAMANEH COMPANY
Supplemental Information: Per the Treasury press release, Sarmadi serves as the chairperson of the board of directors of Sorena Hushmand Samaneh Company.
SEPEHR, Ali Majd
- AKA:
- BITAZAR, Ali
- BITAZER, Ali
- Address: Tehran, Iran
- DOB: 22 Dec 1980
- POB: Tehran, Iran
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 0071722221 (Iran)
- Party Type: Individual
- Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS
Supplemental Information: Per the Treasury and State press releases, Sepehr led the network. Via his Iranian company Sorena Hushmand Samaneh Company, Sepehr impersonated U.S. small businesses to defraud dozens of U.S. information technology companies, resellers, and vendors out of millions of dollars in order to procure restricted goods—including network security and encryption software and hardware. The scheme involved creating fake websites mimicking real U.S. companies and routing shipments through Dubai-based intermediaries. Sepehr also specifically attempted to source spectrum analyzers and non-linear junction detectors from U.S. vendors for the benefit of MODAFL-controlled SAAFTA.
ZAHEDI, Saeid
- Address: Rome, Italy; Iran
- DOB: 03 Oct 1987
- POB: Tehran, Iran
- Nationality: Iran
- Alt. Nationality: Italy
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: YB2971531 (Italy) expires 08 Apr 2028
- National ID No.: 0078347726 (Iran)
- Alt. National ID No.: ZHDSDA87R03Z224O (Italy)
- Party Type: Individual
- Linked To: SEPEHR, Ali Majd
Supplemental Information: Per the Treasury press release, Zahedi is an Italy-based Iranian national who used a U.S. financial account to pay for domain registration services from a U.S.-based company. The registered domains were created by Sepehr to impersonate U.S. businesses when procuring goods from U.S. companies under false pretenses. Zahedi’s account was also used to pay freight forwarding warehouses used by Sepehr.
ZANDIAN, Manoochehr
- AKA: ZANDIAN, Manoochehr Shahryar
- Address: Tehran, Iran
- DOB: 02 May 1960
- POB: Meybod, Iran
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 4489859856 (Iran)
- Party Type: Individual
- Linked To: SORENA HUSHMAND SAMANEH COMPANY
Supplemental Information: Per the Treasury press release, Zandian served as a sales manager at Sorena Hushmand Samaneh Company and helped Sepehr facilitate the transfer of U.S.-origin products to Iran.
The following entities have been added to OFAC’s SDN List:
- OFAC Programs:
- SDGT Specially Designated Global Terrorist — designations pursuant to Executive Order 13224, as amended by Executive Order 13886, targeting terrorists, terrorist organizations, and those who provide support to acts of terrorism.
- IFSR Iranian Financial Sanctions Regulations — designations under 31 C.F.R. Part 561, implementing financial sanctions applicable to Iran’s financial sector and creating secondary sanctions risk for foreign financial institutions that conduct significant transactions with designated persons.
AL KAWTHER NEON LLC
- AKA:
- Arabic: للنیون الکوثر م.م.ذ.ش
- ALKAWTHER NEON CO
- Address: P.O. Box 80123, Dubai, United Arab Emirates
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 30 Jun 2003
- Commercial Registry Number: 996952 (United Arab Emirates)
- Chamber of Commerce Number: 99850 (United Arab Emirates)
- Registration Number: 546643 (United Arab Emirates)
- Economic Register Number (CBLS): 10814414 (United Arab Emirates)
- Linked To: SEPEHR, Ali Majd
Supplemental Information: Per the Treasury press release, Al Kawther Neon LLC is a Dubai-based front company used by Darehshiri alongside Green Light Computer Co LLC to facilitate the receipt of fraudulently procured shipments and arrange their re-export from the UAE to Iran.
GREEN LIGHT COMPUTER CO LLC
- AKA:
- Arabic: شرکة الضوء الاخضر للکمبیوتر ذ.م.م
- GREEN LIGHT COMPUTER CO
- Address: Deira Al Khabeesi, Dubai, United Arab Emirates; P.O. Box 47167, Dubai, United Arab Emirates
- Website: www.greenlightuae.com
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 30 Aug 1999
- License: 513937 (United Arab Emirates)
- Economic Register Number (CBLS): 10801439 (United Arab Emirates)
- Linked To: DAREHSHIRI, Mohammadali Mansour
Supplemental Information: Per the Treasury press release, Green Light Computer Co LLC was founded and is controlled by Darehshiri. It was used to facilitate the receipt of fraudulently procured shipments in the UAE and their subsequent re-export to Iran.
SAIRAN INFORMATION EXCHANGE SPACE SECURITY INDUSTRIES COMPANY
- AKA:
- SAIRAN INFORMATION EXCHANGE SPACE SECURITY INDUSTRY
- “SAAFTA”
- Address: Shahid Teymouri Alley, Shahid Langari Street, Nobonyad Square, Pasdaran Street, Tehran 1957975713, Iran
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 05 Apr 2015
- National ID No.: 14004828226 (Iran)
- Identification Number: 411481176816 (Iran)
- Registration Number: 470437 (Iran)
- Linked To: MINISTRY OF DEFENSE AND ARMED FORCES LOGISTICS
Supplemental Information: Per the Treasury press release, SAAFTA is a MODAFL-controlled entity. Sepehr specifically attempted to source spectrum analyzers and non-linear junction detectors from U.S. vendors for the benefit of SAAFTA.
SORENA HUSHMAND SAMANEH COMPANY
- AKA:
- Arabic: شرکت سامانھ ھوشمند سورنا
- SAMANEH HOUSHMAND SORENA
- SORENA SMART SYSTEM CO LTD
- SORENA TECHNOLOGY
- Address: Unit 9, No. 7, Alley 12, South Ghandi Street, Vanak Square, Tehran, Iran
- Website: sorena.ir
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 10103647730 (Iran)
- Registration Number: 323911 (Iran)
- Linked To: SEPEHR, Ali Majd
Supplemental Information: Per the Treasury press release, Sorena Hushmand Samaneh Company is Sepehr’s Iranian company, used to impersonate U.S. small businesses in order to fraudulently procure restricted goods—including network security and encryption software and hardware—from U.S.-based companies.
OFAC Program: SDGT Specially Designated Global Terrorist — designations pursuant to Executive Order 13224, as amended by Executive Order 13886, targeting terrorists, terrorist organizations, and those who provide support to acts of terrorism.
COMANDO VERMELHO
- AKA: “RED COMMAND”
- Address: Brazil
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Type: Transnational Terrorist Group
- Target Type: Criminal Organization
Supplemental Information: Per the State Department press releases, Comando Vermelho (CV) is one of Brazil’s most violent criminal organizations, commanding thousands of members. CV has orchestrated brutal attacks against Brazilian police officers, public officials, and civilians, with its influence and illicit networks extending across the region and into the United States. The State Department designated CV as an SDGT pursuant to E.O. 13224 and announced its intent to designate CV as a Foreign Terrorist Organization (FTO) effective June 5, 2026, pursuant to section 219 of the Immigration and Nationality Act.
Amendments:
The following changes have been made to OFAC’s SDN List:
- OFAC Programs:
- SDGT Specially Designated Global Terrorist — designations pursuant to Executive Order 13224, as amended by Executive Order 13886, targeting terrorists, terrorist organizations, and those who provide support to acts of terrorism.
- ILLICIT-DRUGS-EO14059 Executive Order 14059 (December 15, 2021) — targets foreign persons who play a significant role in international narcotics trafficking or who materially assist, sponsor, or provide financial, material, or technological support for such persons.
PRIMEIRO COMANDO DA CAPITAL
- AKA:
- “FIRST CAPITAL COMMAND”
- “PCC”
- Address: Brazil
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Type: Transnational Terrorist Group
- Target Type: Criminal Organization
Supplemental Information: Per the State Department press releases, Primeiro Comando da Capital (PCC) is one of Brazil’s most violent criminal organizations, commanding thousands of members. PCC has orchestrated brutal attacks against Brazilian police officers, public officials, and civilians, with its influence and illicit networks extending across the region and into the United States. Previously designated under the ILLICIT-DRUGS-EO14059 program, PCC is now also designated as an SDGT pursuant to E.O. 13224. The State Department announced its intent to designate PCC as a Foreign Terrorist Organization (FTO) effective June 5, 2026, pursuant to section 219 of the Immigration and Nationality Act.
List of Changes:
- Field Name: Secondary sanctions risk
- Added: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Field Name: Organization Type
- Added: Transnational Terrorist Group
- Field Name: Target Type
- Added: Criminal Organization
- Field Name: Program Tags
- Added: [SDGT]
- OFAC Programs:
-
Iran-related Designation; Counter Terrorism Designation
Additions:
The following entity 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
PERSIAN GULF STRAIT AUTHORITY
- AKA: Arabic: نهاد مدیریت آبراه خلیج فارس
- Address: Iran
- Website: https://pgsa.ir
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 2026
- Linked to: ISLAMIC REVOLUTIONARY GUARD CORPS
- OFAC Programs:
-
Notice of Changes to the Consolidated List – 22 May 2026
DFAT updated the Consolidated List on 22 May 2026 following receipt of the attached advice from the United Nations Sanctions Committee established pursuant to resolution 1267 (ISIL (Da ’esh) and Al-Qaida). The changes include
- The removal of 7 individuals under the ISIL (Da ’esh) and Al-Qaida sanctions framework.
The updated Consolidated List can be downloaded from the following page: Consolidated List | Australian Government Department of Foreign Affairs and Trade. Guidance on how to interpret the Consolidated List can be found here: Guide to Australia ’s Consolidated List | Australian Government Department of Foreign Affairs and Trade
If you have any queries, please contact the Australian Sanctions Office at sanctions@dfat.gov.au.
Australian Sanctions Office
-
First, the UN made changes yesterday:
Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee Removes Seven Entries from Its Sanctions List | UN Meetings Coverage and Press ReleasesDownloadThen, today… Canada:
Greetings,
On May 21st, 2026, the UN Security Council ISIL (Daesh) and Al-Qaida Sanctions Committee removed seven individuals from its sanctions list. For more information, consult the Press Release.
This amendment takes effect immediately under Canadian sanctions legislation, pursuant to the Regulations Implementing the United Nations Resolutions on Taliban, ISIL (Daesh) and Al-Qaida.
For further information on UN Security Council sanctions list, consult List of updates to the UNSC Consolidated List | Security Council.
Sincerely,
and the UK:
Today, Friday 22 May, the UK Government has delisted the following individuals under the Isil (Da’esh) and Al-Qaeda (United Nations Sanctions) (EU Exit) Regulations 2019.
De-Listing:
and its sanctions notice:
And lastly, SECO/FINMA:
NEWS
22 May 2026
Financial sanction
2026
Updated sanction message: ISIL (Da’esh) and Al-Qaeda
The State Secretariat for Economic Affairs (SECO) has amended the list of sanctioned natural persons, undertakings and organizations of the Regulation of 21. March 2025 on measures against persons and organizations associated with the organizations ISIL (Da’esh) and Al-Qaeda (SR 946.231.08).
By decision of 21. In May 2026, the responsible UN Sanctions Committee changed the list of persons, companies and organizations sanctioned in this context. The amendment is directly applicable in Switzerland. SECO therefore, on 22. May 2026 adapted the sanctions database SESAM (SECO Sanctions Management), which is relevant for Switzerland, and published the adjustment on its website.
and its PDF update:
and links to its XML update and consolidated program listings.
-
Counter Terrorism Designations
Treasury Press Release: Treasury Targets Hizballah-Aligned Officials Obstructing Peace and Disarmament
State Press Release: U.S. Sanctioning Hizballah’s Enablers in Lebanon
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-MOUSSAWI, Ibrahim (Arabic: ابراهيم الموسوي)
- AKA:
- AL-MOUSAOUI, Ibrahim
- MOUSAWI, Ibrahim
- Address: Lebanon
- DOB: 05 Nov 1965
- 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.: 000019172428 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, al-Moussawi is currently the head of Hizballah’s Media Committee and one of Hizballah’s elected representatives in the Lebanese parliament. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, Hizballah.
BAALBAKI, Ahmad Asaad (Arabic: احمد اسعد بعلبكي)
- AKA: BALABAKI, Ahmad Asad
- Address: Beirut, Lebanon
- DOB: 02 Apr 1961
- POB: Beirut, Lebanon
- Nationality: Lebanon
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 000034246532 (Lebanon)
- Identification Number: 311125 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Baalbaki is the Amal Movement Security Director who coordinated public displays of force with Hizballah leadership to intimidate Hizballah’s political opponents in Lebanon. The Amal Movement is a political ally and security partner of Hizballah. He is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah.
FADLALLAH, Hassan Nizammeddine
- AKA: FADLALLAH, Hassan (Arabic: حسن فضل الله)
- Address: Ainata, Lebanon
- DOB: 02 Oct 1967
- POB: Ainata, Bint Jbeil, 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
- National ID No.: 000032614265 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Fadlallah has represented Hizballah as one of the group’s elected members of the Lebanese parliament since 2005. He also helped found U.S.-designated Al Nour Radio and was a senior director for U.S.-designated Al Manar TV. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, Hizballah.
FANICH, Abdel-Mottaleb Mohamed (Arabic: محمد عبد المطلب فنيش)
- AKA: FNEISH, Mohammad
- Address: Lebanon
- DOB: 10 Feb 1953
- POB: Maaroub, Lebanon
- Nationality: Lebanon
- Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Fanich leads Hizballah’s executive council and is responsible for reorganizing the terrorist group’s administrative and institutional structure in furtherance of Hizballah’s mission of maintaining an armed presence in Lebanon. He has been a Hizballah member since the organization was first established and has held multiple leadership positions within the group. He was elected to Lebanon’s parliament as part of Hizballah’s Loyalty to the Resistance Bloc in 1992 and was later appointed Minister of Youth and Sports. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, Hizballah. The State press release notes that the U.S. Department of State’s Rewards for Justice program is offering up to $10 million for information leading to the disruption of Hizballah’s financial mechanisms.
HAMADI, Samir ‘Adnan (Arabic: سامر عدنان حمادي)
- AKA: HAMADI, Samer
- Address: Mount Lebanon, Lebanon
- DOB: 17 Feb 1982
- alt. DOB: 03 Mar 1982
- POB: Bourj El Brajne, Lebanon
- Nationality: Lebanon
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: LR0499320 (Lebanon) expires 29 Jul 2022
- Identification Number: 4267356 (Lebanon)
- Birth Certificate Number: 533 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Hamadi is the Lebanese Armed Forces (LAF) Intelligence Directorate Dahiyah Branch Chief (Colonel) who shared important intelligence with Hizballah during the ongoing conflict over the past year. He is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah.
HASSAN, Hussein Al-Hajj
- AKA:
- HASSAN, Hussein Al-Haj
- HASSAN, Hussein Ali Al-Hajj (Arabic: حسين علي الحاج حسن)
- Address: Nabi Chit, Beqaa, Lebanon
- DOB: 17 Oct 1960
- POB: Nabi Sheet, Lebanon
- Nationality: Lebanon
- Additional Sanctions Information: Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Hassan has been a Hizballah member since 1982 and has represented Hizballah as a member of the Lebanese parliament since 1996. In his role as a public representative of Hizballah, Hassan has been a key figure opposing the disarmament of the terrorist group. He is designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act on behalf of, Hizballah.
NASSER ELDIN, Khattar
- Address: Khattar Nasser El Din Building, Kalamoun Old Road, Tripoli, Lebanon
- DOB: 07 Apr 1973
- POB: Tripoli, Lebanon
- Nationality: Lebanon
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Passport: RL2508250 (Lebanon) expires 16 Jul 2019
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Nasser Eldin is the General Directorate of General Security (DGS) National Security Department Chief (Brigadier General) who shared important intelligence with Hizballah during the ongoing conflict over the past year. He is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah.
SAFAWI, Ali Ahmad
- AKA:
- SAFAWI, Abu Ahmad
- SAFAWI, Ahmad (Arabic: احمد صفاوي)
- Address: Nabatieh, Lebanon
- DOB: 29 Sep 1981
- Nationality: Lebanon
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- National ID No.: 000013508041 (Lebanon)
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Safawi is the commander of the Lebanese Amal militia in southern Lebanon. Acting as Baalbaki’s subordinate, Safawi coordinated with and took direction from Hizballah on attacks against Israel and led Amal militia forces in joint Hizballah-Amal military operations against Israel. He is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah.
- OFAC Programs:
- [IRAN] Iranian Transactions and Sanctions Regulations, 31 CFR part 560
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [IFSR] Iranian Financial Sanctions Regulations, 31 CFR part 561
SHEIBANI, Mohammad Reza Raouf (Arabic: محمد رضا رؤف شيباني)
- AKA:
- SHEIBANI, Mohammad Reza
- SHEIBANI, Mohammed Reza Ra’of
- Address:
- Lebanon
- Iran
- DOB: 12 Dec 1961
- Nationality: Iran
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Additional Program Tags: [IRGC]
- Party Type: Individual
- Linked To: HIZBALLAH
Supplemental Information: Per the Treasury press release, Sheibani is the Iranian Ambassador designate to Lebanon, whom Lebanon’s Foreign Ministry declared persona non grata after it withdrew its approval of his candidature and ordered him to leave Beirut. Iran’s violation of diplomatic norms, and the practices routinely used by the ambassador in communication between the two states, were cited as the reason for Sheibani’s expulsion. The Lebanese government demanded that security forces take resolute measures to stop the activities of Iran’s Islamic Revolutionary Guard Corps, which has supported Hizballah’s military operations. He is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah.
Amendments:
The following changes have been made to OFAC’s SDN List:
OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
BIN MUHAMMAD, Ayadi Chafiq
- AKA:
- AIADI, Ben Muhammad
- AIADY, Ben Muhammad
- AYADI CHAFIK, Ben Muhammad
- AYADI SHAFIQ, Ben Muhammad
- Address:
- Helene Meyer Ring 10-1415-80809, Munich, Germany
- 129 Park Road, NW8, London, United Kingdom
- 28 Chaussee de Lille, Mouscron, Belgium
- Darvingasse 1/2/58-60, Vienna, Austria
- Tunisia
- DOB: 21 Jan 1963
- POB: Safais (Sfax), Tunisia
- Nationality: Tunisia
- alt. Nationality: Ireland
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Party Type: Individual
- Linked To: AL QA’IDA
Supplemental Information: BIN MUHAMMAD, Ayadi Chafiq (also known as “Abou El Baraa”) was placed on the UN Security Council al-Qaida sanctions list on October 17, 2001, and designated by OFAC as an SDGT. His last known residence was Dublin, Ireland (as of 2009). The UN Security Council Al-Qaida Sanctions Committee delisted him from its consolidated list in October 2011 following a de-listing request reviewed through the Ombudsperson’s office; OFAC’s designation remained in effect. Today’s amendment adds nationality information and formally links him to Al Qa’ida.
List of Changes:
- Field Name: Nationality
- Added: Tunisia
- Field Name: alt. Nationality
- Added: Ireland
- Field Name: Gender
- Added: Male
- Field Name: Linked To
- Added: AL QA’IDA
LAJNAT AL DAAWA AL ISLAMIYYA
- AKA:
- ISLAMIC CALL COMMITTEE
- LAJNA ALDAWA ALISALMIAH
- LAJNA ALDAWA ALISLAMIA
- LAJNA ALDAWA ALISLAMIYA
- LAJNAT AL DAAWA AL ISLAMIYA
- LAJNAT AL DAWA
- LAJNAT AL DAWA AL ISLAMIA
- LAJNAT AL D’AWA AL ISLAMIAK
- LAJNAT ALDAWA AL ISLAMIAH
- LAJNAT ALDAWA ALISLAMIA
- Address: Kuwait
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 1986
- Target Type: Charity or Nonprofit Organization
- Linked To: AL QA’IDA
Supplemental Information: Lajnat Al Daawa Al Islamiyya (also known as the “Islamic Call Committee”) is a Kuwait-based organization first designated by OFAC as an SDGT on January 9, 2003. It presents itself as a humanitarian aid NGO that has provided aid in Afghanistan and other parts of western Asia, but U.S. intelligence analysts asserted it provided logistic support to terrorist groups. The UN Security Council delisted it from its al-Qaida sanctions list in September 2013 through its Ombudsperson process; OFAC’s designation remained in effect. Today’s amendment adds the organization’s established date, target type, and formally links it to Al Qa’ida.
List of Changes:
- Field Name: Organization Established Date
- Added: 1986
- Field Name: Target Type
- Added: Charity or Nonprofit Organization
- Field Name: Linked To
- Added: AL QA’IDA
- AKA:
-
Counter Narcotics and Counter Terrorism Designations
Additions:
The following individuals have been added to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [ILLICIT-DRUGS-EO14059] Executive Order 14059
AISPURO FELIX, Jesus Alonso
- Address: Mexico
- DOB: 01 Aug 1981
- POB: Durango, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: AIFJ810801HDGSLS08 (Mexico)
- Party Type: Individual
- Linked To: SINALOA CARTEL
Supplemental Information: The Sinaloa Cartel was designated a Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT) by the U.S. Department of State on February 20, 2025, following Executive Order 14157 issued by President Trump on January 20, 2025. No prior OFAC designation record found for this individual.
BOJORQUEZ CHAPARRO, Castulo
- Address: Sinaloa, Mexico
- DOB: 23 Mar 1978
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: BOCC780323HSLJHS08 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
Supplemental Information: Jesus Gonzalez Penuelas (a.k.a. “El Chuy Gonzalez”) is the leader of the Gonzalez Penuelas Drug Trafficking Organization, designated by OFAC under the Foreign Narcotics Kingpin Designation Act in May 2021. OFAC has described the Gonzalez Penuelas DTO as one of the largest sources of raw opium gum and heroin in northern Mexico and a major distributor of fentanyl to U.S. markets. No prior OFAC designation record found for this individual.
CASTRO ROCHA, Noe de Jesus
- Address: Sinaloa, Mexico
- DOB: 10 Nov 1975
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: CARN751110HSLSCX05 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
GARCIA SANDOVAL, Fredi Ismael
- Address: Mexico City, Mexico
- DOB: 29 Aug 1973
- POB: Chihuahua, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: GASF730829HCHRNR09 (Mexico)
- RFC: GAGF9908292X4 (Mexico)
- alt. RFC: GASF730829UN5 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
MORENO ZAMORA, Luis Arnulfo
- Address: Sinaloa, Mexico
- DOB: 01 Feb 1990
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: MOZL900201HSLRMS01 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
OJEDA AVILES, Armando de Jesus
- Address: Mexico
- DOB: 01 May 1985
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Digital Currency Address – ETH: 0x038989cbb1710c72b9920dc4fa529158f463e72c
- alt. Digital Currency Address – ETH: 0x14779CEC0B117d5194c750C55Ea1f42086631964
- alt. Digital Currency Address – ETH: 0x32dA24Ca413F3E7B53145D4737e172C3bdF81e3e
- alt. Digital Currency Address – ETH: 0xf2235d55b2950a0b1317469d72d07ae65b2e27cb
- alt. Digital Currency Address – ETH: 0x4F428c11Dc82388fa5136D636e613ad923Eb700B
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: OEAA850501HSLJVR09 (Mexico)
- Party Type: Individual
- Linked To: SINALOA CARTEL
Supplemental Information: OFAC identified five Ethereum cryptocurrency wallet addresses associated with this individual, reflecting the Sinaloa Cartel’s documented use of digital assets to move illicit proceeds. The Sinaloa Cartel was designated a Foreign Terrorist Organization and SDGT on February 20, 2025. No prior OFAC designation record found for this individual.
OROZCO ROMERO, Alfredo
- Address: Mexico
- DOB: 29 May 1979
- POB: Chihuahua, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- R.F.C.: OORA790529H89 (Mexico)
- C.U.R.P.: OORA790529HCHRML03 (Mexico)
- Party Type: Individual
- Linked To: OJEDA AVILES, Armando de Jesus
OROZCO ROMERO, Liliana
- Address: Mexico
- DOB: 14 Jan 1976
- POB: Chihuahua, Mexico
- Nationality: Mexico
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- R.F.C.: OORL760114EN6 (Mexico)
- C.U.R.P.: OORL760114MCHRML06 (Mexico)
- Party Type: Individual
- Linked To: OROZCO ROMERO, Alfredo
ROMERO MORENO, Amalia Margarita
- Address: Mexico
- DOB: 23 Dec 1957
- POB: Chihuahua, Mexico
- Nationality: Mexico
- Gender: Female
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: ROMA571223MCHMRM07 (Mexico)
- Party Type: Individual
- Linked To: OROZCO ROMERO, Alfredo
SAENZ AGUILAR, Baltazar
- Address: Sinaloa, Mexico
- DOB: 12 Aug 1985
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: SAAB850812HSLNGL03 (Mexico)
- Party Type: Individual
- Linked To: GONZALEZ PENUELAS, Jesus
OFAC Program: [ILLICIT-DRUGS-EO14059] Executive Order 14059
ALARCON PALOMARES, Rodrigo
- Address: Mexico
- DOB: 21 Jun 1996
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Digital Currency Address – ETH: 0xaC4cC4B68ea24BbFAAC8fD127B67Ed445ACcCE22
- C.U.R.P.: AAPR960621HSLLLD02 (Mexico)
- Party Type: Individual
The following entities have been added to OFAC’s SDN List:
- OFAC Programs:
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [ILLICIT-DRUGS-EO14059] Executive Order 14059
GORDITAS CHIWAS
- Address: Chihuahua, Mexico
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 11 Jan 2006
- Organization Type: Restaurants and mobile food service activities
- R.F.C.: ROMA5712239X0 (Mexico)
- Linked To: OROZCO ROMERO, Alfredo
GRUPO ESPECIAL MAMBA NEGRA, S. DE R.L. DE C.V.
- Address: Chihuahua, Mexico
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Organization Established Date: 25 Mar 2010
- Organization Type: Private security activities
- Folio Mercantil No.: 25872 (Mexico)
- Linked To: OROZCO ROMERO, Alfredo
Amendments:
The following changes have been made to OFAC’s SDN List:
- OFAC Programs:
- [SDNTK] Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598
- [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
- [ILLICIT-DRUGS-EO14059] Executive Order 14059
GONZALEZ PENUELAS, Jesus (Latin: GONZÁLEZ PEÑUELAS, Jesús)
- AKA: “EL CHUY GONZALEZ”
- Address: Sinaloa, Mexico
- DOB: 10 Nov 1969
- POB: Sinaloa, Mexico
- Nationality: Mexico
- Gender: Male
- Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- C.U.R.P.: GOPJ691110HSLNXS09 (Mexico)
- Party Type: Individual
- Linked To: SINALOA CARTEL
Supplemental Information: Jesus Gonzalez Penuelas, known as “El Chuy Gonzalez,” was originally designated by OFAC under the Foreign Narcotics Kingpin Designation Act (Kingpin Act) on May 12, 2021 as the leader of the Gonzalez Penuelas Drug Trafficking Organization (DTO). OFAC identified the Gonzalez Penuelas DTO as one of the largest sources of raw opium gum and heroin in northern Mexico and a major distributor of fentanyl to U.S. markets, with operations primarily in Sinaloa and Sonora, Mexico, and distribution cells in California, Texas, Colorado, Washington, Utah, and Nevada. He has been indicted on drug trafficking charges by the U.S. District Court for the Southern District of California (2017) and by the U.S. District Court for the District of Colorado (2018) and remains a fugitive. Today’s amendment adds the [SDGT] and [ILLICIT-DRUGS-EO14059] program tags to his existing [SDNTK] designation and formally links him to the Sinaloa Cartel — designated a Foreign Terrorist Organization by the U.S. Department of State in February 2025 — extending counterterrorism authorities to his designation.
List of Changes:
- Field Name: Secondary sanctions risk
- Added: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
- Field Name: Program Tags
- Changed: [SDNTK] to: [SDNTK] [SDGT] [ILLICIT-DRUGS-EO14059]
- Field Name: Linked To
- Added: SINALOA CARTEL
Mr. Sanctions’ Note: There was no associated press release, so the Supplemental Information came from Claude searching far and wide for things to add to OFAC’s listings.
- OFAC Programs:
-
What Does Adding a Counter-Terrorism Designation Actually Add?
The right way to think about this is in terms of marginal impact — what additional legal, financial, political, and compliance burden does the SDGT tag bring when layered on top of a pre-existing program designation? And does that marginal impact differ depending on whether the baseline is Iran sanctions or a counter-narcotics designation?
The short answer is: yes, substantially. Adding CT to a narcotics designation is a much larger step than adding CT to an Iran designation, because Iran sanctions already cover much of the same ground — and then some — that the CT program brings. By contrast, a counter-narcotics designee who picks up an SDGT tag is crossing into a meaningfully different legal universe.
What the Counter-Terrorism Designation Brings Independently
Before comparing the additive effects, it helps to be clear about what the SDGT designation itself contributes:
Asset blocking and U.S. person prohibitions. All assets within U.S. financial systems or under U.S. control are immediately frozen. U.S. persons must block all property and interests in property of SDNs within U.S. jurisdiction and avoid any transactions with them. Entities owned 50% or more by one or more SDNs are also considered blocked, even if not explicitly listed.
Civil and criminal penalties (strict liability). Even inadvertent, harmless, and accidental transactions with designated persons can subject a party to significant civil penalties, because OFAC-administered sanctions are considered strict liability offenses. Persons who willfully violate OFAC-administered terrorism sanctions may also face lengthy prison sentences. Civil penalties can reach the greater of $377,700 per violation or twice the value of the underlying transaction; willful violations can result in criminal fines up to $1,000,000 and up to 20 years in prison.
Secondary sanctions against foreign persons. Under EO 13224 as amended by EO 13886, non-U.S. persons who engage in prohibited transactions or dealings subject to U.S. jurisdiction with SDGTs may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable-through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT.
Material support criminal statutes. The SDGT designation activates 18 U.S.C. §§ 2339A/B, which criminalize the provision of material support to designated groups. This is a separate criminal regime from OFAC’s civil/administrative authority. OFAC has authority to issue general and specific licenses that can enable humanitarian, peacebuilding, and other exemptions under the SDGT and other sanctions regimes — but no comparable licensing authority exists under the material support statutes.
Anti-Terrorism Act civil litigation exposure. An FTO/SDGT designation increases the risk of civil terrorism suits, governmental investigation, and administrative and criminal actions under the ATA (Anti-Terrorism Act), as amended by JASTA.
BIS export controls. The Bureau of Industry and Security requires a license for the export of any item to a person designated as an SDGT and does not provide a license exception.
Enhanced national security apparatus. The fact of designation can enable the government to bring to bear additional national security authorities, including counterterrorism authorities and resources. That additional attention will likely reach and reveal activities by individuals and entities associated (wittingly or unwittingly) with newly designated parties, which will in turn expose them to risk of further investigation.
Reputational stigma and contagion risk. Designation imposes a severe reputational stigma — the stamp of a government label that an organization or individual is a terrorist. An entity that materially assists or supports a designated SDGT may itself be subject to designation under EO 13224.
Adding CT to an Iran Sanctions Designation: Marginal Impact
For a party already designated under Iran sanctions authorities — say, under EO 13846, EO 13902, the IFSR, or the ITSR — much of the damage from blocking and secondary sanctions has already been done. The Iran program is one of OFAC’s most comprehensive, and it already brings:
- Full U.S. person blocking prohibitions covering not just the designated person but the entire Iranian financial and energy sector
- Robust statutory secondary sanctions under CISADA, IFCA, CAATSA, and other Iran-specific statutes, which threaten non-U.S. persons’ access to the U.S. financial system for conduct with no U.S. nexus — this goes significantly further than EO 13224’s secondary sanctions language
- Sector-wide prohibitions, not just entity-specific blocking, covering Iranian banking, energy, shipping, and other industries
- Extension of compliance obligations to foreign subsidiaries of U.S. persons under 31 CFR § 560.215 — a feature not universally present in other OFAC programs
When the SDGT tag is layered on top, the person is now subject to the targeted CT sanctions program in addition to the country-specific Iran program. The incremental additions are real but relatively narrow:
What CT meaningfully adds to an Iran designation:
- Activation of the material support criminal statutes (18 U.S.C. §§ 2339A/B), which the Iran program doesn’t trigger on its own
- ATA/JASTA civil lawsuit exposure against parties who dealt with the designee
- BIS no-license-exception rule specifically tied to SDGT status
- The “terrorist” label itself, which carries political and diplomatic weight beyond the sanctions restrictions — SDGT is a qualitative statement about the designee’s character that Iran sanctions, focused on national security and foreign policy toward a country, do not necessarily make
What CT does not meaningfully add to an Iran designation:
- The secondary sanctions exposure for foreign persons is already robust under Iran-specific statutes, in many cases more extensive than what flows from EO 13224/13886 alone
- The blocking mechanism is already fully in place
- The reputational harm is already substantial — though the “terrorist” label does add a specific stigma
In short: for an Iran designee, the SDGT overlay is a real upgrade in terms of criminal law exposure (material support) and civil litigation risk (ATA), but it adds relatively little on the financial sanctions and secondary sanctions dimensions, where Iran already does heavy lifting.
Adding CT to a Counter-Narcotics Designation: Marginal Impact
The counter-narcotics baseline is structurally thinner. The Foreign Narcotics Kingpin Designation Act and the resulting Foreign Narcotics Kingpin Sanctions Regulations derive directly from a statute rather than an executive order — in several respects quirky vis-à-vis the typical IEEPA-based blocking regulation. The Kingpin Act establishes blocking and U.S. person prohibitions against the designee, but it is fundamentally a targeted blocking program without the country-level architecture or the statutory secondary sanctions depth of the Iran program.
Notably, SDN entries for Kingpin/narcotics designees (
[SDNTK]) do not carry the “Secondary sanctions risk: section 1(b) of Executive Order 13224” language that SDGT entries do — that language is specific to the CT designation. Narcotics entries also do not carry the “Subject to Secondary Sanctions” language that Iran-program entries carry. This is an important baseline difference.When the SDGT tag is added to a counter-narcotics designee, the incremental impact is substantially larger than in the Iran case:
What CT meaningfully adds to a narcotics designation:
- Secondary sanctions against foreign persons — this is a major addition. Non-U.S. persons who engage in prohibited transactions with SDGTs may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable-through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT. The Kingpin Act doesn’t carry this lever; CT does.
- Material support criminal statutes — same as in the Iran case, but even more consequential here because the narcotics program had no equivalent criminal overlay
- ATA/JASTA civil litigation exposure — entirely new for a narcotics designee; the ATA is terrorism-specific
- BIS no-license-exception export rule — tied specifically to SDGT status
- The “terrorist” label and its political/diplomatic weight, which transforms the foreign policy signal from “drug trafficker” to “terrorist” — a much more significant diplomatic instrument with implications for how allied governments treat the designee
- Contagion risk under CT authority — the 50% rule could increase the number of individuals and entities that are blocked pursuant to CT designations, even if not listed on the SDN list themselves. While this rule applies to narcotics too, the CT framework’s broad “associated with” nexus for new designations is more expansive
- Heightened compliance scrutiny — this results in increased legal and operational risks for human rights and social services organizations and nonprofits who must interact with these groups. The CT framework activates compliance concerns in sectors that may be comfortable doing business with parties adjacent to narcotics trafficking (e.g., banks in certain jurisdictions) but that draw a hard line at terrorism
What CT does not add to a narcotics designation:
- The core blocking mechanism is already present under the Kingpin Act
- The “50% rule” already applies under the narcotics program
The Bottom Line Comparison
Dimension CT added to Iran CT added to Narcotics Asset blocking Already covered; no material change Already covered; no material change U.S. person prohibitions Already covered Already covered Secondary sanctions on foreign persons Marginal addition — Iran statutes already more powerful Major addition — not present under Kingpin Foreign subsidiary compliance extension Already covered under Iran (31 CFR § 560.215) Not applicable; no change Material support criminal statutes Meaningful addition — Iran doesn’t trigger these Major addition — entirely new legal exposure ATA/JASTA civil suits Meaningful addition Major addition — entirely new BIS export controls (no license exception) Meaningful addition Major addition “Terrorist” label / diplomatic signal Adds specificity to what Iran designation implies Qualitative transformation of the designation’s meaning National security apparatus activation Meaningful addition Major addition The pattern is clear: adding CT to a narcotics designation is a much larger step than adding it to an Iran designation. Iran sanctions already impose much of what CT brings on the financial side, and in some respects (sector-wide prohibitions, statutory secondary sanctions depth, foreign subsidiary obligations) Iran goes further than CT ever could on its own. What CT adds to Iran is primarily in the criminal law and civil litigation domains — significant, but incremental.
For a narcotics designee, by contrast, the CT overlay brings an entirely new dimension of secondary sanctions exposure, a new criminal regime, and a qualitative recharacterization that changes how every third party — governments, financial institutions, NGOs, businesses — has to think about the person.
The current administration’s expansion of CT authorities to encompass transnational criminal organizations traditionally dealt with through counter-narcotics frameworks is itself a reflection of this dynamic — layering CT on top of narcotics designations is a meaningful escalation tool precisely because it adds so much that the narcotics program lacks.
Sources
- OFAC — Counter Terrorism Sanctions FAQ: ofac.treasury.gov/faqs/topic/2396
- OFAC — Counter Terrorism Sanctions program page: ofac.treasury.gov/sanctions-programs-and-country-information/counter-terrorism-sanctions
- OFAC — Counter Narcotics Trafficking Sanctions program page: ofac.treasury.gov/sanctions-programs-and-country-information/counter-narcotics-trafficking-sanctions
- OFAC — Basic Information FAQ: ofac.treasury.gov/faqs/topic/1501
- eCFR, 31 CFR Part 598: ecfr.gov
- State Department — EO 13224 overview: state.gov
- ICNL — Federal Terrorism Law Explainer: icnl.org
- ACLU — SDGT Designation Briefer: assets.aclu.org
- Baker Botts — FTO/SDGT Compliance Alert (Jan. 2025): bakerbotts.com
- Jones Day — Cartel FTO/SDGT Risk Alert (Feb. 2025): jonesday.com
- WilmerHale — EO 14157 Implications (Apr. 2025): wilmerhale.com
- WilmerHale — Understanding Different Terrorism Designations (Oct. 2025): wilmerhale.com
- Carter Ledyard & Milburn — OFAC SDN List Overview: clm.com
- Charity & Security Network — Cartel SDGT Alert (Apr. 2025): charityandsecurity.org
- Global Investigations Review — U.S. Sanctions Perspective (2026 ed.): globalinvestigationsreview.com
- Turbofac — FNKDA annotations: sanctions.org
- Federal Register — Narcotics Sanctions Regulations amendment (May 2021): federalregister.gov
Mr. Sanctions’ Note: I made the conscious decision not to restate this in plain language for non-experts. I knew this was kind of intricate and really for more experienced and expert practitioners. If you’d like a plain language version of this, let me know – happy to put Claude to work.