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OFAC General License

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The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has restructured the location of penalty and enforcement procedure provisions within its regulations. On September 25, 2026, OFAC published a final rule creating 31 CFR Part 505, the Sanctions Penalties Regulations. Then, on September 30, 2026, OFAC issued a second related rule removing superseded penalties provisions and reorganizing remaining parts. These regulatory updates memorialize OFAC’s existing practices with enforcement matters but do not…

Earlier this month, as part of Operation Economic Outcast targeting Iran, the US Department of the Treasury ushered in a flurry of administrative and regulatory changes. On September 10, 2026, the Office of Foreign Assets Control (“OFAC”) modified its Iran-related specific licensing policy, announced a settlement agreement, and updated the Specially Designated Nationals and Blocked Persons List (“SDN List”). These changes landed two days after OFAC’s September 8, 2026 action against Iran’s aviation sector, which…

On September 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the expiration of the national emergency declared in Executive Order 14046 of September 17, 2021, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia” (“EO 14046”), and removed persons designated under that order from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Department of State published…

On August 24, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) launched Operation Economic Outcast, a campaign that OFAC has characterized as an “economic D-Day” against Iran. The action follows OFAC’s earlier “Economic Fury” campaign against Iran, on which we have previously reported here and here. OFAC stated these actions “mark the beginning of a sustained and systematic campaign to close every financial resource that supports the leading state sponsor…