On October 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published an alert (the “Alert”) warning that foreign financial institutions (“FFIs”) that continue to transact with sanctioned Iranian financial institutions “could be targeted at any time without advance notification.” OFAC also amended Iran-related FAQ 156 to remove earlier language indicating that OFAC would generally contact an FFI about its conduct before making a finding that the FFI knowingly engaged…
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 July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of Iran-related sanctions designations targeting Iranian financial facilitator Ali Ansari and his financial network, as well as several Iranian exchange houses accused of facilitating transactions for sanctioned Iranian banks. Concurrently, OFAC issued General License Y (“GL Y”), authorizing the temporary wind down of transactions involving Smart Global Limited, a newly designated holding company allegedly controlled by Ansari.…
On July 7, 2026, the US Treasury Department’s Office of Foreign Assets Control revoked Iran General License X (“GL X”), which would have otherwise been valid through August 21, 2026. GL X was issued in June to authorize the production, delivery, and sale of Iranian crude, petrochemical products, and petroleum products. See our earlier summary here. OFAC replaced GL X with a narrow wind-down authorization issued as Iran General License X1 (“GL X1”). Under GL…