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 of terror.”
1. Expanded Secondary Sanctions Under EO 13902
OFAC issued a determination pursuant to Section 1(a)(i) of Executive Order 13902, targeting five additional sectors of the Iranian economy for secondary sanctions restrictions: aviation, digital asset, gold, shipping, and technology. These five sectors now sit alongside the previously identified financial and petroleum and petrochemical sectors of the Iranian economy under EO 13902. Under EO 13902, any person determined by the Secretary of the Treasury, in conjunction with the Secretary of State, to be operating in or knowingly engaging in a significant transaction involving any of the identified sectors is at risk of being designated as a Specially Designated National (“SDN”), irrespective of any US nexus.
2. Indefinite Suspension of Five Iran-Related General Licenses and Limited Wind-down
Effective August 24, 2026, OFAC indefinitely suspended the following general licenses under the Iranian Transactions and Sanctions Regulations (“ITSR”):
- 31 CFR 560.544, which authorized certain educational activities by US Persons in third countries;
- 31 CFR 560.550, which authorized certain noncommercial, personal remittances to or from Iran;
- 31 CFR 560.554, which authorized importation and exportation of services related to conferences in the United States or third countries;
- Iran General License F, which authorized certain services in support of professional and amateur sports activities and exchanges involving the United States and Iran; and
- Iran General License G, which authorized certain academic exchanges and the exportation or importation of certain educational services.
Concurrently, OFAC issued General License BB, allowing for all transactions ordinarily incident and necessary to the wind down of any transaction previously authorized by one or more of the above suspended general licenses only through 12:01 a.m. EDT, September 8, 2026, provided that any payment to a blocked person is made into a blocked interest-bearing account located in the United States.
The suspension of these general licenses will impact universities and academic institutions with Iranian student or faculty exchange arrangements, conference and event organizers, sports federations, and financial institutions processing noncommercial personal remittances that were previously authorized under the general licenses.
3. Additional SDN Designations
OFAC added more than 60 entities, individuals, and vessels in various jurisdictions to the SDN List in connection with Operation Economic Outcast. OFAC indicated that these parties “enable the Iranian regime’s recklessness, including illicit nuclear and missile technology procurement, cyber operations, and oil‑revenue generation networks.” These SDNs fall into three main groupings:
- A network of more than 20 entities and individuals across the Middle East and East Asia procuring proliferation-sensitive technology for ballistic missile development and nuclear research;
- A malicious cyber group responsible for compromises of US critical infrastructure and financially motivated cyber theft; and
- A network of brokers, companies, and shadow-fleet vessels operating across the UAE, Hong Kong, China, Singapore, Switzerland, Europe, and other regions to transport Iranian oil and channel revenue to the Islamic Revolutionary Guard Corps-Qods Force.
4. Updated OFAC Alert on the Strait of Hormuz
OFAC also published an update to its May 1, 2026, alert on the sanctions risks of Iranian demands related to efforts to pass through the Strait of Hormuz. The updated alert states that US and non-US persons risk sanctions or penalties by engaging with the so-called Persian Gulf Strait Authority, Persian Gulf Marine Insurance Company, or HormuzSafe Marine Services Authority, which are all SDNs, including by accepting insurance or other services or by responding to information demands for guarantees of safe passage. The update notes that these risks exist even where no payment or other exchange of value is involved, and regardless of the payment method or structure. OFAC strongly encourages maritime service providers to conduct enhanced due diligence on any vessel attempting to transit the Strait of Hormuz. Our previous blog post on OFAC’s guidance related to the Strait of Hormuz can be found here.
