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 14, 2026, OFAC announced additional designations targeting the shipping and commercial network allegedly controlled by Mohammad Hossein Shamkhani (“Shamkhani”), i.e., the son of Ali Shamkhani, a top political advisor to the Supreme Leader of Iran. OFAC also issued General License Z (“GL Z”), authorizing the temporary wind down of transactions involving certain persons and vessels targeted by those designations.
OFAC Designations
OFAC’s designations were imposed pursuant to Executive Order (“EO”) 13876 (related to the Supreme Leader of Iran, state officials appointed by the Supreme Leader, and affiliated persons), EO 13902 (related to Iran’s financial and petroleum sectors), and EO 13224, as amended (related to counterterrorism). This included:
- Ali Ansari and Smart Global Limited: OFAC designated Ali Ansari, a Dubai-based Iranian businessman alleged to be a key financial facilitator for Mojtaba Khamenei, other senior Iranian regime figures, and the Islamic Revolutionary Guard Corps (“IRGC”). According to OFAC, Ansari used his control of the now-defunct Ayandeh Bank and a network of shell companies to amass a global property and investment portfolio on behalf of regime elites. OFAC also designated Smart Global Limited, a Saint Kitts and Nevis holding company allegedly controlled by Ansari with real estate and commercial investments across Europe and the Middle East. Ansari was designated pursuant to both EO 13876 and EO 13224, reflecting OFAC’s allegations that he supports Mojtaba Khamenei and acts on behalf of the IRGC.
- Iranian Exchange Houses: OFAC designated three Iranian exchange houses (i.e., Mohammad Darbani and Partners Exchange General Partnership Company, Lavasani and Partners General Partnership Company, and Mohsen Khandan and Partners General Partnership Company), which allegedly facilitated large-scale foreign currency transactions for sanctioned Iranian banks. According to OFAC, the exchange houses collectively move billions of dollars annually on behalf of sanctioned Iranian financial institutions and provide access to foreign currency and international payment channels. OFAC also designated the entities’ controlling partners and senior executives pursuant to EO 13902 for operating in the financial sector of the Iranian economy.
- Third-Country Front Companies: OFAC designated CDM Trading Limited (Hong Kong) and Naba Alzaki Raw Materials Trading LLC (UAE), which allegedly facilitated transactions for Iranian exchange houses and helped conceal the involvement of sanctioned Iranian parties. Both parties were designated under EO 13902 for operating in the financial sector of the Iranian economy.
- Shamkhani Network: OFAC designated more than 50 individuals, entities, and vessels connected to Shamkhani’s network. This action builds on OFAC’s April 2026 and July 2025 designations and further focuses on Shamkhani’s shipping network, which allegedly serves as a major enabler behind Iran’s oil exports. These parties were designated under EO 13902 for operating in certain sectors of the Iranian economy and for activities in support of certain individuals designated under this authority, including Shamkhani.
OFAC General Licenses
Concurrent with the above designations, OFAC issued GL Y and GL Z on July 10 and July 14, 2026, respectively.
- General License Y: GL Y authorizes transactions ordinarily incident and necessary to the wind down of transactions involving Smart Global Limited and any entity in which it owns, directly or indirectly, a 50% or greater interest. Any payments to blocked persons made pursuant to GL Y must be deposited into a blocked account, and the authorization does not extend to transactions involving other blocked persons unless they are separately authorized by OFAC. The authorization remains in effect through 12:01 a.m. EST on August 9, 2026.
- General License Z: GL Z authorizes transactions ordinarily incident and necessary to the wind down of financial transactions involving certain newly designated persons and vessels, as well as activities related to the safe docking, anchoring, and departure of designated vessels; crew health and safety; emergency repairs and environmental protection measures; and the delivery and offloading of cargo loaded on designated vessels on or before July 14, 2026. Any payments to blocked persons made pursuant to GL Z must be deposited into a blocked interest-bearing account in the United States, and the authorization does not extend to otherwise prohibited transactions. The authorization remains in effect through 12:01 a.m. EST on September 12, 2026.
The issuance of GL Y and GL Z suggests that OFAC recognizes that newly designated persons, companies, and vessels may be integrated into ongoing commercial, financial, and maritime operations. By issuing time-limited wind-down authorizations, OFAC is providing counterparties, financial institutions, insurers, port operators, and other service providers with a limited opportunity to disengage pre-existing commercial arrangements from newly prohibited activities while minimizing disruption to commercial relationships, maritime safety, and environmental protection activities.
