On August 24, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced numerous actions related to Iran sanctions. These actions are deemed “Operation Economic Outcast” and are meant to align with changes in the foreign policy of the United States towards Iran.
On the same day, the U.S. Department of State also designated nearly 60 entities, individuals, and vessels for enabling “the Iranian regime’s illicit procurement, cyber operations, and petroleum and petrochemical product revenue generation networks.” The State Department issued its own press release and fact sheet.
Determination Pursuant to Executive Order 13902
As previously discussed, Executive Order 13902 expanded secondary sanctions on Iran to include “significant” or “material” support transactions between non-U.S. persons and Iran’s construction, mining, manufacturing, and textiles sectors as potentially sanctionable transactions. Executive Order 13902 also authorized the U.S. Secretary of the Treasury to extend these secondary sanctions to additional sectors of Iran’s economy in its discretion after consulting with the U.S. Secretary of State. On August 24, 2026, OFAC issued a determination extending secondary sanctions to five additional sectors: Aviation; Digital Assets; Gold; Shipping; and Technology. OFAC’s determination did not provide specific definitions for these sectors. Under the determination, OFAC now has the discretionary authority to designate persons operating in these Iranian sectors.
OFAC is also issuing a new rule, effective August 24, 2026, indefinitely suspending five general licenses that were issued pursuant to the Iranian Transactions and Sanctions Regulations (“ITSR”) and the Iranian transactions sanctions program. However, in connection with this suspension, OFAC has issued General License BB which authorizes all transactions, otherwise prohibited by Executive Order 13902, that are “ordinarily incident and necessary to the wind down” of transactions under the suspended licenses through 12:01 a.m. eastern time, September 8, 2026. The suspended general licenses are:
- 31 C.F.R. 560.544 – Certain educational activities by U.S. persons in third countries authorized
- 31 C.F.R. 560.550 – Certain noncommercial, personal remittances to or from Iran authorized
- 31 C.F.R. 560.554 – Importation and exportation of services related to conferences in the United States or third countries authorized
- Iran General License G – Certain academic exchanges and the exportation or importation of certain educational services authorized
Separately, OFAC also issued General License AA, which authorizes all transactions “ordinarily incident and necessary to the wind down of any transaction, or the maintenance of operations, contracts, or other agreements” that involve La Nivernaise De Raffinage SAS, or any entity in which the company owns, directly or indirectly, a 50 percent or greater interest. These transactions are authorized through 12:01 a.m. eastern time, October 23, 2026.
Finally, OFAC also issued an update to its May 1, 2026 sanctions alert, providing additional guidance in response to sanctions risks related to payments for or solicitation of guarantees from Iranian entities for safe passage through the Strait of Hormuz. The guidance warns that “U.S. and non-U.S. persons risk sanctions” by “making these payments to, or soliciting guarantees from, the Iranian regime for safe passage” and that “{t}hese risks exist regardless of payment method or structure.” Accordingly, Maritime Service Providers are strongly encouraged to conduct enhanced due diligence on any vessels that attempt to transit the Strait of Hormuz to ensure that vessels do not engage in sanctionable conduct.
The Husch Blackwell International Trade and Supply Chain team continues to monitor developments related to U.S. sanctions on Iran and will provide updates as they become available. If you have questions, please contact Cortney Morgan, Grant Leach, or Eric Dama.