GL-131E
OFAC-designation reference cited in the sb0477 shadow-banking action against Iran.
Last refreshed: 30 April 2026 · Appears in 1 active topic
What exactly is being designated in the OFAC shadow-banking action, and who is it targeting?
Timeline for GL-131E
Issued authorising negotiations to sell Lukoil International GmbH with no Iran component
Iran Conflict 2026: First Iran-free OFAC day of the warMentioned in: OFAC sb0477 hits Iran shadow banking
Iran Conflict 2026- What is OFAC sb0477 and what does it target?
- OFAC sb0477 'Economic Fury Targets Iran Shadow Banking Facilitators' was issued 28 April 2026, designating 35 entities and individuals involved in Iran's shadow banking architecture under Executive Orders 13902 and 13224.Source: OFAC
- How does Iran move money to avoid US sanctions?
- Iran uses a network of front companies, informal money changers, and shell entities across multiple jurisdictions to route payments outside dollar-clearing systems. OFAC sb0477 targeted 35 such facilitators in its 28 April 2026 action.Source: OFAC
- What is GL-131E and what does it authorise?
- GL-131E is an OFAC general licence issued 29 April 2026 authorising negotiations to sell Lukoil International GmbH, a Russian entity. It was the only OFAC action on 29 April, making it the first Russia-only day of the Iran war, breaking a six-week weekly Iran sanctions cadence.Source: OFAC
- Why was 29 April 2026 significant for Iran sanctions?
- On 29 April 2026 OFAC issued only GL-131E, a Russia-related licence for Lukoil International GmbH, with no Iran action. It was the first Russia-only day of the war, breaking the weekly Iran OFAC cadence that had run since February 2026.Source: OFAC
Background
GL-131E is a reference number appearing in OFAC's 28 April 2026 press release sb0477, 'Economic Fury Targets Iran Shadow Banking Facilitators'. The action designated 35 entities and individuals across Iran's shadow banking network, citing Executive Orders 13902 and 13224 as the legal basis. The designation targets the architecture of front companies, money-changers, and financial intermediaries used to move Iranian funds outside the formal banking system and beyond dollar-rail visibility.
The sb0477 action used the framing of Economic warfare rather than targeted financial enforcement, the same rhetorical register Hegseth deployed in his HASC Posture Statement the following morning. GL-131E represents one designation element within that broader action. The sanctions architecture it sits within is designed to collapse the informal payment rails that allow Iran to export oil and receive payment without touching dollar-denominated correspondent banking.
The timing of sb0477, issued one day before the 29 April Hegseth filing, reflects a coordinated Treasury-Pentagon messaging cadence: Treasury struck the financial infrastructure while the Pentagon disclosed the war's cost and formalised its branding in the same 24-hour window.
