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OFAC
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OFAC

US Treasury sanctions bureau administering SDN designations across Iran, Russia, Cuba and cyber-threat programmes.

On 8 September, OFAC designated 27 Iranian airlines and suspended General Licence J-1. The US Treasury bureau's latest Iran action sits beside a widening Cuba designation campaign, showing how its blacklists and licences operate across programmes.

Last refreshed: 22 September 2026 · Appears in 5 active topics

Key Question

What does OFAC's new Reconsideration Portal mean for Russian oil sanctions relief?

Timeline for OFAC

#28 9 Oct

Issued General License 135 authorising Russian diesel imports

Russia-Ukraine War 2026: OFAC opens US market to Russian diesel
#180 30 Sept

Published the General Licence X texts and the codifying rule on 30 September

Iran Conflict 2026: OFAC publishes the licence it revoked
#180 29 Sept

Designated ten nodes of the procurement network under Executive Order 13382

Iran Conflict 2026: Treasury names 10 Iran missile suppliers
View full timeline →

Background

OFAC is the US Treasury bureau that administers and enforces American economic sanctions. It maintains the Specially Designated Nationals list, designates people and organisations under programme authorities, and issues licences that define lawful exceptions or wind-down periods. Its work spans Iran, Russia, Cuba, North Korea and cyber-threat programmes.

The bureau turns sanctions policy into operating rules for banks, insurers, shippers and other firms exposed to the US financial system. A designation can block dealings with a named party, while a general licence can permit narrowly defined transactions for a stated purpose or period. On 14 July, OFAC paired designations of tankers and Iran's central bank with General Licence Z for winding down existing cargo deals.

This combination of listing and licensing gives OFAC practical influence over transactions that touch US dollars, US banks or US-connected businesses. Its authority also reaches supply chains: on 15 July, it designated a network accused of procuring weapons parts for Iran's Revolutionary Guard, including Russian nationals and a Moscow firm.

Key Issues
Iran aviation

OFAC closes Iran aviation relief

OFAC used Executive Order 13902 on 8 September to blacklist 27 Iranian airlines plus nine overseas intermediaries. It suspended General Licence J-1 and issued General Licence DD for firms unwinding temporary aircraft-sojourn dealings.

On 10 September, its licensing division began presuming denial of Iran-specific applications, retaining only legally compelled approvals and safety cases involving life, limb or the environment. For OFAC, the combined measures narrowed a prior exception regime while setting defined exit routes for outstanding aviation business.

Iran finance

OFAC targets a banking route

On 4 September, OFAC designated Golden Global Yatirim Bankasi and two affiliates, alleging links to transactions for the Islamic Revolutionary Guard Corps Qods Force and correspondent-banking access. General Licence CC gave counterparties until 19 September to unwind existing business.

OFAC's action turned an alleged financing route into a compliance Deadline for the bureau's counterparties. On 8 September, Golden Global closed three funds to new subscriptions after saying they were legally separate from its sanctioned parent bank. The case shows how an OFAC designation can reach beyond the named institution into related financial products.

Cuba sanctions

OFAC reaches Cuban intermediaries

On 3 September, OFAC designated Cuba's state trade-finance bank, four fuel and mining traders, and Fidel Ernesto Castro Calis. It issued General Licence 4A on the same day, easing an embassy carve-out.

That pairing shows the bureau can distinguish between targets and permitted dealings inside one programme. On 20 August, OFAC directly designated Cuba's Ministry of Construction alongside the nickel-mining monopoly and two trading firms. From OFAC's perspective, the campaign extends its target set from commercial companies into state institutions and their intermediaries.

Common Questions

Cuba sanctions net keeps widening

What did OFAC do to Cuba on 13 July 2026?
The State Department designated ten Cuban entities under Executive Order 14404, the largest single-day batch since the 18 May wave. OFAC's same-day FAQ 1262 gave two of them, GECOMEX and GEMAR, a 30-day wind-down to 12 August, but issued no guidance for the tourism ministry MINTUR.Source: OFAC FAQ 1262, 13 Jul 2026

Reference

What is the SAIRAN OFAC designation and why does it matter?
On 29 May 2026 OFAC designated SAIRAN (trading as SAAFTA), a MODAFL-controlled procurement ring that impersonated US small businesses to obtain spectrum analysers and counter-surveillance hardware from American IT vendors. The action opened a criminal wire-fraud track alongside the existing oil-sanctions programme and came with a $15m State Department Rewards for Justice bounty on IRGC financial networks.Source: OFAC
What is OFAC General Licence 131G and what does it mean for ISAB Priolo?
GL-131G, issued 25 June 2026, authorised Lukoil International GmbH (and entities in which it holds 50%+) to negotiate the sale of its remaining European refining assets through 25 July 2026. It does not name ISAB, Priolo Gargallo or Italy: Litasco sold ISAB to GOI Energy in May 2023, and ISAB's live sale is GOI Energy to Ludoil Energy, gated by Italian Golden Power clearance and a Milan court seizure order, plus its own separate OFAC transaction licence, not the Lukoil GL-131 series. On 24 July 2026 OFAC amended FAQ 1224, setting three conditions for any future Lukoil International GmbH sale licence: complete severance from Lukoil, residual funds blocked in a US-jurisdiction account, and no windfall via asset or share swaps. Whether GL-131G itself was renewed past its 25 July expiry has not been confirmed.Source: Lowdown European Oil Markets
What is OFAC and how does it enforce sanctions?
OFAC (Office of Foreign Assets Control) is the US Treasury bureau that administers economic sanctions via the SDN list and general licences. Its reach covers any company using US dollars or clearing through US banks, giving it effective global jurisdiction regardless of where a firm is based.Source: editorial
Is OFAC's General Licence 131H a replacement for the lapsed Russia crude-oil waiver?
No. General Licence 131H, issued 24 July 2026, covers payment for legal services and replaces a reporting requirement with a recordkeeping one. It is not a successor to the lapsed GL 134C crude-oil waiver, and OFAC had issued no replacement for that waiver as of early August 2026.Source: US Treasury OFAC
Has OFAC issued an Iran sanctions waiver after the Islamabad MOU?
No waiver has followed the Islamabad MoU. If anything the opposite occurred: OFAC's General Licence X1, issued 7 July 2026, revoked the existing Iranian oil waiver (General Licence X) early rather than extending it.Source: OFAC recent-actions record
What is the PGSA and why did OFAC sanction it?
The Persian Gulf Strait Authority is the IRGC toll-collection body created on 5 May 2026. OFAC designated it under EO 13224 (counterterrorism) on 28 May, meaning any vessel coordinating with it would deal with a sanctioned entity regardless of the Islamabad MoU's reopening terms.Source: OFAC sb0502/EO 13224
Has OFAC sanctioned Chinese companies over Iran oil purchases?
Yes. OFAC designated Hengli Petrochemical (Dalian) on 24 April 2026 — the largest single-entity Chinese designation of the conflict — and CGSTL on 8 May. Mainland Chinese refineries otherwise remained off the SDN list through May 2026; OFAC targeted Hong Kong-registered shells instead to avoid triggering MOFCOM Blocking Rules.Source: OFAC
What happened when OFAC General License U expired in April 2026?
General License U, covering 325 tankers carrying $31.5 billion of Iranian crude, lapsed at 00:01 EDT on 19 April 2026 with no renewal. On the same day Treasury extended Russia's seaborne crude waiver (GL-134B) — creating the first signed Russia-yes, Iran-no asymmetry in US sanctions policy.Source: OFAC
Is General Licence Z the same as General Licence X1?
No. General Licence X1 winds down the revoked Iranian oil waiver, General Licence X, through 17 July 2026. General Licence Z is a separate licence OFAC issued on 14 July 2026 covering wind-down, safety and cargo-offloading transactions only for parties newly blocked that day.Source: OFAC recent-actions record, 14 Jul 2026
What did OFAC do to Iran on 14 July 2026?
OFAC designated more than 50 individuals, entities and vessels, including roughly 28 ships tied to Mohammad Hossein Shamkhani's shipping network, plus crypto addresses linked to Bank Markazi, Iran's central bank, and issued a new wind-down licence, General Licence Z, for the newly blocked parties.Source: OFAC recent-actions record, 14 Jul 2026
How long has the US crude oil waiver for Russia been lapsed?
General License 134C expired 17 June 2026 with no successor. As of 13 July the gap has reached 26 days, the longest of the war, up from 15 days on 1 July. No Treasury statement accompanies the lapse; it is inferred from the absence of a new licence.Source: S&P Global
How does OFAC's new Reconsideration Portal work for companies on the SDN list?
Launched 29 June 2026 (FAQ 1261), the portal allows parties across all OFAC sanctions programmes to apply for SDN removal through a streamlined reconsideration process rather than a full de-novo licensing application. It is a procedural Reform, not a sanctions-relief signal.Source: Lowdown European Oil Markets
Why did OFAC sanction a Chinese satellite company over Iran?
On 8 May 2026, OFAC designated Chang Guang Satellite Technology (CGSTL) under IRAN-CON-ARMS-EO authority for supplying satellite imagery that supported IRGC military operations. It was the first extension of arms-grade Iran sanctions to a Chinese commercial space firm, creating compliance risk for every CGSTL customer globally.Source: OFAC
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