OFAC

The Office of Foreign Assets Control (OFAC) is the US Treasury Department bureau responsible for administering and enforcing economic sanctions based on US Foreign Policy and national security goals. It maintains the Specially Designated Nationals (SDN) list and issues general licences that create targeted exemptions within broader sanctions regimes. OFAC's reach extends beyond US borders: any company transacting in dollars, clearing through US banks, or doing business with US-connected firms falls within its effective jurisdiction, making it an instrument of global rather than bilateral economic pressure.

In 2025-26 OFAC ran simultaneous enforcement programmes across Iran, Russia, Cuba, North Korea, and cyber-threats. Its enforcement method has shifted from commodity-buyer designations toward upstream supply-chain interdiction: satellite imagery firms, shadow-banking networks, defence-electronics procurement rings, and logistics nodes are now targeted alongside oil buyers. The SDN list and accompanying general licences are managed in parallel, sometimes creating signed asymmetries (one programme extended while another lapses on the same calendar day) that carry as much policy signal as the designations themselves.

OFAC's Iran programme escalated sharply through April-May 2026. General License U, covering up to 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) to 16 May, producing the first Russia-yes, Iran-no asymmetry in signed US policy text. On 28 April, OFAC's sb0477 'Economic Fury' round designated 35 entities and individuals linked to Iran shadow banking. On 8 May, OFAC designated Chang Guang Satellite Technology (CGSTL), China's largest commercial SAR satellite operator, under IRAN-CON-ARMS-EO authority: the first extension of arms-grade Iran sanctions to a Chinese commercial space firm. Through mid-May, four consecutive Economic Fury rounds targeted Hong Kong-registered shells while leaving mainland Chinese refineries untouched: a calibration exploiting the gap between MOFCOM Blocking Rules, which constrain action against mainland firms, and HK-registered companies, which carry no such protection.

On 28 May, OFAC simultaneously designated Iran's Persian Gulf Strait Authority (PGSA) under EO 13224 (counterterrorism authority) on the same day US-Iranian negotiators reached a tentative Strait of Hormuz MOU, creating an immediate legal contradiction: any vessel coordinating with PGSA under a reopened strait would transact with a sanctioned entity. On 29 May, OFAC's sb0515 round designated a MODAFL-controlled defence-electronics procurement ring for impersonating US small businesses to obtain spectrum analysers and counter-surveillance hardware, re-exported via two Dubai front companies; the State Department posted a $15 million Rewards for Justice bounty on IRGC financial networks.

Through 18 June 2026, OFAC issued no Iran waiver, general licence, or delisting. Its published actions on 18 June covered Counter-Terrorism and Cuba only. The Islamabad memorandum text confirms full sanctions relief is contingent on a "final agreement on a schedule to be agreed"; only oil-transaction waivers apply "immediately upon signing." Secretary of State Marco Rubio told Congress on 2 June the US "is not discussing, nor has it offered, sanctions relief for Tehran" and had not walked that back as of 19 June. The PGSA designation simultaneously creates a legal snare for any commercial operator seeking to use the reclassified toll corridor envisaged in the MOU. On 17 June, OFAC's General Licence 134C for Russian seaborne crude vessel services lapsed clean with no successor instrument, removing Western P&I clubs and classification societies' last authorised cover on Russian-origin cargoes outside narrow wind-down provisions.

OFAC's two June 2026 actions extended and reorganised its Russia-oil posture without new SDN designations. On 25 June, it issued General Licence 131G, the seventh consecutive monthly extension of the Lukoil International GmbH sale-negotiation window, authorising the ISAB/Priolo refinery transaction through 25 July 2026. On 29 June, OFAC launched a new all-programmes Reconsideration Portal (FAQ 1261), enabling parties across all sanctions regimes to apply for SDN removal without a full de-novo licensing application. Both moves are administrative: no new oil-specific SDN listing was issued this window, and the portal is a case-management efficiency reform applicable across Iran, Russia, Cuba, and cyber-threat programmes alike, not a Russia-oil policy retreat. The next ISAB decision point falls at 25 July 2026.

The vessel-services gap Left by GL-134C's clean lapse has persisted through the summer: by 13 July 2026 no successor had been issued and the lapse had reached 26 days, the longest of the war, up from 15 days on 1 July. No Treasury statement accompanies the gap; it is read from the absence of any new licence in OFAC's recent-actions listings, the same inferred-from-absence pattern that marked GL-134C's original expiry, not from a stated policy decision. This is distinct from GL-131G, which continues to govern the separate Lukoil/ISAB sale-negotiation window through 25 July.