OFAC

The Office of Foreign Assets Control (OFAC) is the US Treasury Department bureau responsible for administering and enforcing economic and trade sanctions based on US Foreign Policy and national security objectives. 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 entities — any company transacting in dollars, clearing through US banks, or doing business with US-connected firms falls within its effective jurisdiction, making it a lever of global rather than bilateral economic pressure.

In April-May 2026, OFAC ran three active conflict programmes simultaneously. On Iran: General License U, covering 325 tankers carrying $31.5 billion of Iranian crude, lapsed at 00:01 EDT on 19 April with no renewal; on the same calendar day Treasury signed GL-134B extending Russia's seaborne-oil waiver to 16 May, producing the first Russia-yes, Iran-no asymmetry in signed US policy text . On 28 April, OFAC published sb0477 'Economic Fury Targets Iran Shadow Banking Facilitators', designating 35 entities and individuals — the first time OFAC deployed a 'fury' rhetorical register, mirroring Operation EPIC FURY military branding . On 8 May, OFAC added eight entities and three individuals under IRAN-CON-ARMS-EO authority, including Chang Guang Satellite Technology (CGSTL), China's largest commercial SAR satellite operator — the first extension of arms-grade Iran sanctions to a Chinese commercial space-imaging firm, a structural precedent that creates compliance exposure for every CGSTL customer globally . Then on 29 April, OFAC issued only GL-131E, authorising the Lukoil International GmbH sale — a Russia instrument with no Iran component — the first Russia-only OFAC day of the war, signalling a cadence break.

On 11 May 2026, OFAC's next Economic Fury round designated three individuals and nine entities including Universal Fortune Trading LLC (Dubai, direct NIOC link) and four Hong Kong-registered shells: Hong Kong Blue Ocean Limited, Jiandi HK Limited, Max Honor International Trade Co. Limited, and a fourth entity. The HK targeting exploited a deliberate gap in mainland China enforcement ahead of the Trump-Xi summit; MOFCOM Blocking Rules constrain OFAC action against mainland Chinese refineries but do not extend to HK-registered companies. The cumulative pattern across four Economic Fury rounds — CGSTL/CITC (8 May, ID:3168), NFRA Hengli (24 April, ID:3160), HK shells (11 May) — shows OFAC systematically mapping and designating each node of the IRGC crude-distribution architecture before closing the next. The supply-chain mapping pattern is now visible across both the Iran and Russia programmes: OFAC is systematically designating upstream technology providers (satellite imagery, precision components, shadow-banking networks) rather than primary commodity buyers alone.