Key developments included:
➡️ Expanded Secondary Sanctions: Treasury expanded secondary sanctions exposure for entities and foreign financial institutions facilitating Iran-related activity;
➡️ Five New Sectoral Determinations: The Office of Foreign Assets Control (OFAC) expanded sanctions across digital assets, technology, gold, aviation and shipping, enabling action against foreign persons operating in or supporting these sectors of the Iranian economy;
➡️ Nearly 60 New Targets: OFAC sanctioned nearly 60 entities, individuals and vessels linked to nuclear and missile procurement, cyber operations, oil revenues and sanctions evasion;
➡️ General Licence Changes: OFAC suspended several general licences covering certain remittance payments and issued additional guidance on sanctions risks associated with shipping in the Strait of Hormuz; and
➡️ Heightened Enforcement Risk: Foreign financial institutions may face secondary sanctions for knowingly conducting or facilitating certain significant transactions involving the designations.
✅ Financial institutions (FIs) should review the designations and the newly designated sectors against their customer and counterparty base, screen for exposure to the identified networks, brokers and shadow fleet vessels, and consider the secondary sanctions risk associated with any Iran-related activity, including transactions processed through or on behalf of foreign financial institutions.
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