• Iran-related Designations; Counter Terrorism Designations Updates

    Treasury Press Release: Economic Fury Targets Iranian LPG Smuggling and Shadow Banking Networks

    State Press Release: Sanctions to Strangle Iran’s Energy Smuggling and Illicit Financial Networks

    Additions:

    The following individuals have been added to OFAC’s SDN List:

    OFAC Program: [IRAN-EO13902]  Executive Order 13902

    GERAMIAN NIK, Mehrdad (Arabic: مهرداد گرامیان نیک)

    • AKA: GRAMIAN NIK, Mehrdad
    • Address: Tehran, Iran
    • DOB: 24 Aug 1964
    • POB: Tehran, Iran
    • Nationality: Iran
    • Alt. nationality: Dominica
    • Additional Sanctions Information – Subject to Secondary Sanctions
    • Gender: Male
    • Passport: V52959771 (Iran)
    • Alt. Passport: I73046943 (Iran)
    • Alt. Passport: RA051286 (Dominica)
    • National ID No.: 0041253825 (Iran)
    • Party Type: Individual
    • Linked to: MEHRDAD GERAMIAN NIK AND PARTNERS COMPANY

    Supplemental Information: Co-operates the family-run exchange house Mehrdad Geramian Nik and Partners Company (Geramian Exchange) alongside Romina Geramian Nik. Geramian Exchange has entered into contracts with sanctioned Iranian banks Bank Tejarat, Bank Mellat, and Bank Pasargad, and over the last several years facilitated transactions moving hundreds of millions of dollars in foreign currency on behalf of those banks. As of early 2026, Geramian Exchange held tens of millions of dollars’ worth of foreign currency on behalf of its sanctioned Iranian bank customers. Like many of his peers, Mehrdad Geramian Nik maintains foreign citizenship in Dominica, reportedly obtained through a citizenship-by-investment program, which enables Iran’s shadow banking actors to travel overseas, establish new companies, and access international banking networks.

    GERAMIAN NIK, Romina (Arabic: رومینا گرامیان نیک)

    • AKA: GRAMIAN NIK, Rumina
    • Address: Tehran, Iran
    • DOB: 09 May 1989
    • POB: Shemiran, Iran
    • Nationality: Iran
    • Additional Sanctions Information – Subject to Secondary Sanctions
    • Gender: Female
    • National ID No.: 0440054621 (Iran)
    • Party Type: Individual
    • Linked to: MEHRDAD GERAMIAN NIK AND PARTNERS COMPANY

    Supplemental Information: Co-operates the family-run Geramian Exchange alongside Mehrdad Geramian Nik.

    MIHANDOUST, Mohammad Shakol

    • AKA:
      • SHAKOOR, Haji Muhammad
      • SHAKOOR, Muhammad
    • Addresses:
      • United Arab Emirates
      • Turkey
    • DOB: 24 Nov 1982
    • POB: Chabar, Iran
    • Nationality: Turkey
    • Gender: Male
    • Passport: U23085392 (Turkey) expires 31 Jan 2030
    • Alt. Passport: U33171256 (Turkey) expires 20 Feb 2034
    • National ID No.: 18986951490 (Turkey)
    • Party Type: Individual

    Supplemental Information: A Turkish national also known as Haji Shakoor, Mihandoust operates a network of UAE-based front companies (Butani Trading LLC, Dundlod Trading FZE, and ADH Energy FZE) alongside Afghani national Sarbaz Abdul Zada, responsible for exporting millions of barrels of Iranian LPG to end users across South and East Asia, often falsely identifying it as Omani LPG to evade sanctions. Mihandoust owns and operates China-based Shanghai Qianye Energy Co., Ltd. In March 2026, ADH Energy FZE was used to sell and export millions of barrels of Iranian LPG to end users in Bangladesh. Mihandoust and Zada rely on Iran’s shadow fleet of vessels to illicitly transport Iranian LPG to foreign markets.

    ZADA, Sarbaz Abdul

    • AKA: BIN HAJJI MOLLA NUR, Sarbaz Abdul Zada (Arabic: سرباز عبدل بن حاجي مولانور)
    • Address: United Arab Emirates
    • DOB: 01 Jan 1977
    • Nationality: Afghanistan
    • Gender: Male
    • National ID No.: 122146116 (United Arab Emirates) expires 16 May 2032
    • Identification Number: 784-1977-2690971-2 (United Arab Emirates)
    • Party Type: Individual

    Supplemental Information: An Afghani national, Zada operates a network of UAE-based front companies alongside Turkish national Mohammad Shakol Mihandoust, responsible for exporting millions of barrels of Iranian LPG to end users in South and East Asia, often falsely labeled as Omani LPG to evade sanctions. Zada has also used UAE-based Sahel Star Oil and Gas Company LLC to ship Iranian LPG. Zada and Mihandoust rely on Iran’s shadow fleet of vessels to illicitly transport Iranian LPG to foreign markets.

    The following entities have been added to OFAC’s SDN List:

    OFAC Program: [IRAN-EO13902]  Executive Order 13902

    ADAMAS SHIPPING INC

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 21 Jun 2023
    • Identification Number: IMO 6420321
    • Business Registration Number: 120582 (Marshall Islands)

    Supplemental Information: Owns, manages, and operates the Panama-flagged LPG tanker GAS LAGOON (IMO 9386304), which has transported millions of barrels of Iranian LPG since 2023.

    ADH ENERGY FZE

    • Address: P5-ELOB, Office No E2-122G-10, Hamriyah Free Zone, Sharjah, United Arab Emirates
    • Website: http://www.adhenergyfze.com
    • Organization Established Date: 23 Jan 2025
    • Business Registration Number: 38672 (United Arab Emirates)

    Supplemental Information: A UAE-based front company operating in furtherance of Zada and Mihandoust’s Iranian LPG smuggling scheme. In March 2026, ADH Energy FZE was used to sell and export millions of barrels of Iranian LPG to end users in Bangladesh.

    BLACK GOLD TRADE CORPORATION

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 21 Aug 2024
    • Identification Number: IMO 0042360
    • Business Registration Number: 127595 (Marshall Islands)

    Supplemental Information: Owns the Panama-flagged LPG tanker MILE (IMO 8910897), which has transported millions of barrels of Iranian LPG since 2024.

    BLUE SEA MARINE INCORPORATED AND FAATEH MARITIME INCORPORATED

    • AKA: BLUE SEA MARINE INCORPORATED & FAATEH MARITIME INCORPORATED
    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 2024
    • Identification Number: IMO 0081438

    Supplemental Information: Owns, manages, and operates the St. Kitts and Nevis-flagged LPG tanker AMIR GAS (IMO 9167409), which has transported hundreds of thousands of barrels of Iranian LPG since 2025.

    BUTANI TRADING LLC

    • Address: Office No 481-02-SM1, Port Saeed, Deira, Dubai, United Arab Emirates
    • Organization Established Date: 21 Jun 2023
    • Commercial Registry Number: 2012881 (United Arab Emirates)
    • License: 1201861 (United Arab Emirates)
    • Chamber of Commerce Number: 468432 (United Arab Emirates)

    Supplemental Information: A UAE-based front company operating in furtherance of Zada and Mihandoust’s scheme. Has shipped tens of thousands of metric tons of Iranian LPG, worth tens of millions of dollars, to South Asia. In early 2025, used the MILE to ship over half a million barrels of Iranian-origin LPG to end users in Bangladesh.

    DUNDLOD TRADING FZE

    • Address: P6-ELOB, Office No. E2-121 F-55, Hamriyah Free Zone, Sharjah, United Arab Emirates
    • Organization Established Date: 06 Jan 2025
    • Business Registration Number: 38618 (United Arab Emirates)

    Supplemental Information: A UAE-based front company. In October 2025, delivered 22,000 metric tons of LPG to Bangladesh worth approximately $10.5 million USD using the LPG SEVAN. In May 2025, also delivered multiple shipments of LPG to Bangladesh using the GAS ZEINA, which has transported Iranian-origin LPG to Bangladesh since 2024.

    ECOSEAS MARITIME LIMITED

    • Address: 80 Broad Street, Monrovia, Liberia
    • Organization Established Date: 2020
    • Identification Number: IMO 6158030

    Supplemental Information: Owns the Panama-flagged LPG tanker GLENDALE (IMO 9139945), which has transported millions of barrels of Iranian LPG since 2020.

    GAS GMS LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 31 May 2023
    • Identification Number: IMO 6413451
    • Business Registration Number: 120290 (Marshall Islands)

    Supplemental Information: Owns the Panama-flagged LPG tanker GAZ GMS (IMO 9131539), which has transported hundreds of thousands of barrels of Iranian LPG since 2023.

    LIMRA GAS LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro 96960, Marshall Islands
    • Organization Established Date: 11 Apr 2023
    • Identification Number: IMO 6400813
    • Business Registration Number: 119426 (Marshall Islands)

    Supplemental Information: Owns, manages, and operates the Palau-flagged LPG tanker MD 23 (IMO 9158240), which has transported hundreds of thousands of barrels of Iranian LPG since 2023.

    MEHRDAD GERAMIAN NIK AND PARTNERS COMPANY (Arabic: شرکت مهرداد گرامیان نیک و شرکا)

    • AKA: MEHRDAD GERAMIAN NIK AND PARTNERS EXCHANGE
    • Address: No. 25, Ground Floor, Rose Commercial and Administrative Complex, Opposite the Central Bank, Mirdamad Boulevard, Tehran, Tehran, Iran
    • Additional Sanctions Information – Subject to Secondary Sanctions
    • Organization Established Date: 22 Feb 2011
    • National ID No.: 10320482405 (Iran)
    • Registration Number: 397342 (Iran)

    Supplemental Information: An Iran-based exchange house (Geramian Exchange) that has entered into contracts with sanctioned Iranian banks Bank Tejarat, Bank Mellat, and Bank Pasargad. Over the last several years, facilitated transactions moving hundreds of millions of dollars in foreign currency on behalf of those banks, and as of early 2026 held tens of millions of dollars’ worth of foreign currency on behalf of its sanctioned Iranian bank customers. OFAC has previously taken actions to dismantle Iran’s network of brokers, including against Radin Exchange, Arz Iran Exchange, Opal Exchange, and Amin Exchange. Iran’s foreign exchange system relies heavily on selected brokers and rahbar companies, which use overseas shell and front companies to conceal Iranian connections, bypass sanctions, and move funds through accounts typically held outside Iran.

    SAHEL STAR OIL AND GAS COMPANY LLC (Arabic: شركة ساحل ستار للنفط والغاز الطبيعي)

    • Address: Office No 3108-3109, Parcel Plot 346-485, Bur Dubai, Dubai, United Arab Emirates
    • Organization Established Date: 17 Oct 2021
    • License: 993937 (United Arab Emirates)
    • Business Registration Number: 11766762 (United Arab Emirates)
    • Linked to: ZADA, Sarbaz Abdul

    Supplemental Information: A UAE-based company that Sarbaz Abdul Zada has used to ship Iranian LPG.

    SHANGHAI QIANYE ENERGY CO., LTD. (Chinese Simplified: 上海千烨能源科技有限公司)

    • Address: Room 2701B, No. 99 Xianxia Road, Shanghai 200050, China
    • Organization Established Date: 12 Jul 2023
    • Commercial Registry Number: 310000401066334 (China)
    • Unified Social Credit Code (USCC): 91310000MACNLJYM25 (China)
    • Linked to: MIHANDOUST, Mohammad Shakol

    Supplemental Information: A China-based entity owned and operated by Mohammad Shakol Mihandoust.

    The following vessels have been added to OFAC’s SDN List:

    OFAC Program: [IRAN-EO13902]  Executive Order 13902

    AMIR GAS (V4WK5)

    • Vessel Type: LPG Tanker
    • Vessel Flag: St. Kitts and Nevis
    • Vessel Year of Build: 1998
    • Vessel Registration Identification: IMO 9167409
    • MMSI: 314550001
    • Party Type: Vessel
    • Linked to: BLUE SEA MARINE INCORPORATED AND FAATEH MARITIME INCORPORATED

    Supplemental Information: The St. Kitts and Nevis-flagged LPG tanker AMIR GAS has transported hundreds of thousands of barrels of Iranian LPG since 2025.

    GAS LAGOON (3E4737)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2008
    • Vessel Registration Identification: IMO 9386304
    • MMSI: 352002989
    • Party Type: Vessel
    • Linked to: ADAMAS SHIPPING INC

    Supplemental Information: The Panama-flagged LPG tanker GAS LAGOON has transported millions of barrels of Iranian LPG since 2023.

    GAZ GMS (3E4634)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 1997
    • Vessel Registration Identification: IMO 9131539
    • MMSI: 352002853
    • Party Type: Vessel
    • Linked to: GAS GMS LIMITED

    Supplemental Information: The Panama-flagged LPG tanker GAZ GMS has transported hundreds of thousands of barrels of Iranian LPG since 2023.

    GLENDALE (3FFP9)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 1996
    • Vessel Registration Identification: IMO 9139945
    • MMSI: 356634000
    • Party Type: Vessel
    • Linked to: ECOSEAS MARITIME LIMITED

    Supplemental Information: The Panama-flagged LPG tanker GLENDALE has transported millions of barrels of Iranian LPG since 2020.

    MD 23 (T8A5356)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Palau
    • Vessel Year of Build: 1998
    • Vessel Registration Identification: IMO 9158240
    • MMSI: 511101848
    • Party Type: Vessel
    • Linked to: LIMRA GAS LIMITED

    Supplemental Information: The Palau-flagged LPG tanker MD 23 has transported hundreds of thousands of barrels of Iranian LPG since 2023.

    MILE (3E4726)

    • Vessel Type: LPG Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 1991
    • Vessel Registration Identification: IMO 8910897
    • MMSI: 352002974
    • Party Type: Vessel
    • Linked to: BLACK GOLD TRADE CORPORATION

    Supplemental Information: The Panama-flagged LPG tanker MILE has transported millions of barrels of Iranian LPG since 2024. In early 2025, Butani Trading LLC used the MILE to ship over half a million barrels of Iranian-origin LPG to end users in Bangladesh.

    Amendments:

    The following changes have been made to OFAC’s SDN List:

    • OFAC Programs:
      • [FTO]  Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597
      • [SDGT]  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594; Executive Order 13224

    COMANDO VERMELHO

    • AKA: “RED COMMAND”
    • Address: Brazil
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Type: Transnational Terrorist Group
    • Target Type: Criminal Organization

    List of Changes:

    • Program Tags:
      • Added: [FTO]
    • OFAC Programs:
      • [FTO]  Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597
      • [SDGT]  Global Terrorism Sanctions Regulations, 31 C.F.R. part 594; Executive Order 13224
      • [ILLICIT-DRUGS-EO14059]  Executive Order 14059

    PRIMEIRO COMANDO DA CAPITAL

    • AKA:
      • “FIRST CAPITAL COMMAND”
      • “PCC”
    • Address: Brazil
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Type: Transnational Terrorist Group
    • Target Type: Criminal Organization

    List of Changes:

    • Program Tags:
      • Added: [FTO]
    , , ,
  • The FINMA Notice:

    Updated sanction message: Sudan

    The Federal Department of Economic Affairs, Education and Research (WBF) has approved Annex 2 of the Ordinance of 25. May 2005 on measures against Sudan (SR 946.231.18).

    On the 4th June 2026, the Federal Department of Economic Affairs, Education and Research WBF amended Annex 2. The WBF has therefore adapted the sanctions database SESAM (SECO Sanctions Management), which is relevant for Switzerland, and will urgently publish the adjustment on its website today. The changes come into effect today, 11:00 p.m.

    In accordance with the provisions of the Regulation, financial intermediaries are required to implement the prohibitions, to block the assets of the sanctioned persons and to report the business relationships concerned to SECO. The report to SECO does not relieve a financial intermediary from making additional clarifications in the event of suspicion in accordance with Art. 6 GwG and, if he cannot clear them, to report it immediately to the notification office for money laundering in accordance with Art. 9 GwG.

    The sanctions list update:

    Links:

    Files of changes – PDF, XML

    Updated program list

  • Cuba Designations; Issuance of Cuba-related Frequently Asked Question

    State Press Release: Sanctions on Cuban Actors Responsible for Subversive Anti-American Activities

    State Press Release: Sanctions on Cuban Military Instrumentalities & Other Actors Responsible for Subversive Anti-American Activities

    Additions:

    The following individuals have been added to OFAC’s SDN List:

    OFAC Program: CUBA-EO14404  Executive Order 14404

    ANIDO CUESTA, Manuel

    • Address: Madrid, Spain
    • DOB: 03 Nov 1994
    • POB: Holguin, Cuba
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual
    • Linked To: CUESTA PERAZA, Lis

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(I) of E.O. 14404 as an adult family member of a person designated pursuant to this order. Manuel Anido Cuesta is the son of Lis Cuesta Peraza and stepson of Miguel Díaz-Canel Bermúdez.

    CASTRO CALIS, Raul Alejandro

    • Address: Havana, Cuba
    • DOB: 16 May 1995
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual
    • Linked To: CASTRO ESPIN, Alejandro

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(I) of E.O. 14404 as an adult family member of a person designated pursuant to this order. Raul Alejandro Castro Calis is the son of Alejandro Castro Espín.

    CASTRO ESPIN, Alejandro

    • AKA: “El Tuerto”
    • Address: Cuba
    • DOB: 1965
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(B) of E.O. 14404 for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, the Government of Cuba. Alejandro Castro Espín is the former head of the Cuban intelligence services and the son of Raul Modesto Castro Ruz. Secretary Rubio identified Castro Espín as a Castro family member and representative advancing the regime’s threats to U.S. national security.

    CUESTA PERAZA, Lis

    • Address: Cuba
    • DOB: 28 Mar 1971
    • POB: Holguin, Cuba
    • Nationality: Cuba
    • Gender: Female
    • Party Type: Individual
    • Linked To: DIAZ-CANEL BERMUDEZ, Miguel

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(I) of E.O. 14404 as an adult family member of a person designated pursuant to this order. Lis Cuesta Peraza is the spouse of Miguel Díaz-Canel Bermúdez.

    DIAZ-CANEL BERMUDEZ, Miguel

    • Address: Cuba
    • DOB: 20 Apr 1960
    • POB: Santa Clara, Cuba
    • Nationality: Cuba
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(E) of E.O. 14404 as a leader, official, senior executive officer, or member of the board of directors of the Government of Cuba. Miguel Díaz-Canel Bermúdez is the President of Cuba. Secretary Rubio specifically identified him as a target of these designations along with members of his network who advance the regime’s threats to U.S. national security.

    The following entities have been added to OFAC’s SDN List:

    OFAC Program: CUBA-EO14404  Executive Order 14404

    AMISTUR CUBA SA

    • Address: Calle 13 #504 e/ D y E, Vedado, Havana, Cuba
    • Organization Established Date: 19 Jan 1996
    • Organization Type: Travel agency activities
    • Linked To: CUBAN INSTITUTE OF FRIENDSHIP WITH THE PEOPLES

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(B) of E.O. 14404 for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, ICAP (Cuban Institute of Friendship with the Peoples), an entity designated pursuant to E.O. 14404 for being a political subdivision, agency, or instrumentality of the Government of Cuba.

    COMMITTEES FOR THE DEFENSE OF THE REVOLUTION

    • AKA:
      • COMITES DE DEFENSA DE LA REVOLUCION
      • “CDR”
    • Address: Linea Avenue, Havana, Cuba
    • Organization Established Date: 28 Sep 1960
    • Organization Type: Public order and safety activities

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(B) of E.O. 14404 for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, the Government of Cuba. CDR is under the direction of the Ministry of Interior of Cuba (previously designated for being a political subdivision, agency, or instrumentality of the Government of Cuba) and is a fundamental pillar of Cuba’s state oppressive security apparatus, per the State Department Fact Sheet.

    CUBAN INSTITUTE OF FRIENDSHIP WITH THE PEOPLES

    • AKA:
      • INSTITUTO CUBANO DE AMISTAD CON LOS PUEBLOS
      • “ICAP”
    • Address: Calle 17 No. 301 e/ H e I, Vedado, Havana, Cuba
    • Organization Established Date: 30 Dec 1960
    • Entity Code: 652 (Cuba)

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(F) of E.O. 14404 for being a political subdivision, agency, or instrumentality of the Government of Cuba. ICAP is a Cuban organization founded by Fidel Castro in 1960 that supports Cuban intelligence and counterintelligence activities, per the State Department Fact Sheet.

    MINERA LA VICTORIA SA

    • AKA: “MLV”
    • Address: Office 123, First Floor, Third Avenue Between 76 and 78, Beijing Building, Miramar Business Center, Playa, Havana 11300, Cuba
    • Organization Established Date: 14 Aug 2020
    • Organization Type: Mining of other non-ferrous metal ores

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(A) of E.O. 14404 for operating in or having operated in the metals and mining sector of the Cuban economy. Per the State Department Fact Sheet, Minera la Victoria SA is a Cuban gold mining joint venture created by Australia-based entity Antilles Gold Ltd and Cuban state-owned enterprise Geominera SA. Secretary Rubio cited this entity as a Cuban government gold mining joint venture that continues to enrich the Cuban military and elite at the expense of the Cuban people.

    MINISTRY OF THE REVOLUTIONARY ARMED FORCES OF CUBA

    • AKA:
      • MINISTERIO DE LAS FUERZAS ARMADAS REVOLUCIONARIAS
      • “MINFAR”
    • Address: Independence Avenue, Sierra Maestra Building, Plaza of the Revolution Municipality, Havana, Cuba
    • Organization Established Date: 16 Oct 1959
    • Target Type: Government Entity

    Supplemental Information: Designated pursuant to Sec. 2(a)(i)(F) of E.O. 14404 for being a political subdivision, agency, or instrumentality of the Government of Cuba. MINFAR is the government ministry in charge of the Cuban military. Per Secretary Rubio’s press statement, MINFAR’s majority holdings and subsidiaries—many of which are identified on the Department of State’s Cuba Restricted List (CRL)—are considered blocked as a result of this designation. Anyone dealing with entities owned 50 percent or more by GAESA, MINFAR, or the previously designated Ministry of the Interior risks exposure to potential U.S. sanctions action.

    , ,
  • Yesterday, OFAC published Cuba FAQ 1258:

    1258. I am a non-U.S. person, what is my exposure to sanctions risk for transacting with entities owned by Grupo de Administración Empresarial S.A. (GAESA), the Cuban Ministry of the Interior (MININT), or the Cuban Ministry of the Revolutionary Armed Forces (MINFAR), including their subsidiaries listed on the Cuba Restricted List (CRL)? 

    As of June 4, 2026, GAESA, MININT, and MINFAR are all blocked pursuant to Executive Order (E.O.) 14404. These three entities are also blocked pursuant to the Cuban Assets Control Regulations (CACR), and MININT is also blocked pursuant to the Global Magnitsky sanctions program under E.O. 13818, as of January 2021. Non-U.S. persons, including foreign financial institutions, are exposed to sanctions risk for engaging in transactions with persons designated under E.O. 14404. Sanctions risk also extends to transactions with any entity in which GAESA, MININT, or MINFAR own, directly or indirectly, a 50 percent or greater interest. Many of the entities listed on the CRLare 50 percent or more owned by one of these three entities and therefore present the same sanctions risk. In addition, any non-blocked CRL entity may become the subject of future sanctions actions. Consequently, persons transacting with any entity on the CRL may run the risk of themselves being sanctioned by the U.S. government.

    Non-U.S. persons should consider conducting enhanced due diligence to inform a risk-based approach to transactions with GAESA, MININT, MINFAR, or any entity in which they own, directly or indirectly, a 50 percent or greater interest. As part of such due diligence, non-U.S. persons are encouraged to consult all available sources to inform their independent assessment regarding the network of entities under GAESA, MININT, and MINFAR, including trusted sources provided by the U.S. government, such as the CRL.

    Released on Jun 04, 2026

  • UK Gov logo, 50% resolution.png

    Today, Thursday 4th June, the UK Government has revoked one entity and amended one individual, both sanctioned under the Russia Sanctions Regime.

    Revoked Entity:

    Name:Unique ID:
    Limited Liability Company responsibility of “RBRU Specialized Depository”RUS2682

    Amended Individual:

    Name:Unique ID:
    Liran COHENRUS3607

    and here’s the sanctions notice:

    , ,
  • Claude tries its hand at the problem:

    Humanitarian Exceptions Under OFAC Sanctions: How They Vary by Program

    A Summary for Senior Leadership


    The Core Concept

    OFAC sanctions generally block U.S. persons from transacting with designated targets — but they are not intended to block food, medicine, or disaster relief from reaching civilian populations. To that end, every OFAC sanctions program includes some form of humanitarian carve-out. The critical point for leadership is this: what is permitted, how it is authorized, and how reliably it works in practice varies significantly from program to program. An authorization that is self-executing and commercially broad under one program may be tightly restricted — or effectively inoperative — under another.


    The Common Baseline

    In December 2022, OFAC standardized a set of humanitarian general licenses across a wide range of sanctions programs, implementing a United Nations Security Council resolution that created a similar carve-out across UN sanctions regimes. The action added or updated four categories of standing authorizations: official U.S. government business; business of certain international organizations (such as the United Nations and the International Red Cross); transactions in support of NGO activities such as disaster relief, health services, and democracy and peacebuilding programs; and the provision of agricultural commodities, medicine, and medical devices.

    These are self-executing authorizations — meaning organizations that assess their activities fall within the license terms may proceed without separately applying to OFAC. Most OFAC sanctions programs have certain exceptions, but exceptions vary in type and scope across different programs.

    However, three important limitations apply across the board even under this baseline:

    1. The authorization for food, medicine, and medical devices to blocked persons (i.e., SDN-listed individuals and entities) covers personal, non-commercial use only. Commercial-scale humanitarian supply operations require program-specific authorizations.
    2. NGOs are not authorized to transfer funds directly to a blocked person, or to any entity owned 50% or more by a blocked person, in connection with activities authorized under these general licenses.
    3. Authorization under one sanctions program does not automatically extend to another. Each program must be analyzed independently.

    Programs Built on Comprehensive Prohibitions (Cuba, Iran, North Korea)

    The most significant humanitarian complexities arise where OFAC administers comprehensive embargoes — programs that prohibit virtually all commercial dealings absent specific authorization, rather than merely targeting named individuals or sectors. The comprehensively sanctioned countries are Cuba, Iran, North Korea, and Syria (plus Russian-controlled Ukrainian regions). Of these, Syria is now largely a special case discussed separately below.

    The TSRA Mechanism: A Congressional Mandate

    For Iran and Cuba, Congress added a layer above the standard OFAC framework via the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA). TSRA provides that the President shall terminate unilateral agricultural and medical sanctions and requires that exports of agricultural commodities, medicines, and medical devices to sanctioned countries be made in accordance with a specific licensing regime.

    The practical effect differs by product type:

    • OFAC has authorized agricultural commodity exports to Iran under a general license, broadly covering food for humans and related products. No prior OFAC approval is required if the exporter meets the terms.
    • Medicine and medical devices are more complex. Anyone seeking to export medicine or medical devices not covered by the relevant general licenses must first obtain a specific license from OFAC — a document-intensive process that requires a one-year OFAC license. This includes more complex medical devices that fall outside the general license terms.

    This specific-license requirement is a meaningful operational difference from the self-executing general licenses that govern most other programs. The application process takes months, and the list of medical devices requiring specific authorization (published separately by OFAC) is not trivial.

    North Korea: The Most Restricted Humanitarian Space

    North Korea presents the tightest constraints. OFAC added general licenses to the North Korea Sanctions Regulations in February 2024 authorizing certain NGO activities, the provision of certain agricultural commodities, medicine, and medical devices, and limited journalistic activities. However, the North Korea program layers compliance obligations that do not appear elsewhere:

    • License Exception for Servicing and Replacement of Parts and Equipment is not available for North Korea, so an individual validated Commerce Department license is required to export replacement parts and components subject to the Export Administration Regulations, including for use in medical devices.
    • For certain items — such as machinery that may qualify as a medical device subject to UN Security Council sanctions — OFAC authorization alone is insufficient. Exporters must also obtain the UNSC 1718 Committee’s separate humanitarian exemption.

    In short: a single OFAC authorization is not necessarily the end of the compliance chain for North Korea. Organizations operating there must navigate OFAC, Commerce, and the UN simultaneously.


    The Paper-Versus-Practice Problem: Iran

    Iran represents the starkest gap between what the regulations authorize and what the market actually permits. Even authorized humanitarian trade with Iran has been curtailed despite legal authorization, because of the general perception of sanctions risk and the aggressive approach to enforcement. Treasury statements and FAQs can only do so much to overcome the surrounding enforcement rhetoric.

    The mechanism is “overcompliance” by the banking sector. The main obstacle to Iran’s importing officially exempted humanitarian materials is that sanctions restrict the means to finance those purchases. Banks and financial institutions in other countries appear unwilling to authorize any business with Iran for fear of incurring U.S. sanctions themselves, despite exemptions for humanitarian trade.

    The current administration’s maximum pressure campaign has intensified this dynamic. Since February 2025, OFAC has sanctioned approximately 1,000 Iran-related persons, vessels, and aircraft, and has systematically targeted Iran’s shadow banking architecture. The designation of the broader Iranian financial sector means that even transactions involving banks not previously designated may create secondary sanctions exposure for foreign financial institutions.

    The operational takeaway for companies with any Iran touchpoint: an OFAC general license for humanitarian trade is a necessary but not sufficient condition for completing a transaction. Finding a financial institution willing to process it is a separate, often intractable problem.


    Targeted Programs: Russia as the Counterexample

    The Russia sanctions program illustrates the other end of the spectrum. Russia is sanctioned through targeted and sectoral restrictions, not a comprehensive embargo. The United States has not imposed sanctions on the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, or medicine relating to Russia. OFAC has issued a broad general license authorizing certain transactions related to agricultural commodities, agricultural equipment, medicine, and medical devices.

    Treasury has been explicit that agricultural and medical trade are not the target of U.S. sanctions on Russia and that those sanctions do not stand in the way of agricultural and medical trade. In this structure, the humanitarian carve-out functions less as an exception to a broad prohibition and more as an explicit safe harbor confirming that these categories were never the target to begin with.


    Syria: A Recent and Instructive Pivot

    Syria illustrates how dramatically program-level conditions can shift. For years, Syria operated under one of OFAC’s most complex humanitarian frameworks — a comprehensive embargo with standing NGO authorizations, ad hoc disaster relief licenses (including a 180-day license issued after the 2023 earthquakes), and ongoing compliance challenges. Effective July 1, 2025, President Trump issued an executive order removing U.S. sanctions on Syria, with sanctions remaining only on Bashar al-Assad and his associates, human rights abusers, ISIS and Al-Qa’ida affiliates, and Iran and its proxies.

    The Syria experience underscores a point worth internalizing at the leadership level: the regulatory environment governing any given program can change substantially within an administration’s tenure, in either direction.


    Summary Comparison

    ProgramHumanitarian ModelSelf-Executing?Key Complications
    Most targeted programsStandard 2022 GL baseline (food/medicine/NGO)YesPersonal use only for SDN-delivered goods
    IranTSRA + program GLsPartial (food yes; complex medical devices: no)Banking sector overcompliance; secondary sanctions chilling effect
    CubaCACR GLs + TSRA + new EO 14404 layerPartialParallel regulatory frameworks; recent tightening
    North KoreaNarrow GLs, recently expandedYes (but limited scope)Must also satisfy Commerce Dept. and UN Committee requirements
    RussiaBroad GL; humanitarian trade never a targetYesTargeted program; food/medicine effectively unimpeded
    SyriaSanctions largely revoked July 2025N/AResidual designations remain

    Practical Guidance for Leadership

    Three principles follow from the above:

    1. Program identity matters as much as transaction type. “This is a humanitarian shipment” is not, by itself, a compliance answer. The relevant question is which program governs the transaction, and what that program specifically authorizes.

    2. Authorization on paper does not guarantee execution. For Iran in particular, even a valid general license may not produce a transaction that clears successfully through the banking system. Due diligence on financial channel availability is part of the compliance analysis.

    3. The framework can change. Licenses are issued, amended, and revoked at OFAC’s discretion. Time-sensitive humanitarian operations — especially in conflict or disaster contexts — should be stress-tested against current authorizations, not assumptions based on prior experience with a program.


    Sources

    The big difference between what I usually do in terms of prompting was that, instead of directing Claude to write for “non-expert professionals”, I instructed it to write for the C-suite, and telling it that they had some cursory sanctions knowledge (which, depending on your firm, may or may not be accurate).

  • Had to wait for Claude to do its magic…

    Counter Terrorism and Iran-related Designations; Democratic Republic of the Congo-related Designations; Issuance of Iran-related Frequently Asked Question

    Treasury Press Release: Economic Fury Targets Iran’s Largest Digital Asset Exchange for Terror Finance and Sanctions Evasion

    Treasury Press Release: Treasury Sanctions Rebel Commanders Driving Conflict in the Democratic Republic of the Congo

    State Press Release: Targeting Iran’s Digital Asset Exchanges for Terror Finance and Sanctions Evasion

    State Press Release: United States Sanctions Armed Group Leaders in Eastern Democratic Republic of the Congo

    In addition to the SDN list updates below, OFAC issued a new Iran-related Frequently Asked Question: FAQ 1257.

    Additions:

    The following individuals have been added to OFAC’s SDN List:

    OFAC Program: SDGT Specially Designated Global Terrorist — Designated pursuant to Executive Order 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten to Commit, or Support Terrorism,” as amended by Executive Order 13886 of September 9, 2019. Administered under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.

    AGHAMIR MOHAMMAD ALI, Seyed Mohammad

    • AKA:
      • AGHAMIR, Mohammad
      • KHARRAZI, Mohammad
    • Address: Tehran, Iran
    • DOB: 1992
    • Nationality: Iran
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: NOBITEX

    Supplemental Information: Seyed Mohammad Aghamir Mohammad Ali (known as Mohammad Aghamir) is a co-founder and blockchain lead at Nobitex, Iran’s largest digital asset exchange. He is a member of the Kharrazi family. OFAC designated him pursuant to Executive Order 13224, as amended, for being a leader or official of Nobitex.

    AGHAMIR MOHAMMAD ALI, Seyed Mohammad Ali

    • AKA:
      • AGHAMIR, Ali
      • AHMAD HOSSEIN, Ali
      • KHARRAZI, Ali
    • Address: Iran
    • DOB: 23 Aug 1986
    • Nationality: Iran
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: NOBITEX

    Supplemental Information: Seyed Mohammad Ali Aghamir Mohammad Ali (known as Ali Aghamir) is a co-founder of Nobitex and a member of the Kharrazi family, which is part of former Supreme Leader Khamenei’s inner circle. OFAC designated him pursuant to Executive Order 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Nobitex.

    KHOEE, Seyed Ali

    • AKA: KHOUEI, Ali
    • Address: Iran
    • DOB: 02 May 1989
    • Nationality: Iran
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Party Type: Individual
    • Linked to: NOBITEX

    Supplemental Information: Seyed Ali Khoee is the current CEO of Nobitex and previously served as the company’s director of product and marketing. OFAC designated Khoee pursuant to Executive Order 13224, as amended, for being a leader or official of Nobitex.

    OFAC Program: DRCONGO Democratic Republic of the Congo — Designated pursuant to Executive Order 13413, “Blocking Property of Certain Persons Contributing to the Conflict in the Democratic Republic of the Congo,” of October 27, 2006, as amended by Executive Order 13671 of July 8, 2014. Administered under the Democratic Republic of the Congo Sanctions Regulations, 31 C.F.R. part 547.

    KUBWAYO, Gustave

    • AKA:
      • “SIRKOFF”
      • “SIRKOOF”
    • Address: North Kivu, Congo, Democratic Republic of the
    • DOB: 1969
    • POB: Rwanda
    • Nationality: Rwanda
    • Gender: Male
    • Party Type: Individual

    Supplemental Information: Gustave Kubwayo, commonly known as “Colonel Sirkoof,” is an FDLR commander and the leader of the Commando de Recherche et d’Action en Profondeur, an FDLR intelligence and special operations unit. He also led an FDLR operational command structure in North Kivu’s Nyiragongo territory that formed in 2022, after M23 attacks forced the FDLR to geographically disperse. The Democratic Forces for the Liberation of Rwanda (FDLR) formed in 2000 from the remnants of the ex-Rwandan Armed Forces and extremist militias that fled Rwanda following the 1994 genocide. FDLR has waged a campaign of ethnically motivated violence against civilians, including summary killings, forced recruitment of children, and sexual violence; OFAC designated the group on January 3, 2013. OFAC designated Kubwayo pursuant to E.O. 13413, as amended by E.O. 13671, for being a leader of FDLR, an entity whose property and interests in property are blocked pursuant to E.O. 13413.

    NZENZE, John Imani

    • AKA: “IDI, Imani Nzenze”
    • Address: North Kivu, Congo, Democratic Republic of the
    • DOB: 06 Aug 1978
    • Nationality: Congo, Democratic Republic of the; alt. Rwanda
    • Citizen: Congo, Democratic Republic of the; alt. Rwanda
    • Gender: Male
    • National ID No.: 1197880137555327 (Rwanda)
    • Party Type: Individual

    Supplemental Information: John Imani Nzenze is an M23 commander and M23’s chief of intelligence. He is regarded as one of the closest collaborators and confidants of Sultani Makenga, the U.S.- and UN-sanctioned overall military commander of M23. Nzenze has been an M23 leader since the group’s first rebellion (2012–2013), when he led M23 attacks on Congolese military positions. M23 is a Rwanda-backed armed group that occupies large portions of North and South Kivu provinces in the DRC; its military campaigns have claimed thousands of civilian lives and resulted in a mass displacement crisis. OFAC designated Nzenze pursuant to E.O. 13413, as amended by E.O. 13671, for being a leader of M23, an entity whose property and interests in property are blocked pursuant to E.O. 13413.

    OFAC Programs:

    • SDGT Specially Designated Global Terrorist — Designated pursuant to Executive Order 13224, as amended by Executive Order 13886. Administered under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.
    • IRAN-EO13902 Iran – Executive Order 13902 — Designated pursuant to Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran,” of January 10, 2020, targeting persons operating in the construction, mining, manufacturing, textiles, financial, or other sectors of the Iranian economy as determined by the Secretary of the Treasury.

    RAD, Amir Hossein

    • AKA:
      • RAD, Amir
      • RAD, Amirhossein
    • Address: Qazvin, Iran
    • DOB: 21 Mar 1986
    • Nationality: Iran
    • Email Address: radamir@gmail.com
    • alt. Email Address: arad@nobitex.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Phone Number: 989121810513
    • National ID No.: 4324461872 (Iran)
    • Party Type: Individual

    Supplemental Information: Amir Hossein Rad is Nobitex’s chairman, co-founder, and former CEO. In June 2025, he helped Nobitex reconstitute its operations following a $90 million hack of the company on June 18, 2025; the company had previously enabled the Iranian regime to evade sanctions and transfer wealth out of the country. OFAC designated Rad pursuant to Executive Order 13224, as amended, for being a leader or official of Nobitex, and pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.

    The following entities have been added to OFAC’s SDN List:

    OFAC Programs:

    • IRAN Iran Sanctions — Persons designated pursuant to various Iran-related executive orders and statutory authorities. Administered in part under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560.
    • IRAN-EO13902 Iran – Executive Order 13902 — Designated pursuant to Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran,” of January 10, 2020, targeting persons operating in the construction, mining, manufacturing, textiles, financial, or other sectors of the Iranian economy.

    BITPIN

    • AKA: SANA AYMAN MUBADALA
    • Address: Unit 2, Floor 1, Viana (Alizadeh) Trade Complex Building No. 42, Shahid Fatehi Blvd., Sharghayegh Alley, Anzali Free Zone, Bandar Anzali, Gilan 4333155170, Iran
    • Website: bitpin.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2020
    • Organization Type: Financial and Insurance Activities
    • Company Number: 14009960142 (Iran)

    Supplemental Information: Bitpin is an Iranian digital asset exchange that received 10 percent of all Iranian digital asset inflows in 2025. It has processed millions of dollars in transactions, including transactions linked to the IRGC. Bitpin’s investors have reportedly been linked to Iranian efforts to evade U.S. sanctions. OFAC designated Bitpin pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.

    RAMZINEX

    • AKA: RAMZINEH ELECTRONIC COMMERCE INNOVATION COMPANY
    • Address: Unit 901, 9th Floor, Sharif Technology Tower, No. 28, Shahid Hamid Salahi Blvd, Azadeh Street, Timori, Tehran, Iran
    • Website: https://ramzinex.com/
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2018
    • Organization Type: Financial and Insurance Activities
    • Company Number: 14009372096 (Iran)

    Supplemental Information: Ramzinex is a digital asset exchange based in Tehran, founded in 2018. It has processed over $2.45 billion in transactions, including transactions linked to the IRGC and a financial institution backed by the Iranian government, and has been used for sanctions evasion. OFAC designated Ramzinex pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.

    WALLEX

    • AKA:
      • KHALGH SARVAT SARZAMIN PARSEH
      • KHALQ THARWAT SARZAMIN PARSEH COMPANY
    • Address: North Unit, Fourth Floor, No. 231, Mirzai Shirazi Street, Shahoda Street, Abbasabad-Andisheh, Tehran 1586753411, Iran
    • Website: https://wallex.ir/
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Organization Established Date: 2019
    • Organization Type: Financial and Insurance Activities
    • Company Number: 14010030821 (Iran)

    Supplemental Information: Wallex is Iran’s second-largest digital asset exchange by volume and received 12 percent of all Iranian digital asset inflows in 2025. It has facilitated numerous transactions linked to the IRGC. OFAC designated Wallex pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.

    OFAC Programs:

    • IRAN Iran Sanctions — Persons designated pursuant to various Iran-related executive orders and statutory authorities. Administered in part under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560.
    • SDGT Specially Designated Global Terrorist — Designated pursuant to Executive Order 13224, as amended by Executive Order 13886. Administered under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594.
    • IRAN-EO13902 Iran – Executive Order 13902 — Designated pursuant to Executive Order 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran,” of January 10, 2020, targeting persons operating in the construction, mining, manufacturing, textiles, financial, or other sectors of the Iranian economy.

    NOBITEX

    • AKA: RAHKAR FANAVARI NOOYAN
    • Address: Unit 1002, Floor 10, Sharif Technology Tower, Akbari Corner, Salehi Boulevard, Tarasht, Tehran, Iran
    • Website: nobitex.ir
    • Additional Sanctions Information: Subject to Secondary Sanctions
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Type: Financial and Insurance Activities
    • Company Number: 1400769571 (Iran)

    Supplemental Information: Nobitex is Iran’s largest digital asset exchange. In 2025, it processed more than 50 percent of all Iranian digital asset inflows, facilitating payments tied to Iran’s terrorist activities, sanctions evasion efforts, and IRGC-linked transactions, including transactions for wallets associated with IRGC-affiliated ransomware actors. Nobitex helped the Central Bank of Iran access hundreds of millions of dollars in stablecoins used to prop up the plummeting value of the Iranian rial, while enabling regime insiders to access international digital asset exchanges and evade sanctions across multiple jurisdictions. Two of Nobitex’s co-founders are close associates of former Supreme Leader Khamenei’s family. Nobitex also reportedly enables the Iranian government to conduct warrantless surveillance of Iranian civilians. Following the commencement of U.S. combat operations in Iran, Nobitex played a role in protecting and moving assets and funds out of the country to shield regime wealth, even during internet blackouts. OFAC designated Nobitex pursuant to Executive Order 13224, as amended, for materially assisting, sponsoring, or providing financial, material, or technological support to the IRGC, and pursuant to Executive Order 13902 for operating in the financial sector of the Iranian economy.

  • Notice of Changes to the Consolidated List – 2 June 2026

    DFAT updated the Consolidated List on 2 June 2026 to reflect the following changes:

    The previous notice incorrectly linked to a previous instrument. Please disregard.

    The updated Consolidated List can be downloaded from the following page: Consolidated List | Australian Government Department of Foreign Affairs and Trade

    Guidance on how to interpret the Consolidated List can be found here: Guide to Australia’s Consolidated List | Australian Government Department of Foreign Affairs and Trade

    If you have any queries, please contact the Australian Sanctions Office atsanctions@dfat.gov.au.  

    Australian Sanctions Office

    _______________________________

    Australian Sanctions Office | Regulatory and Legal Policy Division

    Department of Foreign Affairs and Trade

  • Yesterday, OFAC issues FAQ 1257:

    1257. Are non-U.S. persons exposed to sanctions risk for dealing with Iran-based digital asset exchanges Nobitex, Wallex, Bitpin, and Ramzinex following their June 2, 2026 designation? 

    Yes. OFAC’s June 2, 2026 designation of Iran-based digital asset exchanges Nobitex, Wallex, Bitpin, and Ramzinex pursuant to Executive Order (E.O.) 13902 for operating in the Iranian financial sector means that foreign financial institutions and other non-U.S. persons who engage in certain transactions with these exchanges also risk exposure to sanctions under E.O. 13902. For example, pursuant to E.O. 13902, OFAC has authority to:

    1. Designate persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Nobitex, Wallex, Bitpin, and Ramzinex; or
    2. Prohibit or impose strict conditions on correspondent account or payable-through account opening or maintenance by foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for or on behalf of Nobitex, Wallex, Bitpin, and Ramzinex.

    In addition, foreign financial institutions may be exposed to mandatory statutory sanctions for engaging in significant financial transactions with Nobitex, Wallex, Bitpin, and Ramzinex, designated Iranian financial institutions, pursuant to the National Defense Authorization Act of Fiscal Year 2012. Please see FAQ 174 for more information.

    Released on Jun 02, 2026

  • The FINMA Notice:

    Updated sanction notice: Myanmar

    The Federal Department of Economics, Education and Research WBF has adopted an amendment to Annex 1 of the Ordinance of 17. October 2018 on measures against Myanmar (SR 946.231.157.5).

    On the 1st On 1 June 2026, the Federal Department of Economic Affairs, Education and Research WBF changed the list of persons, companies and organizations sanctioned in this context. The WBF has therefore adapted the sanctions database SESAM (SECO Sanctions Management), which is relevant for Switzerland, and updated the amendment on its website on 2. June 2026. The change comes into effect today, 11:00 p.m.


    In accordance with the provisions of the Regulation, financial intermediaries are required to implement the prohibitions, to block the assets of the sanctioned persons and to report the business relationships concerned to SECO. The report to SECO does not relieve a financial intermediary from making additional clarifications in the event of suspicion in accordance with Art. 6 GwG and, if he cannot clear them, to report it immediately to the notification office for money laundering in accordance with Art. 9 GwG.

    The update:

    The update files – PDF, XML

    And the updated program list.