Skadden, Arps, Slate, Meagher & Flom LLP and Affiliates

US Government Announces New Iran Sanctions Measures

Skadden Publication / National Security Dispatch

Brian J. Egan Eytan J. Fisch Joe Sandman Michael Tian

Executive Summary

  • What’s new: On August 24, 2026, OFAC issued determinations covering five additional Iranian economic sectors, designated nearly 60 Iran-related individuals, entities and vessels, suspended five Iran-related general licenses, and updated its guidance on transit through the Strait of Hormuz. In subsequent actions, Treasury targeted two third-country financial institutions for engaging in transactions with Iran. OFAC later suspended three Iran-related aviation authorizations and designated targets in Iran’s aviation sector, in Iran and third countries, and FinCEN issued an alert on Iranian aviation procurement networks and related red flags. On September 10, 2026, OFAC announced that Iran-related specific license applications will be treated with a presumption of denial except as required by law or in certain circumstances.
  • Why it matters: The Iran-related measures expand secondary-sanctions risks, including for persons operating in or supporting the aviation, digital-asset, gold, shipping and technology sectors, and suspend key authorizations under the ITSR. The financial measures show that Treasury is increasingly willing to target third-country financial institutions that engage in transactions with Iran.

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On August 24, 2026, the U.S. government announced significant sanctions-related actions targeting Iran. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) further strengthened Iran-related sanctions by expanding sectoral sanctions, designating additional persons and vessels, suspending key authorizations under the Iranian Transactions and Sanctions Regulations (ITSR) and issuing further guidance on transit through the Strait of Hormuz. In addition, the U.S. government indicated that Treasury will target Iran-related activity that it identifies and that is not suspended on timelines set by the U.S. government.

The U.S. government has continued to take action against Iran. On August 28, 2026, as a subsequent action as part of so-called Operation Economic Outcast, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking making a finding that the five branches of Egypt’s Banque Misr located in the United Arab Emirates (Banque Misr UAE) constitute a financial institution operating outside the U.S. of primary money laundering concern and imposing the fifth special measure under Section 311 of the USA PATRIOT Act to prohibit U.S. financial institutions from opening or maintaining correspondent accounts for, or on behalf of, Banque Misr UAE. On September 4, 2026, OFAC blocked Türkiye-based Golden Global Yatirim Bankasi Anonim Sirketi (Golden Global Bank) and two subsidiaries for facilitating Iran’s access to international banking channels.

On September 8, 2026, OFAC suspended three Iran-related aviation authorizations and designated targets in Iran’s aviation sector, in both Iran and third countries, and FinCEN issued an alert on Iranian aviation procurement networks and related red flags. On September 10, 2026, OFAC modified its Iran-related specific licensing policy. Effective immediately, Iran-related specific license applications will be treated with a presumption of denial except as required by law or in certain circumstances.

1. Iran: Suspension of General Licenses

On August 24, 2026, OFAC suspended general licenses covering:

  • Certain educational activities by U.S. persons in third countries (31 C.F.R. § 560.544).
  • Certain noncommercial, personal remittances to or from Iran (31 C.F.R. § 560.550).
  • Conference-related services in the U.S. or third countries (31 C.F.R. § 560.554).
  • Services supporting professional and amateur sports activities and exchanges involving the U.S. and Iran (Iran General License F).
  • Certain academic exchanges and educational services (General License G).

At the same time, OFAC issued General License BB, which authorized certain transactions prohibited by the ITSR that were ordinarily incident and necessary to the wind down of any transaction previously authorized by one or more of the five suspended authorizations through 12:01 a.m. Eastern Daylight Time on September 8, 2026. Under General License BB, any payment to a blocked person had to be made into a blocked, interest-bearing account located in the U.S. in accordance with the ITSR.

Separately, on September 8, 2026, OFAC suspended General License J-1, which had authorized the reexportation of certain civil aircraft to Iran on temporary sojourn and related transactions. OFAC also suspended authorizations in 31 C.F.R. § 560.528 and 31 C.F.R. § 560.529, which covered certain overflights of Iran and certain flights by non-U.S. airlines of U.S.-origin or U.S.-controlled commercial aircraft into Iran.

In conjunction, OFAC issued General License DD, which authorizes transactions ordinarily incident and necessary to the wind down of certain civil aviation-related and other transactions previously authorized under the ITSR through 12:01 a.m. EDT on September 23, 2026, and Counter Terrorism General License 37, which authorizes transactions ordinarily incident and necessary to the wind down of transactions involving certain persons blocked on September 8, 2026, through the same deadline.

2. Iran: Additional Secondary Sanctions

OFAC also issued a determination under Section 1(a)(i) of Executive Order (E.O.) 13902 authorizing the imposition of sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate in the aviation, digital asset, gold, shipping and technology sectors of the Iranian economy. The new determination creates secondary sanctions risks for persons operating in these sectors of the Iranian economy, even where such operations have no U.S. nexus. OFAC has not yet provided guidance on the definition or scope of these sectors.

OFAC has explained that persons who knowingly engage in a “significant transaction” for the sale, supply or transfer to or from Iran of significant goods or services used in connection with a designated sector may risk blocking sanctions under E.O. 13902. OFAC generally assesses whether a transaction is significant based on the totality of the facts and circumstances, including:

  • The transaction’s size, number and frequency.
  • Its nature, including its type, complexity and commercial purpose.
  • The level of awareness, including involvement of management.
  • The pattern of conduct, including whether it is the result of a business strategy.
  • The nexus, including proximity to sanctioned parties
  • The impact, including on statutory objectives
  • Deceptive practices, including attempts to obscure or conceal parties, or to evade sanctions.
  • Other case-specific factors.

OFAC has previously issued similar determinations with respect to the construction, mining, manufacturing, textiles, financial and petroleum/petrochemical sectors of the Iranian economy.

3. Iran: Newly Designated Entities

On August 24, 2026, OFAC designated nearly 60 individuals, entities and vessels and added them to the Specially Designated Nationals and Blocked Persons List (SDN List). OFAC relied on a range of authorities, including:

  • E.O. 13382, which targets proliferators of weapons of mass destruction (WMD) and their means of delivery.
  • E.O. 13694, as amended, which targets specified malicious cyber-enabled activities.
  • E.O. 13902, which authorizes sanctions for operating in specified Iranian economic sectors and for specified support or significant-transaction conduct.
  • E.O. 13224, as amended, a counterterrorism authority targeting terrorists and persons that support them.

The designations include many non-Iranian individuals, entities and vessels across third-country jurisdictions, including the United Arab Emirates, Hong Kong, China, Singapore, Switzerland, Malaysia and other jurisdictions. The covered networks and activities include procurement and front companies supporting proliferation-sensitive technology and equipment; cyber actors directed by Iran’s Ministry of Intelligence and Security; vessel brokers and bunkering providers; financial intermediaries; shadow-fleet and oil-revenue networks; and digital-asset activity and financial-sector exposure associated with Iran’s designated sectors, where applicable.

On September 8, 2026, OFAC designated 36 targets for operating in the aviation sector of the Iranian economy, exercising its new authority pursuant to the determination of August 24, 2026, under E.O. 13902.

4. Section 311 Special Measures Against Banque Misr UAE

On August 28, 2026, FinCEN issued a notice of proposed rulemaking making a finding that Banque Misr UAE is a financial institution operating outside the U.S. that is of primary money laundering concern and proposing to impose the fifth special measure under Section 311 of the USA PATRIOT Act to prohibit U.S. financial institutions from opening or maintaining correspondent accounts for, or on behalf of, Banque Misr UAE. Banque Misr is an Egyptian bank, and only its Emirati branches would be covered by the fifth special measure.

If the rulemaking is finalized and Banque Misr UAE is found to be a financial institution of “primary money laundering concern” under Section 311 of the USA PATRIOT Act, the rule would:

  • Prohibit U.S. financial institutions from opening or maintaining correspondent accounts for, or on behalf of, Banque Misr UAE.
  • Require covered financial institutions to perform special due diligence of correspondent accounts to prevent transactions reasonably designed to guard against their use to process transactions involving Banque Misr UAE.
  • Impose requirements that covered financial institutions document their compliance with the notification requirement.

The fifth special measure is the most severe of the special measures available to FinCEN under Section 311, and in the notice of proposed rulemaking, FinCEN stated that Banque Misr UAE processed approximately $1.8 billion between January 2024 and June 2026 for 103 companies potentially linked to Iranian shadow-banking networks.

5. Iran: Golden Global Bank Designation

On September 4, 2026, OFAC designated Türkiye-based Golden Global Bank and its two Türkiye-based subsidiaries, Golden Global Varlik Kiralama Anonim Sirketi and Golden Global Portfoy Yonetimi Anonim Sirketi. Treasury explained that Golden Global Bank had been established to enable Iran to transfer oil revenue from China to Türkiye for conversion to cash and gold and knowingly offered correspondent banking services to Iranian financial institutions. OFAC designated Golden Global Bank pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy and knowingly engaging in a significant transaction for the sale, supply or transfer to or from Iran of significant goods or services used in connection with that sector; the subsidiaries were designated for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Golden Global Bank. OFAC simultaneously issued a general license, General License CC, which authorizes certain wind-down transactions involving Golden Global Bank and the two subsidiaries until 12:01 a.m. EDT on September 19, 2026.

6. Iran: FinCEN Alert on Iran’s Aviation Industry

On September 8, 2026, FinCEN issued an alert to assist financial institutions in identifying and reporting procurement networks supporting Iran’s aviation industry. The alert identifies red flag indicators for Iranian commercial aviation procurement and requests that financial institutions reference the alert when filing corresponding suspicious activity reports.

7. Iran: Strait of Hormuz Passage Risks

OFAC’s August 24, 2026, Strait of Hormuz guidance makes clear that, independently of secondary-sanctions exposure, U.S. persons and U.S.-owned or -controlled foreign entities generally may not engage in direct or indirect dealings with Iran or the Government of Iran absent an applicable exemption or OFAC license. The guidance also warns that U.S. persons, U.S.-owned or -controlled foreign entities, and potentially non-U.S. persons face sanctions risk if they negotiate for or obtain safe passage through the strait from the Government of Iran, the Islamic Revolutionary Guard Corps (IRGC), the Persian Gulf Strait Authority (PGSA), the Persian Gulf Marine Insurance Company (PGMIC) or HormuzSafe Marine Services Authority (HormuzSafe), including by accepting guarantees, insurance or other services, or by responding to information demands, even when no payment or other exchange of value is made. The risk applies regardless of payment method or structure. The warning rests on the Iran sanctions prohibitions, PGSA’s designation under U.S. counterterrorism authorities, and PGMIC’s and HormuzSafe’s designations under E.O. 13902.

Conclusion

The breadth of the recent Iran-related actions signals the U.S. government’s continued willingness to leverage its existing economic authorities with respect to Iran. The package combines new sector determinations; designations under multiple nonproliferation, cyber, economic-sector and counterterrorism authorities; the suspension of existing authorizations; and additional maritime guidance concerning the Strait of Hormuz. Many of the designated persons and vessels are located outside Iran, underscoring the cross-border reach of the campaign and signaling that future measures may continue to extend across international networks supporting Iran-related activity.

This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.

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