On August 24, 2026, President Donald Trump and the Department of the Treasury announced implementation of “Operation Economic Outcast,” marking further efforts remove the Islamic Republic of Iran “and its enablers” from all available financial resources supporting the Iranian regime.

According to a press release, the Treasury Department “has mapped the networks, facilitators, and financial channels that Iran uses to smuggle oil, evade sanctions, and fund terror. Working with our partners across the U.S. government, Treasury will be uncompromising in targeting any source of the regime’s illicit revenue.”  The press release notes that “the Departments of Treasury, State, and War are engaging counterparts around the world to make clear that the United States expects immediate action. Every country will be given a defined timeline to shut down the Iran-related activity we have identified. If they fail to act, Treasury will act.”

In undertaking these efforts to further isolate Iran, the Treasury Department has taken the following immediate actions:

  • OFAC has issued updated guidance on the sanctions risks Iranian demands related to shipping in the Strait of Hormuz. 
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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.