On October 1, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new sectoral sanctions determinations targeting Iran’s automotive and rail sectors.  These determinations authorize OFAC to sanction any entity or individual operating in these sectors. OFAC stated that Iran’s automotive sector is the country’s largest economic sector outside of oil and gas and remains a core contributor to Iran’s industrial base and is a major revenue generator for the regime.  OFAC has also targeted Iran’s rail sector stating that, given the maritime blockade, the Iranian regime is using its railway companies to transport oil and sustain regional trade.  In addition to these new automotive and rails sectoral sanctions, OFAC also announced additional designations and placement on the Specially Designated Nationals (SDN) List of multiple Iranian and third-country entities and individuals involved in the Iranian heavy equipment, mining, metals, steel and oil networks. Additional information on OFAC targeting of Iran’s automotive, rail, manufacturing, and steel industrial sectors is available here.

Specific identifying information on newly sanctioned entities and persons under these aviation and rail sectoral sanctions is available here. As a result of these actions, all property and interests in property of these designated or blocked persons that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.  In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.

Further, OFAC has issued a revised FAQ to assist in guidance on how it defines the sectors of the Iranain economy under its sectoral sanctions.

With these most recent sanctions, Iran’s oil, aviation, automotive and rail sectors are now targeted as being industrial sectors providing revenue to the Iranian regime and the Islamic Revolutionary Guard Corps (IRGC).  For additional information on OFAC sanctions, see SmarTrade updates of September 11, 2026, August 25, 2026, and February 12, 2026.

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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 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.

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.