Sanctions

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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…

On September 30, 2026, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued a final rule in the Federal Register that, effective October 1, 2026, revises the International Traffic in Arms Regulations (ITAR) to remove Syria from the list of countries in ITAR § 126.1 for which there is a policy of denial…

On September 30, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented new sanctions on Cuba and formally amended the existing Cuban Assets Control Regulations (CACR). In May 2026, President Donald Trump issued Executive Order (EO) 14404 titled “Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to…

On September 8 and 10, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned multiple companies and persons for supporting Iran’s aviation sector and for enabling Iran to destabilize the Middle East. The aviation-related sanctions include covert front companies, foreign intermediaries, and deceptive transshipment routes that Iran relies on to obtain…

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…

On July 8, 2026, on the sidelines of the NATO summit, President Donald Trump announced his intention to remove Syria from the State Sponsor of Terrorism list, a significant move that would assist Syria’s efforts to re-engage in the global political and financial systems and rebuild the country after more than a decade of civil…

On July 7, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) revoked Iran-related General License X and issued Iran-related General License X1, for the “Revocation and Wind Down of June 21, 2026 Authorization for the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian Origin.”…

All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2026. This required reporting applies to all relevant persons, not only financial institutions.

This report is pursuant to 31…

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has launched a Reconsideration Portal for the submission of requests by persons or entities seeking to be removed from an OFAC sanctions list. The portal provides an overview of the process for requesting removal from a list as well as information on OFAC’s…

UPDATE: On July 7, 2026, this Iran-related General License X was revoked by OFAC and any activities under this general license must be wound down no later than July 17, 2026. See Thompson Hine Update of July 8, 2026 for additional details.

On June 22, 2026, the Department of the Treasury’s Office of Foreign Assets…