Weekly News Digest - August Week Four

Major Iran escalation.

On August 24, OFAC launched a significant new Iran sanctions package and indefinitely suspended the effectiveness of several General Licenses under the Iranian Transactions and Sanctions Regulations (ITSR). OFAC also issued an alert concerning sanctions risks associated with Iranian demands for passage through the Strait of Hormuz. ofac.treasury.gov

This is particularly important for banks, payment processors and counsel handling Iran-origin funds, family remittances, humanitarian transactions, EB-5/source-of-funds matters and blocked transfers. Transactions previously analyzed primarily under a General License should be re-screened against the August 24 changes rather than relying on an earlier GL analysis

 Treasury simultaneously imposed a broad new round of Iran-related designations
aimed at military procurement, petroleum/petrochemical trading and associated international networks. The campaign reached intermediaries and businesses outside Iran, including entities operating through the UAE and Asia.

UAE banking exposure became a particular focus. On August 28, Treasury announced another Iran-related action specifically targeting Iran's access to UAE banks under what Treasury calls Operation Economic Outcast. ofac.treasury.gov

For compliance purposes, this reinforces the need for enhanced diligence where a transaction has an apparently UAE-based payer, beneficiary or trading company but potentially involves Iranian ownership, Iranian underlying trade, Iranian-origin funds or an Iranian ultimate beneficiary. Simply routing a transaction through a UAE company or bank does not remove the underlying sanctions analysis.

Venezuela licensing changed again
OFAC issued amended Venezuela-related General Licenses and associated FAQs on August 27. ofac.treasury.gov

Any Venezuela opinion or transaction structure relying on an existing GL should therefore use the current August 27 version, not a previously downloaded license.

Russia / counterterrorism
On August 26, OFAC issued counterterrorism designations, a counterterrorism General License and an amended Russia-related General License. ofac.treasury.gov

Syria moved toward further sanctions normalization 
On August 24, the State Department removed Syria's State Sponsor of Terrorism designation. OFAC consequently stated that Syria is no longer subject to the Terrorism List Governments Sanctions Regulations restrictions applicable on that basis. HTS was also removed from the SDN List following revocation of its SDGT designation. ofac.treasury.gov

This does not mean Syria is sanctions-free. OFAC continues targeted sanctions against Assad and associates, human-rights abusers, Captagon traffickers, proliferation actors, ISIS/Al-Qaida affiliates, and Iran/proxy networks. ofac.treasury.gov