OFAC Increases the Scope of Sanctions on Iran

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 U.S.-origin aircraft and sensitive technology. The Middle East terrorism-related sanctions involve entities and individuals that support Kata’ib Hizballah (KH) and Hizballah.

Aviation Sanctions

Under the September 8 sanctions, twenty-seven (27) additional Iranian airlines and entities supporting the Iranian aviation sector have been designated and placed on OFAC’s Specially Designated Nationals (SDN) List.  See here for additional identifying information on these entities.  As a result of these actions, all property and interests in property of the designated entities 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 OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons that involve any property or interests in property of blocked persons. Engaging in certain transactions involving these SDN listed entities also risks the imposition of secondary sanctions on participating foreign financial institutions. 

Concurrently, OFAC suspended three Iran-related aviation authorizations that previously allowed certain limited aviation activities.  These include authorizations that allowed for overflights (31 C.F.R. § 560.522), and for non-U.S. airlines to fly U.S.-origin or U.S.-controlled commercial aircraft into Iran (31 C.F.R. §§ 560.528 and 560.529).  OFAC will consider aviation safety-related requests on a case-by-case basis.  Further Iran General License J-1 that allowed for reexportation of certain civil aircraft to Iran on temporary sojourn has been indefinitely suspended.  OFAC issued Iran General License DD authorizing the all transactions that or ordinarily incident and necessary to the wind down of any transactions covered by the suspension of the above authorizations until 12:01 am (EDT), September 23, 2026.

Terrorism Sanctions

Under the September 10, terrorism-related sanctions, OFAC sanctioned a number of KH and Hizballah commanders and members, as well as certain Iraqi businessmen aiding in sanctions evasion.  See here for additional identifying information on these persons.

Other OFAC Actions

OFAC has also modified its Iran-related specific licensing policy. Effective immediately, OFAC is considering Iran-related specific license applications with a “presumption of denial” except as required by law or in certain circumstances, such as risk to life, limb, or environmental safety.

In addition, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Alert  asking financial institutions to report procurement networks supporting Iran’s aviation industry. 

For additional information on recent OFAC Iran sanctions activities, see SmarTrade post of August 25, 2026.