Last Week's Major Developments in Sanctions - September 7 to September 11, 2026

Monday, September 7

• There was no major development on this day.

Tuesday, September 8

• In a major development in the UK, the Iran (Sanctions) (Amendment) Regulations 2026 was laid in the UK Parliament. The legislation, which enters in force on 29 September imposes (previously announced) further sectoral sanctions on Iran, broadly corresponding to measures lifted by the UK and partners as part of the Joint Comprehensive Plan of Action.  It follows the UK complying with UN sanctions obligations relating to the snapback of UN Iran sanctions in October 2025. New legislation includes financial measures to reduce the ability of the Government of Iran to access the UK financial systems. It will also bring forward trade prohibitions targeting significant industries advancing Iran's nuclear escalation, including the energy, metals, gold, and software sectors, and related activities such as shipping, insurance and banking. Concurrently, the OTSI issued NTE 2026/18 expanding the UK’s sanctions regime against Iran, introducing new financial, trade and transport restrictions, alongside a set of new Schedules (1A to 1I) setting out controlled goods and technology, and also updated NTI 2946. Further, OTSI announced that subject to parliamentary approval, certain trade activities related to Shah Deniz will be permitted via a new OTSI general licence, and accordingly guidance was issued. (Here)

• OFAC imposed blocking sanctions on one individual (Egyptian national based in the UAE) and 35 entities (27 in Iran; two in UAE; one in UK; three in Turkey; one in Malaysia; one in Kazakhstan) under its counterterrorism (E.O. 13224, as amended), global terrorism and Iran sanctions programs (E.O. 13902) targeting the support of Iran's aviation industry and Mahan Air's proliferation, terrorist-linked flight operations, and illicit aircraft procurement. Concurrently, OFAC suspended indefinitely three ITSR aviation-related general licenses/authorizations:

  • 31 CFR § 560.522 (overflight payments),

  • 31 CFR § 560.529 (bunkering/emergency repairs), and

  • Iran GL J-1 (temporary sojourn of U.S.-origin civil aircraft).

• In conjunction with the suspension of the above licenses, OFAC issued General License DD, authorizing all transactions prohibited by the ITSR that are ordinarily incident and necessary to the wind down of any transaction previously authorized by the above applicable general licenses (31 CFR §§ 560.522 and 560.529, and Iran General License J-1) until September 23, 2026. Furthermore, OFAC issued Counterterrorism General License No. 37, authorizing wind-down transactions through September 23, 2026 involving ECT Aviation Support LLC, S Sistem Lojistik Hizmetler A.Ş., Mes Cargo Transportation Tourism and Foreign Trade Ltd., and any entity 50%-or-more owned by them, provided payments to blocked persons are made into a blocked, interest-bearing U.S. account. (Here)

• Alongside OFAC, FinCEN issued an alert under Operation Economic Outcast directing financial institutions to identify and report procurement networks supporting Iranian commercial airlines (Mahan Air, Iran Air) that ferry IRGC-QF personnel, weapons, and hard currency for proxies including Lebanese Hizballah and the Houthis, and that facilitate UAV/ballistic missile-related transport. The alert details Iran's use of front companies across Europe, the Middle East, Africa, and Asia to procure U.S. and Western-origin aircraft and parts and sets out seven red-flag indicators. Filers are asked to reference key term "FIN-2026-IRANAIR" in SAR field 2 and narratives, and are encouraged to also submit OFAC disclosures where sanctions violations are identified. (Here)

• FinCEN, together with the Federal Reserve, FDIC, NCUA, and OCC, issued two new FAQs (plus an amendment to a prior CIP FAQ) confirming that banks and credit unions may rely on unexpired, government-issued verifiable digital credentials (VDCs)—including state-issued mobile driver's licenses—as documentary identity verification, provided the credential evidences nationality or residence, bears a photograph or similar safeguard, and the institution can technically extract and validate the underlying data. The amended FAQ separately clarifies that non-government-issued electronic credentials or VDCs may also serve as a non-documentary verification method, so long as the issuing third party applies an authentication standard equivalent to the institution's own. (Here)

• The UK Government imposed asset freezing sanctions on five individuals under the Global Human Rights Sanctions Regime and on one entity under its Counter-Terrorism (International) Sanctions Regime. (Here)

Wednesday, September 9

• OFAC imposed blocking sanctions on three entities (one in Burma/Thailand; one in Singapore; one in Cambodia) under its Transnational Criminal Organization sanctions program (E.O. 13581) for operating and materially supporting a Chinese-language illicit marketplace used by scam centers, money launderers, and North Korean hackers to defraud Americans. The lead designee, Xinbi Guarantee, has processed over $24 billion in digital assets and fiat since 2022 and absorbed much of Huione Pay's customer base after FinCEN's Section 311 action; Singapore-based SafeW Technology and Cambodia-based Anwen were designated for building the encrypted-messaging and crypto-wallet infrastructure that migrated Xinbi's merchant and money-laundering networks. (Here)

• The U.S. Department of State designated Los Tiguerones (based in Ecuador) as a Foreign Terrorist Organization and Specially Designated Global Terrorist pursuant to INA § 219 and E.O. 13224, as amended, for narcotrafficking and attacks on civilians, law enforcement, and journalists, including the 2024 armed takeover of an Ecuadorian TV station with the designation reflected on OFAC's SDN list the same day. (Here)

• OFAC amended several FAQs (5, 13, 51, 58, 59, 74, 75, 76, 77, and 78) as part of its ongoing process of reviewing published guidance for currency of information. This batch includes review of OFAC's FAQ topic pages, OFAC Licenses, and Assessing OFAC Name Matches. OFAC also published two new license-related FAQs (FAQs 1269 and 1270). (Here)

• The U.S. Department of State publicly designated seven former Ecuadorian officials under National Security, Department of State, and Related Programs Appropriations Act, 2026, rendering them and their immediate family members generally ineligible for U.S. entry for accepting bribes from gangs linked to designated FTOs (CJNG, Los Choneros, Los Lobos, Sinaloa Cartel) in exchange for interfering with Ecuadorian judicial, electoral, or public processes. (Here)

• FinCEN's second health care fraud FTA of the year, issued pursuant to AMLA 2020 Section 6206, analyzed 5,702 BSA reports filed by 471 institutions between March 2025 and February 2026 identifying approximately $17.5 billion in suspicious activity (median $600,000/report), with depository institutions filing 89% of reports and 87% of the dollar volume. Schemes typically targeted a mix of Medicare, Medicaid, and private insurance. FinCEN points to a fraud landscape dominated by shell-like providers with no genuine medical footprint rather than legitimate practices padding claims, concentrated in home health, hospice, behavioral health, DME, and daycare lines of business, and reliant on a fairly consistent playbook of commingling government and private-insurance receipts, layering funds through circular transfers to affiliated or non-health-care entities, and cashing out via personal spending, luxury purchases, or international transfers. (Here)

• In NTE 2026/19, the ECJU announced that it has updated the existing GCAP Open General Licence and introduced a new Open General Export Licence for the Defence Export Controls Agreement, both aimed to support defence collaboration with close partners and provide simplified licensing arrangements, while maintaining the UK’s robust export controls. (Here)

Thursday, September 10

• OFAC imposed blocking sanctions on 14 individuals (9 in Iraq, 4 in Lebanon, 1 in Syria/Turkey) and 5 entities (2 in Iraq, 2 in Lebanon, 1 in UAE) under its counter-terrorism and Iran sanctions programs for enabling Kata'ib Hizballah's and Lebanese Hizballah's Iran-backed operations and Iranian sanctions evasion. The Iraq-nexus designees include four Kata'ib Hizballah commanders/members, PMC-linked facilitators tied to previously-designated al-Maksusi, and the Al-Mandalawi brothers with their Dubai hawala Shams & Bahr Trading Company which was used to move funds from Iraq to Iran via the UAE. The Lebanon-nexus designees form a cash and gold smuggling channel moving IRGC-QF funds through Lebanese and Syrian/Turkish exchange houses to Hizballah. (Here)

• OFAC announced a $1,427,230 settlement with a natural U.S. person for 39 apparent egregious, non-voluntarily-disclosed violations of the ITSR arising from management consulting and advisory services rendered to an Iranian software company and its holding vehicle across 19 virtual meetings (2019–2020), receipt of $713,615 in Iranian-origin dividends via wire transfers routed through Türkiye, the UAE, and Singapore into U.S. accounts (16 occasions), and the purchase of four Iranian real estate properties with dividend proceeds. (Here)

• Effective September 10, 2026, OFAC replaced its prior favorable licensing posture with a presumption of denial for Iran-related specific license applications under the ITSR, suspending previously issued Statements of Licensing Policy and limiting authorizations to those required by law or justified by exceptional and urgent circumstances such as risk to life, limb, or environmental safety, subject to written attestation and case-by-case review in consultation with the State Department. (Here)

• FinCEN issued a whistleblower bulletin, tied to Operation Economic Outcast, encouraging both U.S. and non-U.S. individuals to report suspected BSA and OFAC sanctions violations involving Iran, including conduct by Iranian proxies and facilitators operating outside Iran, so long as the underlying sanctions violation has a U.S. nexus. The bulletin flags typologies to watch for, including the use of high-risk jurisdictions such as Iraq, the UAE, Türkiye, and China, shipping document irregularities meant to obscure vessel identity or Iranian origin, digital asset payments tied to Iran-linked exchanges or front companies, and unusual exchange-house activity inconsistent with normal commercial patterns, as well as terrorist-financing indicators. Whistleblowers whose tips lead to a successful enforcement action yielding penalties over $1,000,000 may receive an award of 10 to 30 percent of the amount collected. (Here)

• OFSI updated its guidance, ‘Permitted travel expenses for sanctions license applications’, to clarify its expectations of applicants and align the guidance with wider OFSI guidance and current practice. The update:

  • Clarifies that the guidance applies not only to travel undertaken by designated persons, but also to travel undertaken by legal representatives or other individuals where an OFSI licence is required to make the relevant payments;

  • Reflects current practice and expectations that applicants provide sufficient evidence at the outset and that OFSI may return an incomplete application for resubmission or refuse an application where adequate evidence was not provided;

  • Confirms that in exceptional circumstances, OFSI may license a flight in a class above that which is normally permitted;

  • Clarifies that where higher-cost travel or accommodation is not justified, OFSI may license a lower amount equivalent to permitted rates (subject to receiving sufficient evidence);

  • Confirms that each application will be assessed on its own merits; and

  • Removes outdated mileage rates and updates links to other relevant guidance. (Here)

Friday, September 11

• There was no major development on this day.