�鶹ֱ��

Key Takeaways

• Iran: maximum pressure, operationalized. The Office of Foreign Assets Control (OFAC) designated dozens of Iranian airlines, suspended long-standing aviation and humanitarian-adjacent general licenses, sanctioned Russia’s VTB Bank, and adopted a presumption of denial for Iran-related specific license applications.
• Cuba: a new regulatory regime. OFAC published new Cuba sanctions regulations, implementing Executive Order (EO) 14404 and amended the Cuban Assets Control Regulations (CACR) to restrict indirect dealings with Cuba Restricted List entities, eliminate the U-turn authorization, and remove group people-to-people and professional-meeting travel authorizations, all effective September 30, 2026.
• Program wind-downs and delistings. The Ethiopia program ended with the expiration of the EO 14046 emergency; OFAC amended the Terrorism List Governments Sanctions Regulations following the rescission of Syria’s State Sponsor of Terrorism designation; and selective delistings occurred under Belarus, Russia, and Democratic Republic of the Congo (DRC) programs.
• Enforcement architecture. OFAC consolidated its penalty and enforcement-procedure provisions into new Sanctions Penalties Regulations (31 C.F.R. Part 505) and removed more than 100 duplicative subparts across its chapter of the CFR.
• Russia and Venezuela licensing. OFAC continued to calibrate licensing for the Lukoil International GmbH divestiture (GL 131J) and Venezuela (GL 49B and other amended licenses).

At a Glance: Principal September Actions

Iran: Operation Economic Outcast Expands Across �鶹ֱ��

Iran was again the dominant focus of U.S. sanctions activity in September. The Treasury framed its actions under the banner of “Operation Economic Outcast,” a Treasury-led campaign that the State Department describes as seeking to isolate the Iranian regime completely from the financial lifelines sustaining its conduct. Many designations were made under Executive Order 13902, which targets additional sectors of Iran’s economy, including its financial sector, and carries secondary sanctions exposure for non-U.S. persons.

Aviation sector designations and suspension of general licenses (September 8, 2026)

On September 8, OFAC designated a large slate of Iranian passenger and cargo carriers, including Iran Air Tour, Iran Aseman Airlines, Kish Airlines, Qeshm Air, Zagros Airlines, Taban Airlines, and many newer carriers, together with aviation-support companies in the United Arab Emirates, the United Kingdom, Turkey, Malaysia, and Kazakhstan linked to Mahan Air. Concurrently, OFAC indefinitely suspended the ITSR general licenses at 31 C.F.R. § 560.522 (overflight payments), § 560.528 (aircraft safety), and § 560.529 (bunkering and emergency repairs), as well as Iran General License J-1 (temporary sojourn of civil aircraft). OFAC issued General License DD to authorize wind-down of transactions previously authorized under §§ 560.522 and 560.529 and GL J-1 through September 23, 2026, and Counter Terrorism General License 37 to authorize wind-down of transactions involving certain persons blocked that day.

These measures build on OFAC’s August 24 suspension of the ITSR authorizations for certain educational activities, noncommercial personal remittances, conference-related services, and General Licenses F (sports) and G (academic exchanges), whose GL BB wind-down period ended September 8. Companies that relied on these authorizations, including airlines, lessors, MRO providers, ground handlers, universities, and remittance providers, should confirm that all relevant activity has ceased.

Presumption of denial for Iran-related specific licenses (September 10, 2026)

OFAC announced that, effective immediately, it will consider Iran-related specific license applications under a presumption of denial, except as required by law or in certain circumstances such as risk to life, limb, or environmental safety. This is a significant departure from prior case-by-case review. Pending applications should be reassessed, and businesses should not assume that a specific license will be available to address legacy exposure. The same day, OFAC designated Iraqi and Lebanese individuals and entities linked to Kata’ib Hizballah and Hizballah’s financial networks, including Lebanese exchange houses and a Dubai-based trading company designated under EO 13902.

Financial sector: VTB Bank and digital assets (September 14 and 17, 2026)

On September 14, the United States sanctioned VTB Bank, one of Russia’s largest financial institutions, under EO 13902. The State Department stated that VTB opened offices in Iran, built banking ties with sanctioned Iranian financial institutions, and worked to move billions of dollars in Iranian assets, and warned that governments and financial institutions considering similar arrangements face exposure to U.S. financial restrictions. On September 17, OFAC designated the Iranian digital-asset platform Bitbank and its operator, Pishtaz Simorgh Electronic Trade Company, as well as associated individuals.

Regulatory codification and continued designations (September 29–30, 2026)

OFAC amended the ITSR to implement certain provisions of EO 13902, revise an existing definition and exemption, and incorporate two exemptions from that order, effective September 30, 2026. On September 29, OFAC also designated Iranian military procurement networks alongside counter-narcotics designations of the Sinaloa Cartel’s Los Mayos faction and associated corruption networks. Separately, the State Department issued a September 22 advisory on luxury goods and wholesale club transaction risks with Iranian officials under the Foreign Missions Act.

Enforcement

On September 10, OFAC announced that an individual agreed to pay $1,427,230 to settle potential civil liability for providing management consulting and advisory services to a leading Iranian software company, receiving Iranian-origin dividends into U.S. bank accounts, and acquiring real property in Iran. OFAC determined that the apparent violations were egregious and not voluntarily self-disclosed and stated that its enforcement campaign against the U.S. and foreign persons who violate Iran sanctions will continue under Operation Economic Outcast. The case is a reminder that individuals, including dual nationals and those with family or investment ties to Iran, are squarely within OFAC’s enforcement focus.

Cuba: New Cuba Sanctions Regulations and CACR Amendments

On September 17, 2026, OFAC designated Cuban state-owned enterprises under EO 14404, including entities in the Moa and Nicaro nickel complex (such as Pinares S.A. and Ceproniquel) and defense research and development centers, along with several individuals. The State Department described the action as targeting Cuba’s mineral wealth and military modernization apparatus.

On September 29, 2026, OFAC announced a broader regulatory package that took effect upon Federal Register publication on September 30, 2026:

• Cuba Sanctions Regulations. New regulations implementing EO 14404 of May 1, 2026, “Imposing Sanctions on Those Responsible for Repression in Cuba and Threats to the United States National Security and Foreign Policy.”
• CACR amendments. Amendments that, among other things, add a prohibition on indirect financial transactions with entities or subentities on the State Department’s Cuba Restricted List, remove the authorization for “U-turn” transactions, and remove the authorizations for group people-to-people travel and professional meetings in Cuba.
• Guidance. Five new Cuba-related FAQs (1271–1275), 29 amended FAQs, and an OFAC Alert, “Expanded Sanctions Against Cuba,” highlighting increased sanctions risk for Cuba-related transactions.

Banks and payment processors should revisit Cuba-related screening logic, particularly given the extension to indirect transactions with Cuba Restricted List entities and the loss of the U-turn authorization. Travel providers, event organizers, and companies sending personnel to Cuba should reassess reliance on the eliminated travel categories.

Russia and Venezuela: Targeted Licensing Adjustments

On September 18, 2026, OFAC issued Russia-related General License 131J, authorizing certain transactions for the negotiation of and entry into contingent contracts for the sale of Lukoil International GmbH and related maintenance activities, and amended FAQs 1224 and 1225. Parties involved in the Lukoil divestiture process should review the revised terms closely, as each iteration of this license has adjusted scope and conditions. OFAC also removed certain persons from the Specially Designated Nationals (SDN) List under Russia-related authorities on September 16.

For Venezuela, OFAC issued amended general licenses on September 2, 14, and 16, and on September 28 issued General License 49B, which replaced and superseded GL 49A in its entirety effective that date. GL 49B, like its predecessor, excludes transactions involving persons in Russia, Iran, North Korea, Cuba, or China (or entities owned or controlled by or in a joint venture with such persons), the unblocking of property blocked under the Venezuela Sanctions Regulations, and transactions involving blocked vessels. Companies operating under Venezuela authorizations should confirm they are relying on the current version of each license.

Program Terminations, Delistings, and Syria

• Ethiopia. The national emergency declared in EO 14046 (September 17, 2021) expired. OFAC removed persons designated under that order from the SDN List, including the Eritrean Defense Forces, the People’s Front for Democracy and Justice, Red Sea Trading Corporation, and Hidri Trust, and withdrew program FAQs.
• Syria. On September 24, OFAC amended the Terrorism List Governments Sanctions Regulations to implement changes resulting from the rescission of Syria’s designation as a State Sponsor of Terrorism, removing and reserving a Syria-specific general license that is no longer necessary.
• Belarus and DRC. OFAC removed several Belarusian entities, including Lakokraska OAO and the Bellesbumprom timber and pulp-and-paper concern, on September 17, and removed certain DRC-related designations on September 23.

Delistings create commercial opportunity — but also compliance traps. Companies should confirm that a counterparty is no longer subject to other U.S. measures (such as export controls or other sanctions programs) and to non-U.S. sanctions regimes before resuming business.

Regulatory Overhaul: The New Sanctions Penalties Regulations

On September 24, OFAC announced new Sanctions Penalties Regulations at 31 C.F.R. Part 505 (91 Fed. Reg. 60821), consolidating previously dispersed information on enforcement procedures and penalties, including the rights of U.S. persons under investigation, into a single part. In a companion final rule effective September 30, 2026, OFAC removed duplicative penalty provisions from dozens of program-specific parts, replacing them with cross-references to Part 505, and relocated provisions on delegations of authority, recordkeeping and reporting, and the Paperwork Reduction Act to an expanded initial subpart in each part. OFAC states that these changes eliminate more than 100 subparts.

While largely structural, the reorganization means that compliance manuals, policies, training materials, and contracts that cite specific program-level penalty or reporting provisions may now contain outdated citations and should be updated.

Other Notable Developments

• On September 9, OFAC designated targets under its transnational criminal organizations and counter terrorism authorities and issued new and amended FAQs; the State Department announced actions against the Xinbi Guarantee transnational criminal organization and the terrorist designation of Los Tiguerones.
• On September 16, the State Department announced sanctions on officials of the Palestinian Authority and members of the Palestine Liberation Organization, and on September 21 announced visa restrictions on 32 individuals connected to the Prince Group TCO.
• OFAC reminded holders of blocked property of the obligation to file the 2026 Annual Report of Blocked Property and published its quarterly TSRA licensing report covering April through June 2026.

Practical Recommendations

• Rescreen and reassess Iran exposure. Update screening for the September designations, particularly in aviation, digital assets, and correspondent banking, and evaluate secondary sanctions risk for non-U.S. affiliates dealing with EO 13902 targets such as VTB Bank.
• Inventory reliance on suspended or amended licenses. Identify any activity that relied on suspended ITSR general licenses, the eliminated CACR authorizations, or superseded Russia and Venezuela licenses, and confirm wind-down periods have been observed.
• Plan around a presumption of denial. Do not build business plans that assume Iran-related specific licenses will be granted; consider whether pending applications should be withdrawn, supplemented, or reframed around the stated exceptions.
• Update Cuba controls. Revise payment-screening rules to capture indirect transactions with Cuba Restricted List entities and to remove reliance on U-turn processing.
• Refresh compliance documentation. Update citations to penalty, recordkeeping, and reporting provisions to reflect Part 505 and the September 30 reorganization.
• Validate delistings before re-engaging. Confirm that delisted parties are not subject to other U.S. or non-U.S. restrictions before resuming dealings.

How �鶹ֱ�� & Lardner LLP Can Help

Our international trade and national security team regularly advises companies, financial institutions, and investors on OFAC compliance, licensing, voluntary self-disclosures, enforcement defense, and sanctions risk in cross-border transactions. Please contact the author or your �鶹ֱ�� & Lardner LLP relationship partner with any questions about how these developments affect your business.