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OFAC Launches “Operation Economic Outcast,” Expanding Secondary Sanctions Risks for Iran-Related Business

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On August 24, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced “Operation Economic Outcast,” a series of economic sanctions measures targeting Iran and persons that continue to maintain economic ties with Iran or facilitate the Iranian government’s access to financial resources despite already-robust U.S. primary and secondary sanctions. The measures expand the categories of Iran-related conduct that may expose non-U.S. persons to secondary sanctions and signal an increased U.S. enforcement focus on foreign parties continuing to do business with Iran.

The actions include: (i) five new sectoral sanctions determinations; (ii) suspension of certain General Licenses (GLs) and regulatory general licenses; (iii) updated guidance regarding sanctions risks associated with Iranian demands for payments or other requirements for passage through the Strait of Hormuz; and (iv) the designation of nearly 60 entities, individuals and vessels.

The Iran sanctions program is already among the most comprehensive U.S. sanctions programs. These measures therefore represent a targeted intensification of secondary sanctions pressure, coupled with a narrowing of previously available authorizations for U.S. persons.

Five New Sectoral Sanctions Determinations Under E.O. 13902
OFAC issued a determination identifying five additional sectors of the Iranian economy pursuant to Executive Order 13902:

  • Digital Assets
  • Technology
  • Gold
  • Aviation
  • Shipping

The determination took effect on August 24, 2026. As a result, persons determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate in any of these sectors of the Iranian economy may be subject to sanctions under section 1(a)(i) of E.O. 13902, regardless of their location.

Importantly, the determinations do not themselves impose comprehensive prohibitions on all dealings involving these sectors. Rather, they expand OFAC’s authority to designate persons determined to operate in them and thereby materially increase secondary sanctions risks for non-U.S. companies with Iran-related operations in these areas.

Treasury also announced that teams from the Departments of Treasury, State and War are engaging foreign governments regarding identified Iran-related activities and providing timelines for those activities to cease. Treasury further warned that financial institutions and other persons may face sanctions exposure for certain transactions involving designated or otherwise blocked persons, and that foreign financial institutions that knowingly conduct or facilitate certain significant transactions on behalf of designated persons may face U.S. correspondent or payable-through account sanctions.

Suspension of Certain General Licenses
OFAC indefinitely suspended several authorizations under the Iranian Transactions and Sanctions Regulations (ITSR):

  • 31 CFR § 560.544: Certain educational activities by U.S. persons in third countries;
  • 31 CFR § 560.550: Certain noncommercial, personal remittances to or from Iran;
  • 31 CFR § 560.554: Importation and exportation of services related to conferences in the United States or third countries;
  • Iran GL F: Authorizing certain services in support of professional and amateur sports activities and exchanges involving the United States and Iran; and
  • Iran GL G: Certain academic exchanges and the exportation or importation of certain educational services.

The suspensions became effective at 12:01 a.m. EDT on August 24, 2026.

In conjunction with the suspensions, OFAC issued GL BB, which authorizes transactions ordinarily incident and necessary to wind down transactions previously authorized by the suspended provisions through 12:01 a.m. EDT on September 8, 2026, provided that any payment to a blocked person is made into a blocked interest-bearing account located in the United States in accordance with the ITSR.

Strait of Hormuz Guidance
OFAC also updated its alert concerning sanctions risks associated with Iranian demands for “toll” payments and other requirements imposed in connection with passage through the Strait of Hormuz.

OFAC warned that U.S. and non-U.S. persons could face sanctions risks by engaging with the designated Persian Gulf Strait Authority, Persian Gulf Marine Insurance Company and HormuzSafe Marine Services Authority, including by accepting insurance or other services or responding to information demands or other requirements in exchange for guarantees of safe passage, even if there is no associated payment or other exchange of value.

The alert is particularly significant for shipping companies, insurers, financial institutions, vessel operators, and other maritime service providers. OFAC strongly encouraged maritime stakeholders to conduct enhanced due diligence regarding vessels seeking to transit the Strait and to carefully assess requests from Iranian authorities or Iran-linked service providers.

Nearly 60 New Designations
OFAC designated nearly 60 entities, individuals, and vessels in multiple jurisdictions that it found to enable the Iranian regime’s illicit activities, including:

  • Shadow Fleet and Oil Revenue Networks: OFAC targeted a network of vessel brokers, bunkering service providers, and financial intermediaries operating across the UAE, Hong Kong, China, Singapore, Switzerland and other jurisdictions that facilitate the transportation and delivery of Iranian crude oil to markets in East Asia. Multiple shadow fleet vessels responsible for transporting millions of barrels of Iranian crude oil and petroleum products were also designated.
  • Nuclear and Missile Technology Procurement: OFAC targeted a network of more than 20 entities and individuals spanning the Middle East and East Asia that support the procurement of critical technology for Iran’s nuclear research and missile development programs, including entities facilitating acquisitions for U.S.-, UN- and EU-sanctioned Malek Ashtar University of Technology.
  • Malicious Cyber Activity: OFAC designated members of an Iranian cyber group directed by Iran’s Ministry of Intelligence and Security that is responsible for extensive compromises of U.S. critical infrastructure and financially motivated cyber theft, including digital asset heists.

Looking Ahead
The August 24 measures materially increase secondary sanctions risk for non-U.S. companies with Iran-related activities, particularly those operating in or providing services involving the digital asset, technology, gold, aviation and shipping sectors. Companies with potential Iran touchpoints should consider reviewing counterparties, payment channels, ownership structures, vessel relationships and other Iran-related exposure in light of the new sectoral determinations and designations.

Treasury has characterized Operation Economic Outcast as the beginning of a sustained campaign and has stated that it intends to accelerate U.S. sanctions enforcement. Additional OFAC guidance may therefore further clarify the scope and practical implications of these measures.