Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

On June 21, 2026, OFAC issued Iran-related General License X (GL X), authorizing transactions otherwise prohibited under the Iranian Transactions and Sanctions Regulations (31 CFR part 560), the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587), the Ukraine-/Russia-Related Sanctions Regulations (31 CFR part 589), and WMD-proliferation sanctions authorities — including new purchases and loadings of Iranian-origin crude oil, petrochemical, and petroleum products, a materially broader carve-out than the cargo-already-loaded window granted by the preceding General License U. Just 16 days later, on July 7, 2026, OFAC issued General License X1, revoking and superseding GL X: as of that date new purchases or loadings of Iranian-origin crude oil, petrochemical, or petroleum products were no longer authorized. GL X1 itself subsequently expired. OFAC formally published both web licenses in the Federal Register on September 30, 2026 — a retrospective publication of licenses already issued and, by then, already revoked and expired.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced on 18 May 2026 that Adani Enterprises Limited (AEL), a flagship publicly traded entity of India's Adani Group (NSE: ADANIENT), agreed to pay $275,000,000 to settle apparent civil liability for violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) arising from AEL's purchases of liquefied petroleum gas (LPG) shipments through a Dubai-based commodity trader between November 2023 and June 2025, where red flags should have placed AEL on notice that the LPG originated from Iran. Approximately $192 million in payments for the Iranian-origin LPG shipments were processed through US financial institutions, providing the US nexus for OFAC jurisdiction. OFAC determined the apparent violations were EGREGIOUS and not voluntarily self-disclosed; AEL did not admit fault but committed to implementing enhanced compliance measures. The settlement is the largest OFAC enforcement action against an Indian corporate entity on record and was announced concurrently with parallel DOJ and SEC resolutions forming part of a broader US legal-relief package for the Adani Group.

On May 1, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated China-based independent ("teapot") refinery Hengli Petrochemical (Dalian) Refinery Co., Ltd. — described as China's second-largest teapot — together with approximately 40 shipping firms and vessels operating as part of Iran's shadow fleet. OFAC sanctioned 19 shadow-fleet vessels (crude, LPG, and petrochemical tankers) as blocked property of designated owners or managers. The action was taken under Executive Order 13902 (Iran petroleum and petrochemical sectors) in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. Treasury press release SB0472. Concurrent with the designations, OFAC issued Iran-related General License W authorising the wind-down of transactions involving the persons newly blocked on May 1, 2026, and published a structurally novel Iran-related Alert, "Sanctions Risks of Iranian Demands for Strait of Hormuz Passage." The Alert states that payments to the Government of Iran or the IRGC — directly or indirectly — for safe passage through the Strait of Hormuz are not authorised for US persons (including US financial institutions) or US-owned/-controlled foreign entities. OFAC also issued new FAQ 1250 to accompany the Alert and GL W. The wave is one of the largest single-day Iran enforcement actions of the Trump 2.0 administration. Treasury characterises it as part of a campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The Strait of Hormuz Alert is the operational US response to Iranian regulatory threats against the ~20% of global oil and ~25% of global LNG transiting Hormuz, putting tanker owners, P&I clubs, flag states, and oil-buyer compliance teams on direct notice.

On April 24, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) added 19 entities and 19 vessels to the Specially Designated Nationals (SDN) List under Executive Order 13902 (Iran petroleum and petrochemical sectors), in furtherance of National Security Presidential Memorandum-2 (NSPM-2) of February 4, 2025. The action is the first OFAC designation of a Chinese independent ("teapot") refinery — Hengli Petrochemical (Dalian) Refinery Co., Ltd., described as one of Iran's largest single customers for crude oil and petroleum products, having purchased billions of US dollars' worth since at least 2023 from cargoes brokered by Sepehr Energy Jahan Nama Pars Company (the oil sales arm of Iran's Armed Forces General Staff, controlled by the Ministry of Defense / MODAFL). Co-designations span shipping firms and vessels registered in China, Hong Kong, Panama, Marshall Islands, Liberia, and Vietnam. Concurrent with the designations, OFAC issued Iran-related General License V authorising a 30-day wind-down (through May 24, 2026) of transactions involving Hengli Petrochemical (Dalian) Refinery Co., Ltd. and certain majority-owned entities. Treasury press release SB0472 ("Economic Fury Targets Global Network Fueling Iran's Oil Trade and Shadow Fleet") frames the action as part of the maximum-pressure campaign that has sanctioned over 1,000 Iran-related persons, vessels, and aircraft since February 2025. The April 24 designations directly triggered the first-ever operational use of China's Blocking Rules (MOFCOM Announcement No. 21 of May 2, 2026) and preceded a second OFAC Iran wave on May 1, 2026 (General License W + Strait of Hormuz Sanctions Risk Alert).

On March 20, 2026, OFAC issued Iran-related General License U (GL U), temporarily authorizing the sale, delivery, offloading and — notably, for the first time in decades — importation into the United States of Iranian-origin crude oil and petroleum products, but only for cargo already loaded onto vessels as of 12:01 a.m. EDT that day. The window ran through April 19, 2026, after which the authorization lapsed. The license excluded any transaction touching Cuba, North Korea, or Russian-government-controlled areas of Ukraine, and did not waive any other, non-Iran sanctions program. OFAC formally published GL U (and the separate, entity-specific GL V wind-down license for Hengli Petrochemical) in the Federal Register on June 10, 2026 — a retrospective publication of licenses already issued and, by then, already expired.

The Council of the EU adopted Implementing Regulation (EU) 2026/262, implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran's military support to Russia's war of aggression against Ukraine. The listing adds 4 individuals and 6 entities to the EU asset freeze, bringing the total under this regime to 24 individuals and 26 entities. Newly listed entities include Fanavaran Sanat Ertebatat Company and front-company trader Sahara Thunder (UAV electronic components and guidance systems), and Shahid Bagheri Industrial Group, Khojir Missile Development and Production, and procurement firm Pishgaman Tejarat Rafi Novin Co. (ballistic missile manufacturing and propellant-precursor procurement). All funds and economic resources of the listed parties are frozen within the EU, and EU persons/entities are barred from making funds available to them.

On 29 January 2026, the Council of the European Union adopted Council Implementing Regulation (EU) 2026/267 and the accompanying Council Decision, implementing the EU's Iran human-rights restrictive-measures regime (Regulation (EU) No 359/2011, in place since 2011 and renewed annually). The package designates 15 individuals and 6 entities over the violent repression of peaceful protests, arbitrary detention, and internet/media censorship in Iran, bringing the regime's cumulative total to 24 individuals and 26 entities. The six newly listed entities are the Iranian Audio-Visual Media Regulatory Authority (SATRA), the IRGC-linked Seraj Cyberspace Organization, the Working Group for Determining Instances of Criminal Content (WGDICC), Yaftar Pazhohan Pishtaz Rayanesh Limited Company, Douran Software Technologies, and Masaf Institute. Designated parties are subject to an EU-wide asset freeze and a prohibition on making funds or economic resources available to them; listed individuals additionally face a travel ban.

On January 23, 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated eight vessel-owning/management firms — based in the UAE, India, Oman, the Seychelles, and the Marshall Islands — and identified nine of their tankers as blocked property, for transporting hundreds of millions of dollars' worth of Iranian crude oil, LPG, naphtha and high-sulfur fuel oil to buyers across East Asia, South Asia and East Africa. The action was taken under Executive Order 13902 (Iran petroleum/petrochemical sector) as part of the maximum-pressure campaign under National Security Presidential Memorandum 2, and OFAC concurrently issued General License T authorizing limited safety, environmental and cargo-offloading transactions involving the newly blocked vessels.

The US Treasury's Office of Foreign Assets Control designated 18 individuals and entities that make up the "rahbar" shadow-banking networks of sanctioned Iranian banks Bank Melli and Shahr Bank, including Singapore-based Golden Mist PTE Ltd, UAE-based Empire International Trading FZE and HMS Trading FZE, Iran-based Nikan Pezhvak Aria Kish Company and Tejarat Hermes Energy Qeshm, and UK-based Nanshan Ltd. Separately, OFAC designated senior Iranian security officials, including SCNS Secretary Ali Larijani, for their role in the regime's violent crackdown on peaceful protesters that began in December 2025. The financial designations were made under E.O. 13902 (Iran's financial/petroleum/petrochemical sectors) and the human-rights designations under E.O. 13553 and E.O. 13876, in furtherance of NSPM-2; Treasury noted it sanctioned more than 875 persons, vessels, and aircraft under the same maximum-pressure campaign in 2025.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) designated 10 individuals and entities in Venezuela and Iran on 30 December 2025 for facilitating Iran's proliferation of unmanned aerial vehicles (UAVs) and ballistic-missile inputs. Venezuela-based Empresa Aeronautica Nacional SA (EANSA) and its chair, Jose Jesus Urdaneta Gonzalez, were designated for negotiating directly with Iran's Qods Aviation Industries (QAI) and overseeing local assembly of QAI's Mohajer-series UAVs, re-branded in Venezuela as the ANSU series — an arrangement OFAC states has run since 2006. Separately, three Iran-based persons were designated for procuring sodium perchlorate, sebacic acid and nitrocellulose — precursor chemicals for ballistic-missile propellant and warhead production — on behalf of Parchin Chemical Industries (PCI), a unit of Iran's Defense Industries Organization (DIO). The action was taken under Executive Order 13382 (WMD proliferators and supporters) and Executive Order 13949 (Iran conventional-arms activities), in furtherance of National Security Presidential Memorandum 2.

On December 18, 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated 29 shadow-fleet vessels and 17 vessel-management/shipping firms — plus Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr and two of his UAE-registered companies (Red Sea Ship Management LLC and High Seas Petroleum LLC) — under Executive Order 13902 for operating in Iran's petroleum sector. The vessels, flagged across Palau, Panama, Cook Islands, Barbados, Jamaica and unknown registries, are said to have transported "hundreds of millions of dollars'" worth of Iranian crude oil, fuel oil, bitumen, naphtha and condensate to buyers in Asia. Treasury frames the action as part of a campaign that has sanctioned more than 180 vessels since President Trump resumed office in January 2025, implementing NSPM-2 maximum-pressure policy.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into a $3,103,360 settlement with Exodus Movement, Inc., a U.S.-incorporated non-custodial / self-custody crypto wallet software company, to resolve 254 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560) committed between October 17, 2017 and January 4, 2019. Exodus customer-support staff provided technical and account-related support — and in 12 of the 254 instances recommended the use of virtual private networks (VPNs) to circumvent partner-exchange geoblocking controls — to users who self-identified as located in Iran, in violation of the ITSR's prohibition on the export of services to Iran (§ 560.204) and, for the 12 egregious cases, the facilitation prohibition (§ 560.203). OFAC deemed the 12 VPN-coaching cases "egregious" because Exodus personnel were generally aware of U.S. sanctions and the company's own terms of use prohibited Iran usage, yet support staff actively helped Iranian users evade controls. Exodus separately committed to invest $630,000 in additional sanctions compliance controls. The settlement is structurally novel as the first OFAC enforcement action against a Web3-infrastructure / non-custodial wallet-software vendor and establishes that OFAC will assert jurisdiction over self-custody software providers based on customer-support facilitation conduct, not just custodial flow control.

The US Treasury's Office of Foreign Assets Control designated 32 individuals and entities based in Iran, the UAE, Turkiye, China, Hong Kong, India, Germany and Ukraine for operating procurement networks that supply Iran's ballistic missile and UAV programmes, including missile propellant precursors and UAV components. The action is Treasury's second round of nonproliferation sanctions since the 27 September 2025 reimposition of UN sanctions on Iran ("snapback") over its non-compliance with international nuclear and missile commitments. Designated entities include Iran-based Kimia Part Sivan Company (KIPAS), which Treasury says has worked with the IRGC-Qods Force to advance Iran's UAV programme. All property and interests of the designated parties subject to US jurisdiction are blocked, and US persons are generally prohibited from transacting with them.

New Zealand's 33rd sanctions round under the Russia Sanctions Act 2022 designated 65 "shadow fleet" tanker vessels involved in transporting Russian-origin crude oil, together with seven entities and two individuals based in Russia, Belarus, North Korea and Iran that refine or transport Russian oil or facilitate oil-related payments. Designated parties are subject to asset freezes and prohibitions on the supply of services (including port access, insurance, chartering and cargo handling) by New Zealand persons. The measure targets the revenue chain funding Russia's war in Ukraine rather than imposing a new tariff or trade-flow control.

On 9 October 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals, entities and vessels for facilitating Iranian crude oil, petroleum-product and liquefied petroleum gas (LPG) exports, in a coordinated action with the State Department. The network included 33 vessels transporting Iranian crude and LPG, shipping entities registered in Panama, the Marshall Islands, Ukraine and Liberia, an Iranian petrochemical producer, four Turkish petrochemical trading entities, five Chinese entities importing/refining/storing Iranian petroleum (including a China-based petrochemical-terminal operator, Jiangyin Foreversun Chemical Logistics Co., Ltd.), three Singapore-based logistics entities, and 27 entities based in Hong Kong, the UAE and India engaged in trading and shipping. The action was taken pursuant to the National Security Presidential Memorandum 2 (NSPM-2) maximum-pressure campaign against Iran and blocks all US property/interests of the designated parties, exposing non-US counterparties to secondary-sanctions risk.

The US Treasury's Office of Foreign Assets Control designated 21 entities and 17 individuals across three procurement networks supplying Iran's Ministry of Defense and Armed Forces Logistics (MODAFL) and its subordinate weapons producers. The networks sourced ballistic-missile guidance components (accelerometers, gyroscopes, MEMS) for the Shahid Bakeri Industrial Group and Shahid Hemmat Space Group, dual-use radar/missile-guidance electronics routed through Hong Kong and China for Shiraz Electronics Industries, and helicopter parts — including a US-origin helicopter — routed through Germany, Türkiye, Portugal and Uruguay for Iran Helicopter Support and Renewal Company (PANHA). The action is Treasury's first nonproliferation-sanctions tranche following the 27 September 2025 UN Security Council "snapback" reimposing pre-JCPOA sanctions on Iran.

The US Treasury's Office of Foreign Assets Control designated two Iranian financial facilitators — Alireza Derakhshan and Arash Estaki Alivand — along with more than a dozen Hong Kong- and UAE-based individuals and entities for operating a shadow-banking network that laundered proceeds from Iranian oil sales through front companies and cryptocurrency. The designated addresses account for over $600 million in total inflows, including more than $100 million in cryptocurrency purchases tied to oil sales between 2023 and 2025. Proceeds are alleged to benefit the IRGC-Qods Force and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). This is the second round of OFAC sanctions targeting Iran's shadow-banking infrastructure since National Security Presidential Memorandum 2 (NSPM-2) directed a maximum-pressure campaign on Iran in February 2025.

New Zealand's 32nd sanctions round under the Russia Sanctions Act 2022 (Russia Sanctions Amendment Regulations (No 4) 2025, SL 2025/195) lowered the price cap on Russian-origin crude oil (HS 2709) from US$60/bbl to US$47.60/bbl, a roughly 21% cut, aligning New Zealand with the EU, UK and Canada's most recent price-cap reductions. The same instrument designated 19 individuals and entities plus 19 vessels, including Russia's GRU cyber unit 29155 (implicated in malware attacks on Ukrainian government networks), actors involved in chemical-weapons use and disinformation, additional "shadow fleet" tankers, alternative payment providers, and third-country facilitators based in North Korea and Iran supporting Russia's war effort.

On 3 September 2025, OFAC announced a civil penalty settlement with Fracht FWO Inc. — a Houston, Texas-based freight forwarder and US subsidiary of Switzerland-headquartered Fracht AG — under which the company agreed to pay USD 1,610,775 to settle its potential civil liability for apparent violations of multiple OFAC sanctions programs. The violations arose from Fracht FWO's brokering of cargo shipments involving EMTRASUR, a wholly owned subsidiary of OFAC-designated Venezuelan state airline CONVIASA, on a Mexico-to-Argentina route on which Iranian crew members were subsequently discovered. Fracht self-initiated a voluntary disclosure to OFAC after learning of the Iranian crew involvement, triggering mitigating credit, and undertook extensive remedial compliance measures. The settlement resolves apparent violations of the Venezuela Sanctions Regulations (VSR), Weapons of Mass Destruction Proliferators Sanctions Regulations (WMDPSR), Global Terrorism Sanctions Regulations (GTSR), and Iranian Transactions and Sanctions Regulations (ITSR).

On 2 September 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated Waleed Khaled Hameed al-Samarra'i, a dual Iraqi/St Kitts-and-Nevis citizen, along with his UAE-based shipping manager Babylon and five Marshall Islands-registered shell companies (Tryfo Navigation, Keely Shiptrade, Odiar Management, Panarea Marine, Topsail Shipholding) that hold registered ownership of nine Liberia-flagged tankers (ADENA, LILIANA, CAMILLA, DELFINA, BIANCA, ROBERTA, ALEXANDRA, BELLAGIO, PAOLA). The network blends Iranian crude with Iraqi oil via ship-to-ship transfers in the Arabian Gulf and at Iraqi ports, then markets the blend as solely Iraqi-origin to evade US sanctions, generating hundreds of millions of dollars for the Iranian regime and al-Samarra'i. The action was taken pursuant to Executive Order 13902 and blocks all US property and interests of the designated individual, entities and vessels.

The US Treasury's Office of Foreign Assets Control designated five entities and one individual based in Iran, Hong Kong, Taiwan and China for procuring CNC (computer numerical control) machine tools on behalf of Iran Aircraft Manufacturing Industrial Company (HESA), the state-owned defense-ministry subsidiary that builds Iran's Ababil-series military UAVs used by the IRGC. Designated parties include Javad Alizadeh Hoshyar, CEO of Iran-based Control Afzar Tabriz Co Ltd, which used Hong Kong-based Clifton Trading Limited as an intermediary to obscure CNC-machine shipments to HESA, and Taiwan-based Mecatron Machinery Co Ltd and Joemars Machinery and Electric Industrial Co Ltd, which shipped CNC machines toward Iran through similar concealment channels. The action was taken pursuant to National Security Presidential Memorandum 2 (NSPM-2), which directs that Iran be denied conventional and asymmetric weapons capabilities. All designated parties' US property and interests are blocked and US persons are generally barred from transacting with them.

On 30 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals and entities and identified more than 50 vessels belonging to the shipping empire of Mohammad Hossein Shamkhani, son of Ali Shamkhani, a top political adviser to Iran's Supreme Leader. Treasury described the action — over 115 sanctions in total — as its largest Iran-related action since 2018. The network launders billions of dollars from sales of Iranian and Russian crude oil and petroleum products (mostly to buyers in China) through vessels and front companies registered across the UAE, Hong Kong, India, Cyprus, Panama, Romania, China, Liberia, the Marshall Islands and Seychelles. Concurrently, the State Department designated 20 entities and identified 10 vessels under E.O. 13846 and E.O. 13902 for trading and transporting Iranian petroleum and petrochemical products.

On 22 July 2025, the US Treasury's Office of Foreign Assets Control designated two individuals and five entities under Executive Order 13224 for facilitating revenue generation and material support to the Houthis (Ansarallah) through petroleum importation and money laundering. The network — Muhammad Al-Sunaydar's Arkan Mars petroleum companies (Yemen/UAE) and Yahya Mohammed Al Wazir's Al-Saida Stone for Trading and Agencies and Amran Cement Factory — coordinated roughly $12 million of Iranian petroleum imports through the Houthi-controlled Ras Isa port with an Iranian IRGC-linked petrochemical trading entity, and laundered approximately €6 million through bulk-coal front-company transactions. The action builds on a cadence of OFAC designations against Houthi revenue and weapons-procurement networks running since mid-2024.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced on 8 July 2025 that Harman International Industries, Inc. agreed to pay $1,454,145 to settle potential civil liability for 11 apparent egregious violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) that occurred between 22 May 2018 and 27 October 2020. Overseas employees of a U.S. subsidiary of Harman — a Samsung-owned consumer-electronics and automotive-electronics company headquartered in Stamford, CT — enabled the diversion of consumer-audio products through Harman's UAE distributor to end-users in Iran with knowledge that the distributor was reselling into Iran in violation of the ITSR. OFAC determined the apparent violations were egregious but voluntarily self-disclosed, and Harman agreed to invest $400,000 in additional compliance measures as partial satisfaction of the settlement amount.

New Zealand's Russia Sanctions Amendment Regulations (No 3) 2025, made under the Russia Sanctions Act 2022, came into force on 19 June 2025 designating seven entities and ten individuals -- including North Korean, Iranian and Belarusian actors supporting Russia's war effort and Russian actors involved in drone and weaponry production. The same instrument created a new "restricted ship" category under Regulation 8 and sanctioned 27 vessels in Russia's shadow fleet under it, and expanded the Regulation 12 legal-services exception. Designated parties are subject to asset freezes and prohibitions on New Zealand persons supplying services to them.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) announced a $3,882,797 civil settlement with Unicat Catalyst Technologies LLC, an Alvin, Texas-based specialty catalyst supplier, resolving 13 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) and one apparent violation of the Venezuela Sanctions Regulations (VSR, 31 CFR Part 591). OFAC determined the conduct egregious; Unicat had voluntarily self-disclosed. The settlement was concurrent with separate actions by the U.S. Department of Justice and the Department of Commerce Bureau of Industry and Security (BIS). The violations, spanning 2016–2021, involved the supply of catalyst products and consulting services to Iranian customers via a Dutch affiliate and Chinese supplier, and the sale of catalysts to Orinoco Iron S.C.S., a blocked Venezuelan government-owned entity, routed through a Chinese intermediary.

The US Treasury's Office of Foreign Assets Control designated more than 35 individuals and entities tied to Iranian brothers Mansour, Nasser, and Fazlolah Zarringhalam, whom OFAC says have collectively laundered billions of dollars through the international financial system using Iranian exchange houses (including Zarrin Ghalam, GCM Exchange, and Berelian Exchange) and foreign front companies based in the UAE and Hong Kong. The network is used to move revenue from Iranian oil and petrochemical sales that fund the regime's nuclear and missile programs and terrorist proxies. The action, taken pursuant to Executive Order 13902, is the first designation round under National Security Presidential Memorandum 2's "maximum pressure" campaign since its February 4, 2025 issuance; Treasury's FinCEN concurrently issued an updated advisory on Iranian shadow-banking and oil-smuggling red flags for financial institutions.

On 30 April 2025 the US Department of State designated seven entities and identified two vessels as blocked property for facilitating trade in Iranian petroleum and petrochemical products, under Executive Order 13846 and in furtherance of National Security Presidential Memorandum 2 (NSPM-2, "Restoring Maximum Pressure on the Government of Iran"). The action named four UAE-based sellers and one purchaser of Iranian petrochemicals — including Solvent Organics (over $300 million in exports of Iranian-origin petrochemicals to third countries) and Alseerah Trading (over $150 million) — plus a Turkiye-based petrochemical trader, an Iran-based cargo inspection company, and a marine management company involved in transporting millions of barrels of Iranian crude. Secretary of State Marco Rubio stated the goal was to drive Iran's illicit oil and petrochemical exports, including to China, to zero.

On 4 February 2025, President Donald J. Trump signed National Security Presidential Memorandum/NSPM-2, "Imposing Maximum Pressure on the Government of the Islamic Republic of Iran, Denying Iran All Paths to a Nuclear Weapon, and Countering Iran's Malign Influence." The memorandum reimposes the first- term "maximum pressure" framework, directing the Secretaries of State and Treasury and the Attorney General to (i) drive Iran's exports of crude oil and petroleum products — including to the People's Republic of China — to zero; (ii) review and modify or rescind sanctions waivers and general licences (notably the Chabahar port waiver benefiting India); (iii) sanction shadow-fleet vessels, intermediaries, refineries (including PRC "teapot" refiners) and oil traders facilitating Iranian energy exports; and (iv) lead a diplomatic isolation campaign including a snapback of UN Security Council sanctions under JCPOA Resolution 2231 paragraph 11. Since promulgation, OFAC has designated 1,000+ Iran-related persons, vessels and aircraft and four PRC independent ("teapot") refiners alleged to have processed sanctioned Iranian crude. The DOJ is also directed to pursue impoundment of Iranian oil cargoes and seizure of Iranian assets to satisfy US-court terrorism-victim judgments.

The Council of the EU adopted Implementing Regulation (EU) 2024/2697, implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran's military support to Russia's war of aggression against Ukraine. The listing adds 7 individuals and 7 legal entities to the EU asset freeze. The entities include three Iranian state and private airlines (Saha Airlines, Mahan Air, Iran Air) named as repeat carriers of Iranian-made UAVs and related technology to Russia, a UAV-procurement network (Basamad Electronic Pouya Engineering Co., Teyf Tadbir Engineering Company) run through EU-listed businessman Hossein Hatefi Ardakani, and two entities tied to Iran's ballistic-missile programme: Iran Alumina Company (IAC), Iran's sole producer of alumina powder used in solid rocket-fuel propellant, and Shahid Haj Ali Movahed Research Center, a missile R&D subsidiary of the EU-listed Shahid Hemmat Industries Group. All funds and economic resources of the listed parties are frozen within the EU, and EU persons/entities are barred from making funds available to them.

On 11 October 2024, the Secretary of the Treasury — acting in consultation with the Secretary of State and pursuant to section 1(a)(i) of Executive Order 13902 — determined that the petroleum and petrochemical sectors of the Iranian economy are sectors of strategic concern, exposing non-US persons that operate in or knowingly facilitate significant transactions with those sectors to secondary sanctions and SDN-listing risk. The determination was issued in response to Iran's 1 October 2024 ballistic- missile attack on Israeli targets and was formally published in the Federal Register on 19 November 2024 (FR Doc 2024-26800). Concurrent with the determination, OFAC designated an international network — including Sepehr Energy Jahan Nama Pars — that had shipped millions of barrels of Iranian crude on behalf of Iran's Armed Forces General Staff to the People's Republic of China.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a final rule amending 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate, with amendments, General License (GL) D-2 — originally issued on OFAC's website on September 23, 2022 — which authorizes the export, reexport, and provision of certain services, software, and hardware incident to communications over the internet to persons in Iran. The codification preserves the GL D-2 expansion (cloud-based services; third-country importation of hardware/software previously exported to Iran; ex-Iran installation, repair and replacement services; case-by-case licensing for internet-freedom activities) and updates the § 560.540 List of Services, Software, and Hardware Incident to Communications. Effective June 17, 2024, the List is amended to exclude laptops, tablets, and personal computing devices with an Adjusted Peak Performance (APP) exceeding 1 Weighted TeraFLOP (WT) — narrowing the consumer-electronics authorization to lower-performance devices and aligning the carve-out with broader BIS-style compute thresholds. The rule does not relax primary ITSR prohibitions; it codifies a humanitarian / internet-freedom exception while inserting a narrow high-performance-compute carve-out.

On 18 October 2023 the Governor in Council registered Regulations Amending the Special Economic Measures (Iran) Regulations (SOR/2023-220) under the Special Economic Measures Act, citing Iran's proliferation- sensitive nuclear activities and weapons-of-mass-destruction-related programme as a grave breach of international peace and security. The amendment prohibits Canadians and Canadian entities from exporting, selling or supplying to Iran dual-use goods and technology, conventional arms (battle tanks, armoured combat vehicles, large-calibre artillery, combat aircraft, attack helicopters, warships), Missile Technology Control Regime-listed equipment, and technical data related to ballistic missiles and nuclear-weapon delivery systems; it also bars importing arms and related material from Iran. The same instrument adds 156 entities and 18 individuals to Canada's Iran sanctions list (asset freeze / dealings prohibition).

Switzerland's Federal Council amended the Ordinance on measures related to the situation in Ukraine (SR 946.231.176.72) to align with the remainder of the EU's tenth sanctions package, effective 8pm on 29 March 2023. The amendment extends the existing Russia import ban to additional petroleum products (including petroleum jelly and petroleum coke), bitumen/asphalt, bituminous mastics, carbon and synthetic rubber, adds further export controls and designations linked to drone transfers to Russia, and tightens reporting obligations in the financial sector.

On 25 February 2023, one year into Russia's full-scale invasion of Ukraine, the Council of the European Union adopted Council Regulation (EU) 2023/427, the 10th package of sanctions, amending Regulation (EU) 833/2014. It entered into force on publication the following day (26 February 2023). The package bans imports of asphalt and synthetic rubber from Russia (with a temporary transitional import quota for rubber products running to 30 June 2024), expands the export ban on dual-use and advanced-technology goods, suspends further Russian media broadcasting licences in the EU, and designates 87 individuals and 34 entities — including Iranian persons and entities involved in drone manufacture and supply, and 96 entities tied to Russia's defence-industrial base — to the EU asset-freeze/travel-ban list.

On 8 October 2020, the US Treasury's Office of Foreign Assets Control (OFAC) determined that section 1(a)(i) of Executive Order 13902 (10 January 2020) applies to the financial sector of the Iranian economy, exposing non-US persons that operate in or knowingly facilitate significant transactions with that sector to secondary sanctions. Concurrently, OFAC designated eighteen Iranian banks (sixteen under E.O. 13902, one as an owned-or-controlled affiliate, and Hekmat Iranian Bank under E.O. 13382 non-proliferation authority). After a 45-day wind-down, the secondary-sanctions exposure became effective on 22 November 2020. The determination was formally republished in the Federal Register on 1 October 2025 (FR Doc 2025-19123) under Trump 2.0's maximum-pressure restoration; the underlying economic measure dates to the 2020 action.