Industrial Policy & Trade Monitor· 2672 actions· ✨ 89 recent

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.

FinCEN issued a final rule under Section 311 of the USA PATRIOT Act (31 U.S.C. § 5318A) prohibiting US covered financial institutions from opening or maintaining a correspondent account for, or on behalf of, Cambodia-based Huione Group, a foreign financial institution found to be of primary money-laundering concern. Treasury determined that Huione Group and its subsidiaries — including Haowang Guarantee, Huione Pay PLC, and Huione Crypto — laundered at least $4 billion of illicit proceeds between August 2021 and January 2025, including funds tied to North Korean cyber-heist actors and Southeast Asian "pig-butchering" investment-scam compounds. The rule also imposes a special-due-diligence requirement on US covered institutions to guard against indirect access via foreign correspondent accounts. Effective November 17, 2025.

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.

The US Treasury's Office of Foreign Assets Control designated 22 entities based in Hong Kong (18), the UAE, and Türkiye under Executive Order 13224 for facilitating sales of Iranian oil that benefit the IRGC-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. The front-company network moves refinery payments for Iranian oil through offshore accounts to fund IRGC-QF activity; the action is the second round of sanctions under National Security Presidential Memorandum 2's "maximum pressure" campaign, following a June 6, 2025 action against Iranian exchange-house money-laundering networks. All property and interests of the designated entities within US jurisdiction are blocked, and US persons are generally prohibited from dealing with them.

On 3 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the other member states of the Terrorist Financing Targeting Center (TFTC), designated five entities and sixteen individuals forming the core of Hizballah's financial infrastructure, under Executive Order 13224 as amended. Newly designated entities include Tashilat SARL (a Lebanese lender that provided loans on behalf of Hizballah and operated as part of Al-Qard Al-Hassan (AQAH) and Bayt al-Mal), alongside senior AQAH officials Samer Hasan Fawaz and Ali Mohamad Karnib. The action reaffirms and expands sanctions on AQAH, Hizballah's shadow "benevolent loan association" bank, and Bayt al-Mal, its unofficial treasury, both previously designated by OFAC in 2007 and 2006 respectively. It is the ninth TFTC joint designation since the center's creation in May 2017 and the third under this Administration; designated persons are alleged to have moved over $500 million through the formal Lebanese banking system — including US-designated Jammal Trust Bank — via joint and shadow accounts despite existing sanctions.

On 25 June 2025, FinCEN issued three coordinated orders identifying CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. as foreign financial institutions of primary money-laundering concern in connection with illicit opioid trafficking, and prohibiting US covered financial institutions from engaging in certain transmittals of funds (including convertible virtual currency transmittals) to or from those three institutions or any account or CVC address administered on their behalf. The orders were published in the Federal Register on 30 June 2025 (FR docs 2025-11991 Vector, 2025-11993 CIBanco, 2025-11990 Intercam) with an original effective date of 21 July 2025. These are the first-ever orders issued under Section 2313a of the Fiscal Year 2024 NDAA (added by the FEND Off Fentanyl Act and Fentanyl Sanctions Act), and target Mexican counterparties tied by FinCEN to the Beltran-Leyva Cartel, Jalisco New Generation Cartel (CJNG), and the Gulf Cartel.

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.

FinCEN issued a final rule under Section 311 of the USA PATRIOT Act (31 U.S.C. § 5318A) prohibiting US covered financial institutions from opening or maintaining a correspondent account for, or on behalf of, Iraq-based Al-Huda Bank, a foreign financial institution found to be of primary money-laundering concern. Treasury determined that Al-Huda Bank exploited its access to US dollars to support designated Foreign Terrorist Organizations including Iran's Islamic Revolutionary Guard Corps (IRGC) and IRGC-Quds Force, as well as Iran-aligned Iraqi militias Kata'ib Hizballah and Asa'ib Ahl al-Haq. The rule also imposes a special-due-diligence requirement on US covered institutions to guard against indirect access via foreign correspondent accounts. Published in the Federal Register on July 3, 2024; effective August 2, 2024.

Between 22 and 28 February 2022 — coinciding with Russia's full-scale invasion of Ukraine — OFAC issued a Financial Services Sectoral Determination and four directives under Executive Order 14024 of April 15, 2021. Together they authorise designation of any person operating in Russia's financial sector, prohibit US persons from trading Russian sovereign debt, bar US banks from maintaining correspondent accounts for designated Russian financial institutions (Sberbank, Alfa-Bank and others), prohibit new investment in certain Russia-related entities, and block all transactions involving the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance — effectively freezing approximately USD 640 billion in Russian sovereign reserves held in Western financial systems. The package was formally published in the Federal Register on 31 May 2022.

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.

The International Emergency Economic Powers Act of 1977 (IEEPA, Title II of Pub. L. 95-223, 91 Stat. 1626, codified at 50 U.S.C. §§ 1701–1708) was signed by President Carter on 28 December 1977 and grants the President sweeping authority to declare a national emergency with respect to "any unusual and extraordinary threat, which has its source in whole or substantial part outside the United States, to the national security, foreign policy, or economy of the United States" — and then to investigate, regulate, direct, compel, nullify, void, prevent, or prohibit any transaction in, or involving, foreign exchange, banking transfers, importing, exporting, or dealings in property by persons subject to US jurisdiction. IEEPA is the parent enabling statute for every OFAC-administered autonomous sanctions program (Russia, Iran, DPRK, Venezuela, Cuba, Syria, Belarus, Myanmar, cyber, Global Magnitsky, Hong Kong, ICC, and others) as well as the legal basis for the entire Trump-era IEEPA-tariff regime (EO 14193–14195 fentanyl tariffs, Canada/Mexico/China; EO 14257 reciprocal-tariff framework; EO 14323 Brazil; EO 14380 Cuba; EO 14382 Iran; and the US-India interim tariff agreement). Between 1977 and 2025 Presidents invoked IEEPA in 77 national-emergency declarations; of these, 7+ directly parent IPTM-filed implementing actions, with ~dozens of OFAC SDN designation actions tracing their legal root to this statute.