US Expands Iran Sanctions to Target Third-Country Enablers
The Treasury and State Departments announced a significant escalation of the Iran sanctions program, targeting new economic sectors and threatening secondary sanctions against non-U.S. companies that facilitate Iranian trade.
On August 24, 2026, the U.S. government initiated "Operation Economic Outcast," a major escalation of its Iran sanctions program aimed at third-country enablers. The initiative imposes new sectoral sanctions on Iran's digital assets, technology, gold, aviation, and shipping industries. Concurrently, the Treasury's Office of Foreign Assets Control (OFAC) suspended five general licenses that had previously authorized certain educational, remittance, and cultural exchange activities. The action also includes nearly 90 new designations of entities, individuals, and vessels across several countries. For sophisticated counsel, this signals a "zero-leakage" enforcement posture with heightened secondary sanctions risk for non-U.S. companies, which are now on notice to sever ties with Iran. The accompanying FinCEN Section 311 action against a UAE bank demonstrates a broader use of regulatory tools to isolate Iran from the global financial system. Companies with any direct or indirect exposure to Iran should immediately review and update their compliance programs and screening protocols, as U.S. authorities have signaled that further enforcement actions against third-country facilitators are imminent.