US Expands Iran Sanctions, Targeting New Sectors and Foreign Banks
The Treasury Department expanded secondary sanctions to Iran's aviation, tech, and shipping sectors, suspended general licenses, and designated third-country banks for facilitating Iranian transactions, creating broad new compliance risks.
The U.S. government has unveiled a significant expansion of its Iran sanctions program, creating new risks for companies operating globally. In a series of actions, the Treasury's Office of Foreign Assets Control (OFAC) authorized the imposition of secondary sanctions on entities involved with Iran's aviation, technology, digital asset, gold, and shipping sectors. This move exposes non-U.S. persons to potential U.S. sanctions for transacting with these sectors, even with no other U.S. nexus. The measures also include the designation of nearly 60 new parties, the suspension of several general licenses, and a new policy of presumptive denial for most specific license applications.
Sophisticated clients care because these actions signal a more aggressive enforcement posture, particularly against third-country actors. Treasury's designation of financial institutions in Türkiye and the UAE for supporting Iranian transactions underscores the heightened risk for international banks. Companies in the affected sectors must urgently re-evaluate their compliance frameworks and supply-chain diligence to avoid inadvertent violations. Counsel should monitor for OFAC guidance defining the scope of the new sectoral sanctions and advise clients to review FinCEN's new alert on Iranian aviation procurement red flags.