OFAC Tightens Iran and Cuba Rules, Assumes Denial of Iran Licenses
September: mass Iranian aviation designations, suspended general licenses, a presumption of denial for Iran specific licenses, a VTB Bank hit, a new Cuba regime, and penalties rules consolidated into Part 505.
OFAC's September 2026 activity, as summarized in this single-source firm roundup, was unusually broad. On September 8 the agency designated dozens of Iranian passenger and cargo carriers plus aviation-support companies in the UAE, UK, Turkey, Malaysia and Kazakhstan, and indefinitely suspended ITSR general licenses 522, 528 and 529 and GL J-1, leaving a September 23 wind-down under GL DD. On September 10 it announced a presumption of denial for Iran-related specific license applications — a break from prior case-by-case review — alongside a $1,427,230 civil settlement. VTB Bank was designated under EO 13902 on September 14, extending secondary-sanctions exposure to non-U.S. financial institutions, and an Iranian digital-asset platform was hit September 17.
A new Cuba Sanctions Regulations package implementing EO 14404, plus CACR amendments prohibiting indirect transactions with Cuba Restricted List entities and deleting the U-turn and travel authorizations, took effect September 30. OFAC also consolidated penalties and enforcement procedure into new Part 505 regulations (91 Fed. Reg. 60821), eliminating more than 100 duplicative subparts.
For counsel, near-term work is rescreening, inventorying reliance on suspended or superseded licenses, and refreshing citations in compliance manuals. Watch further FAQs and any challenge to the Iran licensing presumption; details here rest on one publisher's account.