Sanctions Watch | Weekly Vol. 168

Sanctions Watch Vol 168

In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

U.S. Escalates Iran Sanctions Under “Operation Economic Outcast” While Delivering Sweeping Sanctions Relief to Syria

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced major sanctions actions affecting Iran and Syria, marking sharply contrasting policy shifts toward the two countries.

The U.S. Treasury and State Departments launched an expanded sanctions campaign against Iran, targeting the regime’s military activities, procurement networks, and petroleum and petrochemical trade. OFAC added numerous Iran-related persons and entities to the SDN List and issued a determination under Executive Order 13902 covering Iran’s aviation, digital asset, gold, shipping, and technology sectors.

OFAC also suspended Iran General Licenses F and G, previously covering certain U.S.-Iran sports activities and academic and educational exchanges. At the same time, General License AA, authorizing certain activities involving La Nivernaise De Raffinage SAS, and General License BB, permitting the wind-down of certain previously authorized transactions. OFAC also updated its sanctions-risk alert concerning Iranian demands for passage through the Strait of Hormuz.

In contrast, the United States significantly eased sanctions on Syria. The State Department rescinded Syria’s designation as a State Sponsor of Terrorism and revoked Hay’at Tahrir al-Sham’s SDGT designation. OFAC consequently removed HTS from the SDN List, revoked Syria General License 25 as no longer necessary, updated related FAQs, and joined Commerce and State in issuing updated guidance on Syria sanctions and export-control relief.

OFAC Issues New Counterterrorism Wind-Down Authorization and Updates Russia-Related Diamond Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two General Licenses addressing counterterrorism sanctions and Russia-related diamond restrictions, alongside updates to the SDN List.

Under the Global Terrorism Sanctions Regulations (31 CFR Part 594), OFAC issued General License 36, authorizing transactions ordinarily incident and necessary to wind down dealings with Autistici Inventati, including entities it owns directly or indirectly by 50% or more. The authorization remains valid through 12:01 a.m. EDT on September 25, 2026. Payments to blocked persons must be placed into blocked accounts, and transactions involving other blocked persons remain prohibited unless separately authorized.

OFAC also issued Russia-related General License 104B, permitting certain transactions necessary for importing specified non-industrial diamonds into the United States through September 1, 2027, provided the diamonds were physically outside Russia before applicable cutoff dates and have not subsequently been exported or re-exported from Russia.

The authorization does not permit imports of non-industrial diamonds of Russian Federation origin, which remain prohibited under Executive Order 14068. GL 104B took effect on August 26 and superseded General License 104A.

OFAC Expands and Updates Sanctions Authorizations Covering Venezuela’s Oil, Gas, Minerals, and Telecommunications Sectors

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a broad package of updated Venezuela-related General Licenses, authorizing specified activities across several key sectors of the Venezuelan economy.

The measures include General Licenses 46D, 47B, 48C, 50C, 51C, 52B, 54B, and 61A. Collectively, the licenses cover certain activities involving Venezuelan-origin oil and petrochemical products, sales of U.S.-origin diluents, supplies of specified goods and services, oil and gas sector operations, and transactions involving Venezuela’s state-owned petroleum sector.

The authorizations also address activities involving Venezuelan-origin minerals, including gold, the supply of certain items and services supporting mineral operations, and supplies related to telecommunications in Venezuela.

Alongside the General Licenses, OFAC updated its compliance guidance for the Venezuela sanctions program. The agency issued two new Frequently Asked Questions (FAQs 1267 and 1268) and amended FAQs 1233 and 1244. OFAC also archived FAQ 1260.

The August 27 actions represent a significant update to the framework of U.S. sanctions authorizations applicable to Venezuela, particularly across the country’s energy, minerals, and telecommunications sectors.

Malta Issues New Guidance Strengthening Sanctions Compliance Requirements Under Article 32

The Malta’s Sanctions Monitoring Board (SMB) issued new guidance on implementing Article 32 of the National Interest (Enabling Powers) Act, Chapter 653, setting out its expectations for effective sanctions compliance.

The guidance emphasizes that sanctions compliance should extend beyond maintaining written policies and procedures. Organizations are expected to understand their specific sanctions exposure and establish appropriate controls to identify, manage, and mitigate related risks.

The SMB provides practical direction across several core areas, including governance, sanctions risk assessments, screening measures, escalation procedures, record keeping, and reporting obligations. These elements are intended to help operators evaluate whether their existing sanctions compliance frameworks are effective in practice.

The guidance also stresses a risk-based and proportionate approach. Organizations should regularly review and update their compliance frameworks as sanctions regimes evolve, considering the nature, size, and risk profile of their business. Controls considered appropriate for one organization may not necessarily be suitable for another.

The publication is intended as a practical reference for operators reviewing existing compliance arrangements or developing stronger controls, helping them understand the SMB’s expectations and translate Article 32 sanctions compliance requirements into operational practice.

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Sanctions Watch is a weekly recap of events and news related to sanctions around the world.