Sanctions in a Snap: Developments in Sanctions August 2026

Hughes Hubbard’s “Sanctions in a Snap” is intended to provide a clear and concise summary of recent developments from the Office of Foreign Assets Control (OFAC). We hope you find it helpful in assessing U.S. economic sanctions compliance risk against current U.S. government designation and enforcement priorities.

Highlights from August 2026 include a renewed maximum pressure campaign against Iran, an Iran-related civil monetary penalty and the rise of risk exposure from Ecuador.

In total, OFAC added 148 individuals and entities to its Specially Designated Nationals and Blocked Persons List (SDN List) and identified 16 vessels as blocked property. OFAC also removed 22 individuals and entities and two aircraft from the SDN List.

The August actions reflect OFAC’s continued prioritization of China, Cuba and Iran as primary threats to the national security and foreign policy interests of the United States. The graph at the end of this update provides a visual representation of the current targeting priorities reflected in the August designations.

Operation Economic Outcast

On Aug. 24, OFAC announced the initiation of “Operation Economic Outcast,” a sanctions campaign aimed at economically isolating Iran, with designations, a Determination making additional sectors of the Iranian economy sanctionable and the suspension of certain general licenses that previously authorized payments to Iran.

OFAC and the State Department announced the designations of 72 mostly non-Iranian individuals and entities to the SDN List for alleged involvement in Iran’s nuclear and missile technology procurement, cyber operations and oil‑revenue generation networks.

The Determination means that OFAC may sanction any individual or entity it determines operates in the aviation, digital asset, gold, shipping or technology sectors of the Iranian economy.

Lastly, OFAC suspended certain general licenses that previously authorized limited financial connections to Iran. Most notably, OFAC suspended the authorizations for certain noncommercial, personal remittances and academic exchanges.

• Please see our comments on Operation Economic Outcast published by The Japan Public Broadcasting Corporation NHK, CNBC, Arabian Gulf Business Insight, Bloomberg, Energy Intelligence and Alhurra.

$60K Iran-Related Civil Monetary Penalty Against U.S. Manufacturer and Distributor

On Aug. 12, OFAC announced a $60,764 settlement with Rice Lake Weighing Systems, a Wisconsin-based manufacturer and distributor of weight-related products and equipment, to resolve potential civil liability arising from apparent violations of the Iran sanctions program. According to OFAC, between June 2019 and November 2021, the company’s Italian subsidiary knowingly sent $121,527 in equipment and components to Iran through a UAE-based distributor.

OFAC found that the apparent violations were voluntarily self-disclosed and non-egregious. Based on those findings, OFAC assessed the base penalty equal to one-half the transaction value of the apparent violations.

Root cause of the violations: Failure of the U.S. parent entity to implement an effective sanctions compliance program for its foreign subsidiary, including awareness training, as well as centralized monitoring, testing and auditing.

Ecuador

On Aug. 20, OFAC announced the designations of 15 Ecuadorian individuals and companies and the identification of 10 vessels allegedly involved in the shipment of cocaine into the United States.

Those actions follow the July 1 Foreign Terrorist Organization designation of Chone Killers, an Ecuadorian gang. They are also the first designations of Ecuadorian individuals and companies under the second Trump administration.

Companies and banks should expect continued OFAC focus and attention on Ecuador arising from the current apparent U.S.–Ecuador political, trade and security/military alliance.

Additional Sanctions Actions in July

In addition to the OFAC actions summarized above, the U.S. government announced the following in July:

Designations (additions to the Specially Designated Nationals and Consolidated Sanctions Lists):

• Aug. 6 – Eleven Cuban individuals and entities for allegedly being state-owned entities, military enterprises and Ministry of the Revolutionary Armed Forces officials involved in foreign military cooperation and the procurement of military equipment intended for the Cuban regime.

• Aug. 7 – Eighteen individuals and entities, mostly nationals of or companies formed in Iran, the UAE and Hong Kong, allegedly involved in Iran-related cryptocurrency activity and sanctions evasion.

• Aug. 18 – The president and senior trial lawyer of the International Criminal Court, nationals of Japan and Senegal respectively.

• Aug. 18 – One British Virgin Island entity under the Venezuela-related program. Notably, no press release announced this designation, but the entity is publicly identified as previously holding a minority stake in Venezuela’s second-largest private oil producer.

• Aug. 20 – Ten Turkish individuals for alleged involvement in transferring cash to Hizballah.

• Aug. 20 – Twelve Cuban individuals and entities connected to the Cuban Institute of Friendship with the Peoples, the Cuban metals and mining sector or other Cuban government-controlled entities.

• Aug. 26 – Five individuals and entities pursuant to the counterterrorism authority, for alleged connections to “violent far-left terrorist groups.”

• Aug. 28 – One Emirati individual and one Hong Kong entity, for allegedly serving as the general manager of Bank Melli’s Dubai branch and aiding sanctioned Iranian persons in accessing the international financial system, respectively.

Sanctions List Removals

• Aug. 5 – Iraq-based airline Fly Baghdad and two of its aircraft, previously sanctioned and identified under the counterterrorism program.

• Aug. 7 – Two Colombian individuals and six Mexican individuals and entities previously sanctioned under the counternarcotics program.

• Aug. 24 – Twelve Syrian individuals and one entity previously sanctioned under the counterterrorism program.

General Licenses

• Venezuela-related General License 5Y (Aug. 3), “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After September 17, 2026.”

• International Criminal Court-related General License 12 (Aug. 18), “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on Aug. 18, 2026.”

• Russia-related General License 131I (Aug. 20), “Authorizing Certain Transactions for the Negotiation of and Entry Into Contingent Contracts for the Sale of Lukoil International GmbH and Related Maintenance Activities.”

• Venezuela-related General License 61 (Aug. 21), “Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications.”

• Venezuela-related General License 62 (Aug. 21), “Authorizing Negotiations of and Entry Into Contingent Contracts for Investment in the Telecommunications Sector of Venezuela.”

• Counter Terrorism General License 36 (Aug. 26), “Authorizing the Wind Down of Transactions Involving Autistici Inventati.”

• Russia-related General License 104B (Aug. 26), “Authorizing Transactions Related to Imports of Certain Diamonds Prohibited by Executive Order 14068.”

• Venezuela-related General License 46D (Aug. 27) “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products”; Venezuela-related General License 47B (Aug. 27), “Authorizing the Sale of U.S.-Origin Diluents to Venezuela”; Venezuela-related General License 48C (Aug. 27), “Authorizing the Supply of Certain Items and Services to Venezuela”; Venezuela-related General License 50C (Aug. 27), “Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela of Certain Entities”; Venezuela-related General License 51C (Aug. 27), “Authorizing Certain Activities Involving Venezuelan-Origin Minerals, Including Gold”; Venezuela-related General License 52B (Aug. 27), “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.”; Venezuela-related General License 54B (Aug. 27), “Authorizing the Supply of Certain Items and Services for Minerals Operations in Venezuela”; and Venezuela-related General License 61A (Aug. 27), “Authorizing the Supply of Certain Items and Services to Venezuela Related to Telecommunications.”

Regulations and Guidance

• Frequently Asked Questions

  • On Aug. 3, OFAC issued technical amendments to Venezuela-related FAQ 595.

  • On Aug. 6, OFAC issued Cuba-related FAQ 1264 to provide guidance on the risk exposure to non-U.S. persons arising from sending food, medicine or medical devices to Cuba.

  • On Aug. 7, OFAC issued Iran-related FAQ 1257 to provide guidance on the risk exposure to non-U.S. persons arising from dealing with digital asset exchanges designated pursuant to Executive Order 13902.

  • On Aug. 20, OFAC issued technical amendments to Russia-related FAQs 1224 and 1225.

  • On Aug. 20, OFAC issued Venezuela-related FAQ 1265 to provide guidance on the risk exposure to non-U.S. persons arising from dealings with the Department of State designated the Ministry of Construction of Cuba.

  • On Aug. 21, OFAC issued Venezuela-related FAQ 1266 to provide guidance on the scope of the telecommunications general license.

  • On Aug. 24, OFAC updated Syria-related FAQS 1220, 1221 and 1222 to provide additional guidance following the Aug. 24 rescission of Syria’s designation as a State Sponsor of Terrorism.

  • On Aug. 27, OFAC issued Venezuela-related FAQs 1267 and 1268 clarifying that the related general licenses “are no longer required to include a choice of law provision in the contract.” OFAC also updated Venezuela-related FAQs 1233 and 1244 relating to OFAC’s adjudication of specific license applications seeking to perform authorized contingent contracts and the scope of dispute resolution.

• Advisories

  • On Aug. 24, the U.S. Departments of Commerce, State and Treasury updated the Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria to incorporate the Aug. 24 rescission of Syria’s designation as a State Sponsor of Terrorism.

  • On Aug. 24, OFAC published an update to its OFAC Alert: Sanctions Risks of Iranian Demands for Strait of Hormuz Passage.

United States Targeting Priorities