Sanctions in a Snap: Developments in Sanctions September 2026

A summary of recent developments from OFAC.

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 September 2026 include intensified implementation of Iran and Cuba sanctions and an Iran-related $1.4 million civil monetary penalty against an individual.

In total, OFAC added 129 individuals and entities to its List of Specially Designated Nationals and Blocked Persons (SDN List) and removed 16 individuals and entities and one vessel from the SDN List.

The September designations reflect OFAC’s prioritization of Iran, Mexico and Cuba as primary threats to the national security and foreign policy interests of the United States. In contrast to other months in which China was heavily targeted, OFAC only imposed sanctions against two Chinese targets in September. This is likely because of the late September Trump-Xi summit.

The graph at the end of this update provides a visual representation of the current targeting priorities reflected in the September designations.

Operation Economic Outcast

OFAC intensified its implementation of Operation Economic Outcast, a sanctions campaign announced last month aimed at economically isolating Iran, with (1) designations, (2) suspension of additional general licenses and (3) a Statement of Licensing Policy establishing a presumption of denial for Iran-related license applications.

1. Designations

A Turkish financial institution alleged to have provided Iran with correspondent banking services used to transfer oil revenue from China to Turkey
Russia’s VTB Bank redesignated for allegedly maintaining correspondent banking relationships with Iranian banks
A crypto exchange that allegedly transferred Bitcoin worth hundreds of millions of dollars to Iran’s IRGC
Alleged Iranian Ministry of Defense and Armed Forces Logistics (MODAFL) weapons procurement networks based in Türkiye, China, Pakistan and Saudi Arabia
The remaining 27 previously undesignated Iranian airlines
18 Iraqi and Lebanese individuals and entities and one UAE entity allegedly connected to Iran's terrorist proxy groups Hizballah and Kata’ib Hizballah

2. Suspension of Additional Iran Sanctions General Licenses

Payments for overflights of Iranian airspace
Aircraft safety
Bunkering and emergency repairs
Aircraft to Iran on temporary sojourn

3. Statement of Licensing Policy

Presumption of denial for all license applications seeking authorization for transactions prohibited by sanctions on Iran.
OFAC will now deny all Iran-related specific license applications except as required by law or in “exceptional and urgent circumstances.”

Please see our comments on the September Operation Economic Outcast developments published by Arabian Gulf Business Insight and Fox News, and our interview with Fox News.

Increased Pressure on Cuba

OFAC further increased economic pressure on Cuba primarily through (1) signaling aggressive enforcement by issuing the Cuba Sanctions Regulations, (2) narrowing and removing existing general licenses, and (3) expanding the prohibition on transactions with Cuba Restricted List entities.

1. Cuba Sanctions Regulations

OFAC issued the Cuba Sanctions Regulations to implement Executive Order 14404. That May 2026 order transformed the Cuba embargo into a comprehensive sanctions program akin to that used for Iran through secondary, derivative and sectoral sanctions designation criteria.
The new regulations plainly signal the imminent targeting of non-Cuban companies and banks. Notably, the Sept. 29 OFAC Alert titled “Expanded Sanctions Against Cuba” explicitly warns that “foreign financial institutions should exercise caution when dealing with any person sanctioned under this authority.”

2. General Licenses

Rescinded authorizations
- U-Turn transactions (banks previously authorized to process Cuban transactions that originated and terminated outside the United States)
- Bank accounts for Cuban independent private sector entrepreneurs
- Travel to Cuba for professional meetings or conferences
Educational Cuba travel must now be under the auspices of a U.S. organization, a representative of which must accompany most travelers.

3. Cuba Restricted List

Banks may no longer act as intermediaries for financial transactions involving entities on the Cuba Restricted List.
Expanding the scope of prohibited transactions from direct to indirect financial transactions comports with the recission of the U-Turn authorization referenced above.

$1.4M Iran-Related Civil Monetary Penalty Against an Individual

On Sept. 10, OFAC announced a $1,427,230 settlement with a natural U.S. person to resolve potential civil liability arising from apparent violations of the Iran sanctions program. According to OFAC, between June 2019 and July 2021 the individual (1) provided management consulting and advisory services to a leading Iranian software solutions company, (2) received Iranian-origin dividends to their U.S. bank accounts, and (3) acquired real property in Iran. Those apparent violations occurred after the individual had attained status as a U.S. Lawful Permanent Resident (commonly referred to as LPR or green card holder) or was physically located in the United States.

OFAC found that the apparent violations were not voluntarily self-disclosed and were egregious. Based on those findings, OFAC assessed the base penalty equal to the schedule amount, which is $14,730,300.

OFAC reduced the base penalty in large part because the individual ceased the violative activity prior to receiving OFAC’s administrative subpoena and demonstrated an inability to pay a larger settlement amount.

Root cause of the violations: The individual maintained business relationships with Iran after he/she became a U.S. person through holding a green card and then later relocating to the United States.

Additional Sanctions Actions in September

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

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

Sept. 3 – An adult member of the Castro family and five entities for allegedly operating in the energy or metals and mining sector of the Cuban economy
Sept. 9 – Chinese-language platform allegedly used extensively by Chinese cybercriminals, and alleged supporting developers based in Cambodia and Singapore, pursuant to the Transnational Criminal Organizations authority
Sept. 9 – Ecuador-based gang Los Tiguerones as a Foreign Terrorist Organization
Sept. 17 – Four Cuban entities for allegedly operating in the defense sector of the Cuban economy and three individuals for their alleged involvement in those entities; the State Department also designated four Cuban entities for their alleged involvement in Cuba’s nickel sector
Sept. 29 – 21 Mexican individuals and 25 Mexican entities allegedly tied to the Sinola cartel
Sept. 30 – 11 predominantly Venezuelan individuals and entities allegedly involved in Tren de Aragua ATM-related theft from U.S. banks and a Tren de Aragua leader.

Sanctions List Removals

Sept. 3 – One Swiss entity previously sanctioned under the Russia-related program
Sept. 16 – One Mexican individual previously sanctioned under the counternarcotics program, and one Swiss individual and Turkish entity previously sanctioned under the Russia-related program
Sept. 17 – Two Belarusian entities previously sanctioned under the Belarus-related program
Sept. 18 – OFAC announced the revocation of the Ethiopia-related program following expiration of Executive Order 14046 and the resulting removal of two Eritrean individuals and four Eritrean entities
Sept. 23 – A Congolese individual and entity previously sanctioned under the Democratic Republic of the Congo-related program
Sept. 30 – A Mexican individual previously sanctioned under the counternarcotics program and a Belarusian individual previously sanctioned under the Belarus-related program; OFAC also removed a vessel previously identified as blocked property under the Libya-related program

General Licenses

Venezuela-related General License 51D (Sept. 2), “Authorizing Certain Activities Involving Venezuelan-Origin Coal or Minerals, Including Gold”
Venezuela-related General License 54C (Sept. 2), “Authorizing the Supply of Certain Items and Services for Coal or Minerals Operations in Venezuela”
Venezuela-related General License 55A (Sept. 2), “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela’s Coal or Minerals Sectors”
Cuba General License 4A (Sept. 3), “Authorizing Transactions for Third-Country Diplomatic and Consular Missions in Cuba”
Iran General License CC (Sept. 4), “Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on September 4, 2026”
Iran General License DD (Sept. 8), “Authorizing the Wind Down of Certain Civil Aviation-Related and Other Transactions”
- Previously Authorized Under the Iranian Transactions and Sanctions Regulations
Venezuela-related General License 52C (Sept. 14), “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.”
Russia-related General License 131J (Sept. 18) “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 46E (Sept. 28), “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products”
Venezuela-related General License 48D (Sept. 28), “Authorizing the Supply of Certain Items and Services to Venezuela”
Venezuela-related General License 49B (Sept. 28), “Authorizing Negotiations of and Entry Into Contingent Contracts for Certain Investment in Venezuela”

Regulations and Guidance

Frequently Asked Questions

On Sept. 2, OFAC amended Venezuela-related FAQ 1247 to explain that authorizations pursuant to Venezuela-related General Licenses 51D, 54C and 55A include transactions involving coal and Carbones del Zuliathe.
On Sept. 9, OFAC amended cross-program FAQs 5, 13, 51, 58, 59, 74, 75, 76, 77 and 78 and added new FAQs 1269 and 1270 to provide guidance on the license application process.
On Sept. 14, OFAC amended Venezuela-related FAQ 1245 to explain that General License 52C authorizes individuals blocked pursuant to the Venezuela Sanctions Regulations to execute and sign contracts authorized by General License 52C in their official capacity as officers, employees or authorized representatives of PdVSA or PdVSA Entities.
On Sept. 18, OFAC issued technical amendments to Russia-related FAQs 1224 and 1225.
On Sept. 29, OFAC issued Cuba-related FAQs 1271–1275 and amended FAQ 29 to provide updated guidance on regulatory changes, including the narrowing or removal of general licenses and the expansion of prohibited financial transactions with Cuba Restricted List entities.

Regulatory Amendments

On Sept. 25, the Federal Register published the Sanctions Penalties Regulations, which consolidate existing OFAC enforcement procedures and penalties information.
On Sept. 25, the Federal Register published amended Terrorism List Governments Sanctions Regulations reflecting the removal of a Syria-specific general license following recission of that country from the State Sponsors of Terrorism List.
On Sept. 30, the Federal Register published amended regulations following OFAC’s rule Removing Duplicative Penalties Information and Reorganizing Certain Parts.
On Sept. 30, the Federal Register published amendments to the Iranian Transactions and Sanctions Regulations to incorporate Executive Order 13902.