On 28 April 2026, the U.S. Department of the Treasury, through its Office of Foreign Assets Control (OFAC), announced a major sanctions action targeting Iran’s shadow banking system. The measures designate 35 individuals and entities responsible for facilitating large scale sanctions evasion and illicit financial flows linked to Iran’s military and terrorist financing activities.
According to the Treasury, these networks enable Iran to move tens of billions of dollars through complex financial structures, including offshore shell companies and intermediary firms. The funds are used to support Iran’s armed forces, including the Islamic Revolutionary Guard Corps, by enabling payments for illicit oil exports, procurement of sensitive components for weapons systems, and financial transfers to regional proxy groups.
The action is implemented under Executive Orders 13902 and 13224, reflecting both financial sector sanctions and counterterrorism authorities. It builds on earlier designations in January 2026 and forms part of a broader “maximum pressure” campaign, under which approximately 1,000 Iran related individuals, entities, vessels, and aircraft have been sanctioned since February 2025.
All designated parties are added to the Specially Designated Nationals list, resulting in asset blocking and a prohibition on dealings by U.S. persons. The Treasury also warned that non-U.S. financial institutions and companies facilitating such networks may face significant secondary sanctions exposure. In addition, OFAC is issuing firm guidance to warn about the significant sanctions exposure related to making “toll” payments to the Government of Iran or the IRGC for passage through the Strait of Hormuz. These payments create sanctions risk for U.S. and non-U.S. persons, including financial institutions.
This development highlights the increasing sophistication of sanctions evasion mechanisms and underscores the need for enhanced due diligence beyond name screening. Trade compliance professionals should focus on identifying indirect exposure through complex ownership structures, intermediary entities, and high-risk trade corridors linked to energy and financial flows.
Please refer to the official press release issued by the U.S. Department of the Treasury: