The Office of Foreign Assets Control announced the following sanctions action last week.
Iran-related Sanctions
Treasury targets A7 sanctions-evasion network: On Oct. 1, as part of Operation Economic Outcast, Treasury took action against the A7 Network, a Russia-linked shadow banking network used by Iran to evade sanctions. FinCEN proposed restrictions on fund transfers involving the network’s sub-agents and issued an alert to help financial institutions identify related suspicious activity, while OFAC designated the A7 Network as a significant transnational criminal organization. Treasury said the network helped disguise transactions tied to sanctioned persons and sectors, including those connected to Iran and the Islamic Revolutionary Guard Corps. Read more.
OFAC targets Iran’s rail and automotive sectors: As part of Operation Economic Outcast, OFAC targeted Iran’s rail and automotive sectors, describing them as key remaining sources of revenue and logistical support for the Iranian regime and the Islamic Revolutionary Guard Corps. OFAC also issued sectoral determinations under Executive Order 13902 authorizing sanctions on persons operating in Iran’s rail and automotive sectors, and designated related Iranian firms, foreign suppliers and facilitators. Read more.
Related to this action, OFAC issued a determination under Executive Order 13902 adding the automotive and rail sectors of the Iranian economy to the sectors subject to sanctions risk under the order. OFAC also amended Iran-related FAQ 831 to provide updated guidance related to the determination.
OFAC targets Iran military procurement network: As part of Operation Economic Outcast, OFAC sanctioned 10 individuals and entities across multiple jurisdictions for procuring weapons and weapons components for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), which oversees Iran’s weapons, ballistic missile and unmanned aerial vehicle programs. Treasury said the action is intended to disrupt Iran’s military procurement networks and increase the costs for those supporting the regime’s defense sector. The designations were issued pursuant to Executive Order 13382. Read more.
Illicit Drug-related Sanctions
Foreign Terrorist Organization Sanctions
OFAC targets Hamas financing network: On Oct. 2, OFAC designated a member of Hamas’s Al-Qassam Brigades, along with two France-based individuals and two affiliated entities, for allegedly helping move more than $2 million to Hamas through charitable fronts and cryptocurrency channels. Treasury said the network used money services businesses, digital assets and deceptive fundraising schemes to support Hamas’s operations and evade detection. The designations were issued pursuant to Executive Order 13224, the United States’ primary counterterrorism sanctions authority. Read more.
Counter-terrorism Sanctions and Transnational Criminal Organization Sanctions
OFAC targets Tren de Aragua fraud and money-laundering network: OFAC designated 10 individuals and entities tied to a Tren de Aragua fraud scheme that allegedly used malware to force U.S. ATMs to dispense cash, with the proceeds laundered and transferred to members of the criminal organization. The action also targeted alleged Tren de Aragua leader Juan Gabriel Rivas Nunez and individuals linked to illicit gold-mining operations, as part of broader efforts to disrupt the group’s financial networks. The designations were issued pursuant to Executive Orders 13581 and 13224. Read more.
