OFAC Recent Actions Digest

OFAC’s latest measures combine targeted sanctions against Iranian and Cuban networks with limited licenses intended to manage the consequences of existing sanctions on Russia and Cuba.

Russia — controlled pathway for a Lukoil divestment. Russia-related General License 131H permits negotiations, due diligence, contingent sale agreements, and routine maintenance involving Lukoil International GmbH (LIG) and its majority-owned subsidiaries through August 22, 2026. It does not authorize an actual sale. Any eventual transaction will require separate OFAC approval, completely sever LIG from Lukoil, place consideration owed to Lukoil in a blocked U.S.-jurisdiction account, and avoid giving Lukoil upfront value or a windfall. GL 128C separately supports continued operation of specified non-Russian Lukoil service stations through October 29, 2026. Neither license permits funds to be transferred to Russia. (FAQ 1224, FAQ 1225)

Iran — expansion of sanctions against Babak Zanjani’s financial network. OFAC designated four people and nine entities supporting sanctioned financier Babak Zanjani. The action reaches his Iran-based Dot One conglomerate—including its holding, gold, rail, barter, airline, and ride-sharing businesses—and overseas facilitators in Türkiye and the UAE. Those facilitators supported the Zedcex and Zedxion digital-asset exchanges through payment services, fiat settlement, technology, diamonds, tokens, and corporate infrastructure. OFAC says exchange-linked addresses processed funds for IRGC-associated wallets. The action builds on the January designation of Zanjani, Zedcex, and Zedxion and illustrates OFAC’s growing focus on digital assets, precious commodities, transportation projects, and offshore companies used together to conceal Iranian state-linked finance. (Treasury background action)

Cuba — new designations accompanied by narrowly tailored relief. OFAC added Cuban officials and entities to the SDN List, including José Ángel Portal Miranda, CEIBA Investments Limited, the state-owned petroleum research company CEINPET, and Comercializadora de Servicios Médicos Cubanos. At the same time, OFAC issued three licenses: GL 2 authorizes the wind-down of transactions involving CEIBA; GL 3 addresses certain CEIBA debt, equity, and derivatives transactions; and GL 4 permits transactions supporting third-country diplomatic and official missions in Cuba. The package isolates designated Cuban revenue and financial channels while allowing orderly exit activity and preserving diplomatic operations. (OFAC July 23 action)

Related terrorist and criminal-finance networks. OFAC also designated a senior Egyptian Muslim Brotherhood official and Hamas-linked charities, financiers, and an underground exchange network operating across the United Kingdom, Türkiye, Indonesia, and Gaza. Separately, its largest action to date against CJNG sanctioned more than 50 Mexican individuals and entities spanning cartel leadership, drug-trafficking cells, money laundering, fuel theft, agriculture, consumer businesses, and other fronts. These actions reinforce OFAC’s preference for disrupting entire financial ecosystems rather than individual leaders alone. (Hamas and Muslim Brotherhood action, CJNG action)

Administrative and compliance changes. OFAC also adopted a final rule updating website and contact information across its regulations, replacing a reporting obligation with a recordkeeping requirement for certain authorized legal-service payments from non-U.S. funds, and correcting typographical and cross-reference errors. Separately, amended Venezuela FAQ 1239 directs prospective depositors to obtain instructions from the State Department before making authorized payments into the Foreign Government Deposit Funds account and to submit detailed transaction documentation. (FAQ 1239)