OFAC made Iran's car and rail industries sanctionable on 1 October. Half of the 30 names it listed that day are neither

The US Treasury made Iran's automotive and rail industries sanctionable on 1 October. A determination under section 1(a)(i) of Executive Order 13902, signed by OFAC Director Bradley T. Smith, says any person found to operate in either sector "shall be subject to sanctions". It took effect the same day.

The order now covers 14 sectors of Iran's economy. Four were named in it in January 2020. Treasury added finance in October 2020, petroleum and petrochemicals in October 2024, and aviation, digital assets, gold, shipping and technology on 24 August this year. We wrote then that a determination gives you a population to investigate rather than a name to screen. This time the population came with names attached, though not the ones the headline suggests.

Treasury's press release gives a stated ground for each designation. We sorted the 30 entries by it.

The Iranian carmakers are Iran Khodro, SAIPA, Iran Khodro Diesel, Pars Khodro, Zamyad and the two Niroo Motor companies. Treasury says Iran Khodro and SAIPA hold more than 90 percent of Iran's domestic market and make nearly 1.5 million vehicles a year between them. The rail entries are the state railway company, Raja Passenger Trains and a freight company listed as Sherkat-e Rah Ahan-e Khamle-o-Naghle.

The five foreign suppliers are where a European buyer is most likely to meet this action. PT Golden Motorcycle International in Indonesia shipped parts to Niroo Motor Damavand. Integrated Auto Parts LLC, with an office in the Burj Khalifa, moved parts through the UAE that Treasury says were transshipped from Turkey and India. Troy Trading in Istanbul sent truck parts to Bahman Diesel. Two Hong Kong companies supplied Iran Khodro and SAIPA: Hessenberg Co., Limited, which is also listed as Jedburgh Co., Limited, and Tanex Global Trading Hong Kong Limited.

The other 15 have nothing to do with cars or trains. Heavy Equipment Production Company (HEPCO) makes bulldozers and excavators; its Shanghai subsidiary buys its parts. Eight were designated under the metals order, E.O. 13871, and five as part of Iran's financial sector.

TECH-TRADE INTERNATIONAL IMPEX GMBH is the only EU company in the update. The entry gives an address on Engelbertstrasse in Hilden, the register number HRB 82099, and an incorporation date of 29 November 2017. Treasury says it sold several shipments of precursor materials to Esfahan's Mobarakeh Steel Company, which it calls the largest steel producer in the Middle East. It was designated under E.O. 13871, the metals order, not under the new determination.

Anyone screening only for the words automotive or rail would miss the one company with an EU address. OFAC listing a German company does not put it on any EU list, which takes an EU act. The US designation still reaches a European firm that pays or is paid in dollars.

KGT Trading, Dominion Trading Group, Bonasol Group, Meizi and East Concord Development were designated for operating in the financial sector of Iran's economy. None of the five is an Iranian company. Treasury's press release names them in a sentence about the shell companies of Ramin Keshvardoust, who is on the same page. He is an Iranian and Dominican national in Hong Kong, listed under the metals order for moving Iranian steel and oil.

Since early 2025, Treasury says, operatives in Iran's shadow banking system sent dozens of transactions to the five, totalling tens of millions in euros and dollars. The money moved on behalf of Farab Soroush Afagh Qeshm Company, which handles payments for clients of Iran's Bank Shahr. One network, two orders, two tags.

The same day OFAC amended FAQ 831, which defines five of the 14 sectors and still names none of the other nine. We compared it with an archived copy of 11 September. Only the financial-sector definition changed. The old text ran through Iranian financial institutions: entities organised in Iran, located there, or owned or controlled by the Government of Iran or by one of those institutions. The new text adds "providers of economic or financial services in or involving Iran", related activities, and persons that own or control those providers. Nothing in it requires the provider to be Iranian.

The entries give a payments team something to compare beyond the names. All five were incorporated between July 2023 and December 2024. Bonasol and East Concord give the same office, unit 2610 on the 26th floor of Apec Plaza, 49 Hoi Yuen Road. The two entries spell it differently, one as Apec Plaza, Kowloon, the other as Apec Plz, Kwun Tong, so an address match needs a human eye. Two carry aliases with no distinctive word in common with the primary name: Bonasol is also LIDA SHINE GROUP LIMITED, and Dominion is also XINYI INTERNATIONAL DEVELOPMENT CO., LIMITED. Each entry carries a Hong Kong business registration number.

Every one of the 22 entries under E.O. 13902 carries the same tag, [IRAN-EO13902]. Iran Khodro, the state railway, HEPCO and Meizi Co., Limited are indistinguishable on that field. The sector is in the press release, not in the list entry.

Two existing entries were also changed. EVER SHINING LIMITED became EVER SHINING LTD, lost its Hong Kong address and company numbers, and had its establishment date moved from 2000 to 2021; it keeps IMO 6225490. FLUXUS MARINE INC lost its Kazakh address. A match stored against the old text no longer reads the same as the list.

Two days earlier, on 29 September, OFAC designated 10 people and companies it says procured weapons components for Iran's defence ministry, under the non-proliferation order, E.O. 13382. They include the ministry's representative in Beijing, the Iranian electronics buyer Kavoshcom, the Hong Kong supplier EC Mojo Technology, and three Cavalier Dynamics companies in Pakistan, Saudi Arabia and Turkey. Seven of the 10 sit outside Iran. The 1 October list has the same shape: 18 of the 30 are outside Iran.

1. Re-screen supplier, customer and payee files now, starting with auto parts, rail equipment, machinery and steel counterparties in the UAE, Hong Kong, mainland China, Turkey, Indonesia and Germany. A result dated before 1 October does not reflect these entries.
2. Compare registration numbers, not just names. The entries carry Hong Kong business registration numbers, UAE licence numbers, a Turkish tax ID and HRB 82099 for the German company.
3. Search the aliases. LIDA SHINE GROUP LIMITED, XINYI INTERNATIONAL DEVELOPMENT CO., LIMITED, JEDBURGH CO., LIMITED, RAJA RAIL TRANSPORTATION COMPANY and NIROO MOTOR COMPANY share little or nothing with their primary names.
4. Look at who you pay, not only who you sell to. The financial-sector designations describe one pattern: a Hong Kong shell company that receives euros and dollars on behalf of someone else's clients.
5. Keep a sector register. Counterparties that sell into Iran's car or rail industries are exposed from 1 October whether or not they are listed, and no document sets a wind-down.
6. Check ownership. Under OFAC's 50 percent rule, companies owned half or more by Iran Khodro, SAIPA or the others are blocked without appearing on the list.

A batch screening run in ScreenVeritAI checks a whole supplier or customer file against current OFAC, EU and UK data in one pass, with evidence for each row and an export of the whole file. Registration numbers in the entries above are still for an analyst to compare against your own records.

This is a reading of four documents OFAC and the Treasury published on 1 October 2026: the list update, the determination, the press release and FAQ 831. We compared the FAQ with an archived copy from 11 September. The sector of each entry comes from the press release. The A7 Network designation and FinCEN's proposed rule on it, published the same day, are a separate story.

These are US measures. We have not checked whether any of the 30 appear on EU, UK or UN lists, and an obligation in those jurisdictions comes only from their own instruments. Nothing here is legal advice.