OFAC lists an Iraqi bank and Cuba's BICSA on 15 October. A bank with offices in Panama also calls itself BICSA

The US Treasury and the State Department added 27 entries to the SDN List on 15 October. Treasury designated 26 of them under Executive Order 13902, which targets sectors of the Iranian economy, and tagged them [IRAN-EO13902]. The State Department designated the 27th, Banco Internacional de Comercio S.A., a Cuban state-owned bank, under Executive Order 14404, tagged [CUBA-EO14404].

Treasury's release gives no total. We counted 16 individuals and 11 entities in OFAC's notice and again in the SDN CSV file downloaded on 20 October.

Treasury says the Iraqi bank, International Development Bank for Investment and Finance, was set up by Iranian companies to supply Iran with dollars. Bank Melli, which sat next to it in Iraq, closed under US sanctions and transferred its capital to it, and the bank sends its profits to Iran in dollars each month. The two Iranian banks operate "offshore" in free trade zones: Jazireh International Bank Company is affiliated with Bank Mellat, and Chabahar International Bank Overseas Company with Bank Shahr. The State Department says BICSA has served Karafarin Bank, designated in 2020, since at least 2022.

Iran General License FF is a licence. It authorises transactions "ordinarily incident and necessary to the wind down" of any transaction involving the Iraqi bank, or any entity it owns 50 percent or more of, until 12:01 a.m. Eastern Daylight Time on 30 October 2026. A payment owed to a blocked person goes into a blocked account, not to the payee. Paragraph (b) adds that no other person blocked under the Iranian Transactions and Sanctions Regulations (ITSR) is covered.

FAQ 1276 is not a licence. It says the US government does not intend to target foreign persons, including foreign banks, under E.O. 14404 for winding down or divesting from BICSA, or entities it owns 50 percent or more of, through 14 November 2026. It authorises nothing. US persons were barred from dealing with BICSA before 15 October under the Cuban Assets Control Regulations, and the FAQ says they still are, including when a foreign bank's wind-down passes through them.

Read the last row twice. The 25 other entries, from the two offshore banks to the 16 people, were blocked on 15 October with no wind-down period at all.

The SDN entry reads BANCO INTERNACIONAL DE COMERCIO S.A. (a.k.a. "BICSA"). The double quotes mean OFAC has classed BICSA as a weak alias, the term it uses for aliases broad enough to produce many false hits. OFAC's FAQ 124 says it does not generally expect firms to screen weak aliases, only to use them to confirm a hit raised by other information.

BICSA is also what Banco Internacional de Costa Rica, S.A. calls itself on its own website, which lists offices in Panama, Costa Rica, El Salvador, Guatemala, Mexico and Miami. It is a different bank. The two legal names share their first 25 characters, BANCO INTERNACIONAL DE CO, before one continues MERCIO and the other STA RICA.

There are two ways to get this wrong. A system that screens weak aliases stops payments to the Costa Rican bank because the message says BICSA. A fuzzy matcher that scores the full names rates them close. The identifiers settle both: the Cuban bank's address is in Miramar, Havana, its BIC is BIDCCUHH, and characters five and six of a BIC are the country code. CU is Cuba.

The Iraqi bank carries a weak alias too, "INTERNATIONAL DEVELOPMENT BANK", and a strong one, IRAQ DEVELOPMENT BANK. Its entry gives BIC IDBQIQBA, legal entity number 2549001T72VRU0W37E62 and the website idb.iq. DEVELOPMENT BANK sits in the primary name of nine SDN entries, this one included, and in the aliases of two more.

FAQ 123 says that in OFAC's CSV files weak aliases sit in the remarks field of the main file. The alias file downloaded on 20 October has no row for either one. A system that builds its alias index from that file alone has never seen the name BICSA. OFAC's guidance allows that, and it is why a hit on BICSA has to be confirmed from the entry's other fields.

The four exchange houses are each recorded as "Other monetary intermediation", and each is named after the people Treasury says own it. Their owners were designated with them, so a query on the surname returns the company and the person together:

• SEYYED ABBAS HOSSEINI PARSA AND PARTNERS QESHM GENERAL PARTNERSHIP COMPANY and Seyyed Abbas Hosseini Parsa.
• BAVI AND PARTNERS EXCHANGE COMPANY and Sadegh Bavi. A third SDN record, BAVI GENERAL TRADING CO L.L.C, was listed earlier under [IRAN-EO13846].
• ABOLHASAN JALALI AND PARTNERS EXCHANGE COMPANY and Abolhasan Jalali. Four SDN primary names contain the string JALALI, one of them a Jalalian; two are from 15 October.
• SOHEIL AND SORUSH NAJAFZADEH AND PARTNERS COMPANY, Soheil Najafzadeh and Sorush Najafzadeh, listed with the alias spellings Suhail and Sorosh.

Spellings drift between the documents. Treasury's release calls Jalali "Abolhassan"; the list says Abolhasan. The release names the Bank Shahr affiliate "Farab Sorough Qeshm Company". The list entry the seven employees are linked to, which was on the SDN List before 15 October, is FARAB SOROUSH AFAGH QESHM COMPANY. Screen against the list, not the press release.

A country filter on Iran misses part of the action. Iraq Development Bank is in Baghdad and the trading company in Hong Kong. Sadegh Bavi has a Dubai address and a passport from Dominica, and Sayyed Ruhollah Razavi, the oil trustee, is listed as a citizen of Dominica and Turkey.

Nor is the "Subject to Secondary Sanctions" line a filter. It appears on 24 of the 27 entries but not on the Iraqi bank, the Hong Kong company or BICSA. Treasury's release still says that certain transactions with the persons designated that day may expose foreign financial institutions to secondary sanctions.

FinCEN issued FIN-2026-Alert008 on 15 October, on Iran's use of religious charities and of khums, the tithe of a fifth of surplus income. Its four red flags describe a charity that raises money but runs no programme or openly backs Iran, and one that takes large donations from an unknown source over a short period and then wires the money to other charities. The other two are staff who avoid currency transaction reports, and a customer who receives charity transfers for no clear reason and cashes them out or sends them on.

None of this is a list. It is transaction monitoring and adverse-media work. FinCEN asks for the key term FIN-2026-IRANCHARITYABUSE in SAR field 2.

1. Find Iraq Development Bank in your payment chains, by BIC IDBQIQBA and LEI as well as by name, including as a correspondent or intermediary. Anything to wind down has until 12:01 a.m. EDT on 30 October.
2. Separate the two BICSAs by legal name, address and BIC country code, and write the reason into the alert disposition.
3. Put 14 November in the calendar if you are a non-US firm with BICSA exposure, and check that no US bank or US person is in the wind-down path.
4. Re-screen exchange and money-service counterparties in the Gulf and Hong Kong. The 25 other entries have no wind-down.
5. Check ownership. Under OFAC's 50 percent rule, an entity owned 50 percent or more by any of the 27 is blocked without being listed.
6. Store which entry matched, with its programme tag. Hosseini Parsa the man and Hosseini Parsa the company are two records.

A match is only useful if it shows the entry behind it. In a batch screening run, each candidate carries the list and the identifiers of the record it hit, so the two BICSAs can be told apart from the file. The source register shows which OFAC lists we load.

This is a report of what OFAC, Treasury, the State Department and FinCEN published on 15 October 2026. It also draws on OFAC FAQs 122 to 124 and 1276, the website of Banco Internacional de Costa Rica, and OFAC's SDN CSV files as downloaded on 20 October. We did not read the text of E.O. 14404. We take no position on the merits of any designation.

These are US measures. Any EU or UK obligation would come from an EU or UK instrument, and we have not checked those. Nothing here says that Banco Internacional de Costa Rica is or is not on any sanctions list, only that it is not the bank OFAC's entry describes. The counts of entries containing a word are counts of primary names in OFAC's SDN CSV file, with alias rows stated separately; they are not counts of people or companies.