OFAC added 78 entries to the SDN List on 24 August; its five Iranian sector determinations added none

On 24 August 2026 the US Treasury opened what it calls Operation Economic Outcast against Iran. One OFAC update carried five documents, and only one of them put names on a list.

The determination is one page. It takes effect on 24 August and says nothing about a wind-down. GL BB does not fill that gap, because it covers only the five suspended authorisations. When the order first named four sectors in January 2020, OFAC gave 90 days to wind down, according to its FAQ 816. None of the 24 August documents sets a period for the five new sectors.

Treasury Secretary Scott Bessent's prepared remarks that day were aimed at the money:

And let me be clear: any entity that facilitates money laundering on behalf of Iran will be removed from the U.S. dollar system. The clock is ticking.

— Scott Bessent, US Treasury Secretary, prepared remarks, 24 August 2026

Treasury's press release says OFAC sanctioned "nearly 60" entities, individuals and vessels. OFAC's list update for the day shows 78 new entries. We sorted them by programme tag. Fifty-seven carry the authorities the press release cites: E.O. 13902, 13382, 13694 and 13224. The other 21 carry the IRAN-EO13846 and IRAN-CON-ARMS-EO tags; the press release says the State Department made its own designations the same day.

The same update deleted 13 entries, al-Nusrah Front and 12 individuals, all under the SDGT programme. OFAC published those deletions in the same notice as the removal of Syria's designation as a State Sponsor of Terrorism. A screening file that counts entries therefore grew by 65, not 78.

The update also lists 31 digital currency addresses. Sixteen sit on four newly listed individuals. Three are members of a cyber group the press release says is directed by Iran's Ministry of Intelligence and Security; the fourth is Almpertos Tsoris, a Greek national the release links to bunkering for vessels carrying Iranian oil. The other 15 were added to the existing entry for Behzad Mesri. In total there are 6 Bitcoin, 20 Ethereum, 4 TRON and 1 USDT address.

The determination works differently. Section 1(a)(i) of E.O. 13902 lets Treasury block any person it determines to operate in a named or determined sector. Section 1(a)(ii) reaches anyone who knowingly engaged in a significant transaction for significant goods or services used in such a sector. Section 2 lets Treasury cut a foreign bank off from US correspondent accounts for a significant financial transaction of that kind. None of this names anyone. A company can do exactly the business the determination describes and still produce no match until Treasury designates it.

The order now covers 12 sectors, not five:

The press release says OFAC "can now sanction any person, regardless of where they are located," that operates in the five sectors. For banks the lever is access to the dollar: the release warns that OFAC can prohibit or restrict a foreign financial institution's US correspondent or payable-through account if it knowingly conducts a significant transaction for a designated person.

The new entries show where the risk sits. Singapore-based Wellbred Capital owns trading arms in the UAE and in Geneva, and the press release says the Geneva company bought La Nivernaise de Raffinage, a cooking-oil refinery in France, in 2024. There is a Shenzhen logistics cluster around the Iranian freight firm BRE Line, four Turkish plastics and petrochemical companies, Indian traders, and a UK-based company that owns the tanker TELA. Under the 50 Percent Rule, companies they own half or more of are blocked too, without appearing on the list.

1. Re-screen customers, vendors and payees against the 24 August update, including alias spellings. A result dated before 24 August does not reflect it.
2. Build a register of counterparties that operate in any of the 12 sectors. That register, not the SDN match report, shows the exposure the determination creates.
3. Check ownership for every counterparty linked to a new entry, because the 50 Percent Rule blocks subsidiaries the list does not show.
4. For counterparties in a determined sector, record what they do, who owns them and whom they trade with, with dates and sources. Ambiguous cases go to counsel.
5. Check wallet histories against the 31 listed addresses.
6. Close anything still relying on a suspended authorisation. GL BB expired on 8 September; OFAC's notice says later activity needs a specific licence.

In his remarks Bessent said every country "has a defined timeline to shut down activities we have identified". None of the Treasury releases we opened publishes those timelines.

Update, 1 October 2026: Treasury has since issued further actions under the same name. On 28 August FinCEN proposed a rule to cut Banque Misr UAE off from correspondent banking with US financial institutions. On 10 September OFAC targeted networks supporting Kata'ib Hizballah and Hizballah. On 14 September it designated Russia's VTB Bank for Iran-related sanctions evasion, including correspondent relationships with sanctioned Iranian banks.

The 24 August entries were screenable here the same day, Washington time, and continuous monitoring rechecks existing counterparties against new entries without a manual import. A sector determination has no entry to load, so the exposure work above stays with the compliance team.

The counts are of SDN entries on OFAC's 24 August page, not of companies or ships still trading; the split between Treasury and State rests on programme tags and the press release, not on a list of who designated whom.

These are US measures. Any EU or UK obligation comes from an EU or UK instrument you have to check separately, and we have not checked whether E.O. 13902 falls under the annex of the EU Blocking Regulation.

Press reports quoted Bessent answering a question about Chinese banks at the launch. That remark is not in the press release or the prepared remarks we opened, so we do not quote it. We also did not check OFAC FAQs issued after 24 August for wind-down guidance on the five sectors. Nothing here is legal advice.