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meta_id 3107579

pc nid 92278 Apr 28, 2026 pdonofrio@vixio.com US Track 2 U.S. Department of the Treasury horizon scanning
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U.S. Department of the Treasury Designates 35 Entities and Individuals Facilitating Iran's Shadow Banking System

On April 28, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated 35 entities and individuals operating within Iran's shadow banking architecture as part of the Economic Fury campaign. These designations target networks that facilitate the movement of tens of billions of dollars through sanctions evasion and support Iran's sponsorship of terrorism. The shadow banking system enables Iran's armed forces, including the Islamic Revolutionary Guard Corps (IRGC), to access the international financial system to receive payments for illicit oil sales, purchase sensitive components for missiles and weapons systems, and transfer funds to Iran's terrorist proxies. The designations specifically target rahbar companies—private firms that manage thousands of overseas shell companies used to execute payments for Iranian imports and exports. These companies coordinate with Iranian exchange houses and front companies across multiple jurisdictions to facilitate sanctioned trade on behalf of the IRGC, Iran's Armed Forces General Staff, the National Iranian Oil Company (NIOC), and other sanctioned entities. The action was taken pursuant to Executive Order 13902, targeting persons operating in Iran's financial sector, and Executive Order 13224, a counterterrorism authority. It builds on OFAC's January 15, 2026 action targeting the rahbar networks of Bank Melli and Bank-e Shahr. Since February 2025, OFAC has sanctioned approximately 1,000 Iran-related persons, vessels, and aircraft as part of this maximum economic pressure campaign. All property and interests in property of the designated persons in the United States or in the possession or control of U.S. persons are blocked. Unless authorized by OFAC or exempt, U.S. persons are prohibited from engaging in transactions involving any property or interests of blocked persons. Violations may result in civil or criminal penalties. Non-U.S. persons are also prohibited from causing U.S. persons to violate sanctions or engaging in conduct that evades U.S. sanctions.

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US Office of Foreign Assets Control Designates Individuals and Entities Facilitating Iran's Shadow Banking System

On April 28, 2026, the US Office of Foreign Assets Control (OFAC) designated 35 individuals and entities operating within Iran's shadow banking system as part of  its "Economic Fury" initiative. The designations target networks that facilitate the movement of tens of billions of dollars through sanctions evasion and support Iran's sponsorship of terrorism. The designations specifically target "rahbar" companies — private firms that manage thousands of overseas shell companies used to execute payments for Iranian imports and exports. According to OFAC , these companies coordinate with Iranian exchange houses and front companies across multiple jurisdictions to facilitate sanctioned trade on behalf of the Iranian Revolutionary Guard Corps (IRGC), Iran's Armed Forces General Staff, the National Iranian Oil Company (NIOC) and other sanctioned entities. The action was taken pursuant to Executive Order 13902 , targeting Iran's financial sector, and Executive Order 13224 , a counterterrorism authority. All property and interests in property of the designated individuals and entities are blocked, and US individuals and entities are generally prohibited from conducting transactions with them unless expressly authorized by OFAC.