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ARTICLE · 15 AUGUST 2025

OFAC Expands Sanctions On Iran's Shadow Banking Network And Surveillance Infrastructure

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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On August 7, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") announced a new round of sanctions targeting 18 entities and individuals...

United StatesInternational Law
Jonathan Cross
Jonathan Cross
Christopher Boyd
Christopher Boyd
Yash Dattani
Yash Dattani
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Overview

On August 7, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") announced a new round of sanctions targeting 18 entities and individuals involved in Iran's efforts to circumvent U.S. sanctions programs and fund its surveillance and military infrastructure. The August 7 designations include offshore banks, financial institutions, and technology firms that OFAC alleges are central to Iran's shadow banking infrastructure. We last reported on OFAC action targeting Iran's shadow banking network on June 18, 2025.

This marks the third major action in 2025 against Iran's shadow banking system, following OFAC's June 6 and July 9 designations targeting oil brokers and front companies linked to the Islamic Revolutionary Guard Corps ("IRGC"). Similar to the previous actions, the latest action is taken pursuant to Executive Order 13902 and in furtherance of National Security Presidential Memorandum 2, which directs a campaign of

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