After the reimposition of United Nations “snapback” sanctions on Iran on September 27, 2025, in connection with unfulfilled Iranian nuclear program control and inspection commitments, Washington moved quickly to announce the imposition of a set of unilateral sanctions to support the snapback UN sanctions for “significant non-performance” of Iran’s nuclear commitments on October 1.
Washington then released a major new package of unilateral Iran sanctions on October 9 focused on reducing income generated by the Iranian oil and petrochemical sector. That step was designed to demonstrate that the U.S. policy of “maximum pressure” on Iran was alive and well despite the broad shutdown of most non-essential U.S Government functions which started on October 1 and ran until November 12.
The U.S. Treasury Department (Office of Foreign Assets Control – OFAC) announced on November 12 sanctions against 32 individuals and entities spanning Iran, UAE, Turkey, China, Hong Kong, India, Germany, and Ukraine for their involvement in procurement networks supporting Iran’s ballistic missile and unmanned aerial vehicle programs.
Yet again, on December 18, the U.S. imposed sanctions on 29 vessels and their respective management firms identified as part of Iran’s “shadow fleet,” which Washington believes transports Iranian crude and petroleum products — normally utilizing deceptive practices to evade sanctions. The action targeted ships and companies involved in carrying Iran’s oil abroad to reduce Iran’s petroleum revenue.
Different targets in 2026
This year, in view of the massive anti-regime street demonstrations in Iranian cities seen in January, Washington’s Iran sanctions focus has had to shift somewhat, with the threat of armed conflict between the two countries remaining real. It was a commonly held belief in Iran that the totality of western sanctions programs, led forcefully by the United States, had caused major economic disruptions and created shortages of essential consumer products, contributing substantially to the unrest in January.
In January, U.S. President Donald Trump announced new tariffs of 25 percent on countries that continue to trade with Iran, specifically pressuring its largest trading partners like China. However, while Trump stated the tariffs are active, no formal legal documentation from the White House or the U.S. Trade Representative (USTR) has been released to clarify how they will be enforced. There had been a mention of February 1 as the target date. Trump is continuing to make threats but none of the standard documents needed to implement these threats have been published.
The U.S. Treasury’s OFAC unit announced on January 30 focused sanctions against specific Iranian officials responsible for the regime’s brutal crackdown on its own people. It had announced a smaller sanctions package against Iran’s “shadow fleet” on January 23 and an initial, but smaller package targeting Iranian regime supporters on January 15.
Among the officials sanctioned was Interior Minister Eskandar Momeni Kalagari, who oversees the so-called Law Enforcement Forces of the Islamic Republic (LEF), a key entity responsible for the mass killings of thousands of peaceful protestors, in addition to arrests and forced disappearances.
OFAC also designated Babak Morteza Zanjani, a criminal Iranian investor who previously embezzled billions of dollars in Iranian oil revenue that was never fully recovered. Freed from imprisonment in order to launder money for the regime, Zanjani has provided financial backing for major projects that support the Islamic Revolutionary Guard Corps (IRGC) and the Iranian regime more broadly.
Additionally, for the first time, OFAC designated two digital asset exchanges linked to Zanjani that have processed large volumes of funds associated with IRGC-linked counterparties. This will mark OFAC’s first designation of a digital asset exchange for operating in the financial sector of the Iranian economy.
“Rather than build a prosperous Iran, the regime has chosen to squander what remains of the nation’s oil revenues on nuclear weapons development, missiles, and terrorist proxies around the world,” noted Secretary of the Treasury Scott Bessent when approving the new sanctions.
Bessent also stated, “President Trump stands with the people of Iran and has ordered Treasury to sanction members of the regime. Treasury will continue to target Iranian networks and corrupt elites that enrich themselves at the expense of the Iranian people. This includes the regime’s attempts to exploit digital assets to evade sanctions and finance cybercriminal operations. Like rats on a sinking ship, the regime is frantically wiring funds stolen from Iranian families to banks and financial institutions around the world. Rest assured, Treasury will act.”
OFAC’s actions are being taken pursuant to Executive Order (E.O.) 13553, which authorizes sanctions on certain persons with respect to serious human rights abuses by the Government of Iran; E.O. 13224, as amended, a counterterrorism authority; and E.O. 13902, which targets Iran’s financial, petroleum, and petrochemical sectors. In 2025, OFAC sanctioned more than 875 people, vessels, and aircraft as part of this campaign.
Security forces in OFAC’s crosshairs
The IRGC Intelligence Organization, under the leadership of Majid Khademi, has played an instrumental role in violently suppressing protests. The IRGC Intelligence Organization has underpinned the Iranian security forces’ national campaign of mass violence, arbitrary detentions, and intimidation aimed at crushing Iran’s protest moment.
Ghorban Mohammad Valizadeh serves as commander of the IRGC’s Seyyad al-Shohada Corps in Tehran province. Tehran province has experienced some of the deadliest violence since the protests began, with children among the dead.
Hossein Zare Kamali is the IRGC commander of Hamadan province, where the families of those killed in protests have been forced to bury their dead without funerals and where security forces have sought to ransom the bodies of dead protestors.
Hamid Damghani is the IRGC commander of Gilan province, where some of the regime’s worst atrocities have occurred.
Mehdi Hajian is the commander of the LEF for Kermanshah province, where some of the earliest regime-orchestrated violence against protestors occurred. Under Hajian’s command, Kermanshah’s LEF has worked with the IRGC and Basij Resistance Force to conduct the regime’s crackdown, which has included mass killings and sexual violence against protestors.
Interior Minister Eskandar Momeni Kalagari is being designated pursuant to E.O. 13553 for being an official of the Government of Iran (including members of paramilitary organizations) who is responsible for or complicit in, or responsible for ordering, controlling, or otherwise directing, the commission of serious human rights abuses against persons in Iran or Iranian citizens or residents.
Majid Khademi, Ghorban Mohammad Valizadeh, Hossein Zare Kamali, and Hamid Damghani are being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the Islamic Revolutionary Guard Corps. Mehdi Hajian is being designated pursuant to E.O. 13553 for having acted or purported to act for or on behalf of, directly or indirectly, the Law Enforcement Forces of the Islamic Republic of Iran.
Operators of digital assets used to evade sanctions
Babak Morteza Zanjani (Zanjani), mentioned above, is an Iranian businessman and experienced sanctions evader. He is active in multiple fields including hospitality, transportation, technology, financial services, and oil exports. In March 2016, Zanjani was sentenced to death in Iran for embezzling billions of dollars from Iran’s National Oil Company, funds that rightfully belong to the Iranian people. His sentence was commuted in 2024, and in April 2025, Zanjani served as a financial backer of one of Iran’s largest railway investments in history.
Zedcex Exchange, Ltd. (Zedcex) and Zedxion Exchange, Ltd. (Zedxion) are two UK-registered digital asset exchanges with connections to Zanjani. Since its registration in August 2022, Zedcex has processed over $94 billion in transactions. When Zedxion was registered in May 2021, it initially listed Zanjani as its director. Multiple Zedcex and Zedxion-attributed addresses have processed funds for wallets known to be linked to the IRGC.
OFAC has designated Babak Morteza Zanjani, Zedcex Exchange, Ltd., and Zedxion Exchange, Ltd. pursuant to E.O. 13902 for operating in the financial sector of the economy of Iran. Additionally, OFAC also designated Zedcex Exchange, Ltd. and Zedxion Exchange, Ltd. pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC.
Support for internet freedom
The United States supports the Iranian people in their protests against the corrupt and repressive regime in Tehran. As Iran’s violent crackdown and internet blackout continue, Treasury encourages relevant parties to keep in mind the longstanding general license, often referred to as GL D-2, that facilitates the Iranian people’s access to the internet and is included in the Code of Federal Regulations at 31 CFR § 560.540. OFAC notes that the U.S. Government stands with the Iranian people and will continue to expedite related requests for guidance and, as necessary and appropriate, specific licenses.
The standard OFAC procedures freeze assets of sanctioned officials
As a result of the January 30 action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.
Unless authorized by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.
Additional “shadow fleet” and petrochemical sanctions announced on February 6
On February 6, the same day U.S. and Iranian negotiators were meeting in Oman, the Department of State identified and sanctioned 14 shadow fleet vessels as property of entities involved in the transportation of Iranian petroleum, petroleum products, and petrochemical products. In addition the Department of State sanctioned 15 entities that have traded in Iranian-origin crude oil, petroleum products, or petrochemical products, as well as two associated individuals. Companies and entities sanctioned were from a wide range of countries including Turkiye (by far the largest group of firms), the Seychelles, Panama, Barbados, UAE, San Marino and India.