The Director of the Office of Foreign Assets Control determined on 24 August 2026 that Section 1(a)(i) of Executive Order 13902 applies to the aviation, digital asset, gold, shipping and technology sectors of the Iranian economy. The determination was made in consultation with the Department of State under 31 CFR § 560.802 and took effect on the day it was signed. Any person determined to operate in one of those sectors is subject to sanctions under that subsection.
Section 1(a)(i) blocks the property of persons determined to operate in an identified sector; the determination names no person and creates a designation ground. Executive Order 13902 reaches further, to persons who knowingly engage in a significant transaction for the sale, supply or transfer to or from Iran of goods or services used in connection with an identified sector, and to persons who materially support anyone designated under it, neither limb requiring a United States nexus. Screening at intake stops resolving on an SDN name match: the test is what a counterparty and its beneficial owners do, and OFAC’s 50 Percent Rule carries blocking through to entities owned in the aggregate 50 percent or more by blocked persons. On the metal, the evidence that answers that test is origin documentation, the refining mark, the assay, the serial numbers and the weight list, together with what the refiner’s own supply-chain screening records under the LBMA Responsible Sourcing Programme and the OECD Due Diligence Guidance. Counterparty and source-of-funds files closed before 24 August 2026 were assembled against a sector list that did not carry gold, and the assessment they record is complete only to that date. Section 2 of the same order authorises the Secretary of the Treasury to prohibit the opening, and to prohibit or impose strict conditions on the maintenance, of a United States correspondent or payable-through account for a foreign financial institution that knowingly conducts or facilitates a significant financial transaction connected with an identified sector, which places the same documentation demand on the settlement bank. When OFAC identified Iran’s financial sector under the same subsection on 8 October 2020, eighteen Iranian banks were designated the same day.
The determination identifies sectors and designates no one; blocking a named person is a separate decision of the Secretary of the Treasury in consultation with the Secretary of State. Licensing, interpretive guidance and any wind-down authorisation for the identified sectors sit with OFAC under 31 CFR Part 560.