MODIFICATIONS MADE TO OFAC’S IRAN RELATED SPECIFIC LICENSING POLICY
October 12, 2026
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As part of OFAC’s August 2026 Operation Economic Outcast (“OEO”) campaign, the agency recently adjusted its licensing policy for Iran-related activities. OEO is described by Treasury as a whole-of-government economic campaign against Iran and its enablers, with the stated goal of pressuring Iran to stop pursuing nuclear and conventional weapons capabilities and obstructing the Strait of Hormuz.
Effective September 10, 2026, OFAC established a “presumed denial” policy for specific license requests involving activities prohibited by the Iranian Transactions and Sanctions Regulations (“ITSR”) and other Iran-related authorities. Under the new policy, Iran-related specific licenses may be issued only when required by law or in exceptional and urgent circumstances, such as risks to life, limb, or environmental safety.
This update follows broader sanctions actions announced as part of OEO on August 24, 2026, which expanded OFAC’s ability to impose sanctions on foreign persons, regardless of where they are located, that operate in or provide services supporting five identified sectors of the Iranian economy: digital assets, technology, gold, aviation, and shipping.
For specific license applications, applicants should provide a written attestation explaining the circumstances that support an exception to the presumed-denial policy. OFAC will review these applications on a case-by-case basis and may consult with the Department of State before deciding whether to grant the requested authorization.
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