Print PDF

Iran Sanctions Enforcement: The Economic Fury Campaign in Review

May 2026

The United States government has dramatically escalated sanctions pressure against Iran since early 2025, culminating in an unprecedented campaign — designated “Economic Fury” — that has produced more than 1,000 designations of Iran-related persons, vessels, and aircraft in approximately fifteen months. Below is a comprehensive discussion of recent actions taken by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the legal authorities invoked, the categories of actors targeted, and the general licenses issued.

The pace, breadth, and geographic reach of these actions are historically significant. OFAC has simultaneously targeted Iran’s petroleum export infrastructure (“shadow fleet”), its shadow banking system (exchange houses and “rahbar” networks[1]), its ballistic missile and unmanned aerial vehicle (UAV) procurement networks, Chinese “teapot” refineries purchasing Iranian crude, and multilateral financing structures used to transfer value to Hizballah and the Islamic Revolutionary Guard Corps (IRGC). Companies operating in energy trading, maritime logistics, financial services, and commodities must reassess their screening programs, counterparty due diligence procedures, and internal controls in light of these developments.

National Security Presidential Memorandum 2 (NSPM-2)

The foundational policy instrument driving the current campaign is National Security Presidential Memorandum 2 (NSPM-2), issued by President Trump upon taking office in 2025. NSPM-2 formally reinstated the “maximum pressure” strategy against Iran that characterized the first Trump Administration (2018–2021) and significantly expanded its scope and ambition. NSPM-2 directs multiple U.S. government agencies to take coordinated action across several fronts, including Treasury/OFAC to evaluate and potentially implement a “know-your-customer’s-customer” (KYCC) standard for Iran-related transactions, to modify or rescind existing general licenses and guidance that provides any economic relief to Iran or its proxies, and to conduct an aggressive and continuous campaign of designations targeting shadow banking and sanctions evasion networks; State Department to modify or rescind existing sanctions waivers and to work with key allies to complete the “snapback” of international sanctions on Iran through the UN Security Council mechanism; Commerce Department to conduct a robust export control enforcement campaign to restrict the flow of technology and components used by Iran for military purposes, including by addressing transshipment and diversion networks; and Justice Department to pursue all available legal steps to investigate, disrupt, and prosecute Iranian sanctions evasion, including seeking impoundment of Iranian oil cargoes and pursuing Iranian assets to satisfy terrorism judgments.

NSPM-2 represents a comprehensive, whole-of-government approach that goes beyond the designation of individual entities and seeks structural disruption of Iran’s ability to generate and use oil revenues. The directive does not itself change existing sanctions law, but it has been implemented with exceptional speed and intensity.

Reimposition of UN Sanctions and Snapback

A separate but closely related development occurred on September 27, 2025, when UN sanctions and restrictions on Iran were reimposed as a direct result of Iran’s “significant non-performance” of its nuclear commitments under the Joint Comprehensive Plan of Action (JCPOA). The U.S. government pursued this snapback through its role as a JCPOA participant, and the reimposition of UN sanctions has provided additional legal authority and international legitimacy for OFAC’s nonproliferation designations. OFAC has explicitly characterized successive rounds of its WMD-proliferation designations as actions “in support of” the September 2025 snapback.

Principal Executive Orders Invoked

The Economic Fury campaign draws on a suite of pre-existing executive order authorities, each targeting a different dimension of Iran’s sanctions evasion architecture:

Shadow Fleet Targeting

Iran’s shadow fleet of tankers constitutes the primary mechanism by which Iranian petroleum reaches foreign markets, principally in Asia. OFAC has made sustained disruption of this fleet a central pillar of the Economic Fury campaign, designating more than 180 vessels responsible for shipping Iranian petroleum and petroleum products since the campaign’s launch. Key actions include:

Shadow Banking: Exchange Houses and Rahbar Networks

Parallel to the shadow fleet campaign, OFAC has systematically dismantled the financial infrastructure that allows Iran to convert oil revenues into usable currencies and access the international banking system. Because Iran primarily settles its oil sales in Chinese yuan, specialized exchange houses play a critical role in currency conversion for the Iranian military and its proxies and partners.

Ballistic Missile and UAV Procurement Networks

A series of nonproliferation-focused designation rounds have targeted Iran’s efforts to reconstitute its ballistic missile production capacity and expand Shahed-series UAV capabilities, which Iran has deployed against regional energy infrastructure and U.S. allies. Key actions include:

These nonproliferation actions are explicitly linked to the September 2025 reimposition of UN sanctions and signal that OFAC views its missile and UAV-related designations as part of a coordinated multilateral pressure strategy, not simply a unilateral U.S. tool.

General Licenses and Wind-Down Authorizations[2]

In conjunction with several designation rounds, OFAC has issued general licenses to authorize limited categories of transactions that would otherwise be prohibited:

The wind-down licenses are narrow in scope and do not authorize new transactions, investments, or payments beyond what is strictly necessary to conclude existing arrangements.

Key Takeaways

The Economic Fury campaign represents the most intensive and operationally sophisticated Iran sanctions campaign in U.S. history. Its simultaneous targeting of petroleum logistics, shadow banking, weapons procurement networks, and foreign end-users across multiple jurisdictions reflects a comprehensive strategy to sever Iran’s access to the international financial system at every point in the value chain. The campaign shows no signs of abating in the near term and will continue to generate new designations, general licenses, and enforcement guidance at a rapid pace.

Treat the 50% Rule as a primary screening obligation. Any entities owned, directly or indirectly, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked. The rapid expansion of the SDN List means the universe of constructively blocked entities is substantially larger than the published list. Name-matching alone is insufficient. Beneficial ownership analysis – tracing corporate structures through offshore jurisdictions commonly used by Iranian-linked networks – must be a standard component of counterparty onboarding and periodic review.

Apply heightened due diligence to UAE, Turkey, and Hong Kong counterparties. These three jurisdictions appear in virtually every major Economic Fury action as registration hubs for exchange house front companies, shadow fleet managers, and procurement intermediaries. Counterparties registered or operating primarily in these jurisdictions, particularly in petroleum trading, maritime logistics, and financial services, should be treated as presumptively elevated risk.

Reassess secondary sanctions exposure if your business touches Iranian petroleum. The designation of Hengli Petrochemical removed any ambiguity about OFAC's willingness to designate major foreign industrial enterprises. Companies purchasing Iranian crude, servicing shadow fleet vessels, or maintaining financial relationships with Iranian exchange houses or rahbar networks face real designation risk regardless of whether they have any U.S. nexus in the underlying transaction.

Maritime participants should audit the full service chain, not just vessel ownership. OFAC has explicitly targeted ship managers, vessel provisioners, technical managers, and insurers servicing designated vessels, not just their owners. Port operators, P&I clubs, bunker suppliers, and cargo underwriters should confirm that their screening extends across the full chain of maritime services and that their vessel diligence accounts for AIS anomalies, frequent flag changes, and multi-layer offshore ownership structures.

Begin developing KYCC procedures now. NSPM-2 directs Treasury to evaluate a formal know-your-customer's-customer standard for Iran-related transactions. No rule has been issued yet, but institutions that wait for a formal mandate before updating their diligence frameworks will be behind the curve. Proactive implementation, particularly for correspondent banking, trade finance, and foreign exchange in high-risk corridors, is sound practice and a mitigating factor in any future enforcement context.

Document every compliance decision contemporaneously. As always, the quality of recordkeeping is a primary determinant of enforcement exposure. Every screening decision, including decisions not to escalate, should be documented in real time, with clear notation of the sources consulted, steps taken, and reasoning applied. This is especially important for transactions involving general license reliance, high-risk jurisdiction counterparties, or commodity types associated with Iranian export activity.

[1] A “rahbar” company is an Iranian entrusted entity established by sanctioned Iranian banks to manage international transactions, acting as a key part of Iran's “shadow banking” network. These companies (meaning “leader” in Persian) use webs of front companies to facilitate trade payments and evade sanctions. U.S. Department of the Treasury, “Secretary Bessent Announces Sanctions Against Architects of Iran’s Brutal Crackdown on Peaceful Protests,” Jan. 15, 2026, https://home.treasury.gov/news/press-releases/sb0364.

[2] https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions