This edition of Sanctions Watch covers U.S. sanctions and trade-enforcement actions announced between July 27 and August 7, 2026. Every item below is drawn from public government records linked in the text.
The Treasury Department spent the past two weeks tightening an already severe squeeze on Iran’s remaining financial arteries — from crypto exchanges and Dubai front companies to an alleged maritime “insurance” racket in the Strait of Hormuz — while opening a new sanctions front against Cuba’s military procurement network. The same period brought reminders that the sanctions machine turns in both directions: Treasury removed 84 stale entries in its modernization drive and quietly delisted an Iraqi airline it had blacklisted in 2024. Here are the actions that mattered, and why.
1. Treasury moves against Iran’s crypto lifelines and shadow banks
In the week’s most consequential action, the Office of Foreign Assets Control (OFAC) on August 7 announced two coordinated designation packages aimed at what it describes as the digital-asset and “shadow banking” infrastructure keeping the Iranian regime liquid. According to Treasury’s releases — “Treasury Sanctions Crypto Exchanges Funding Iran’s IRGC and Enabling Illicit Finance” and “Treasury Dismantles Iranian Regime’s Global Clandestine Currency Networks” — the targets include the Shelbit Exchange, operated through a Georgia-registered company by Siavash Kayvanpour, and Tehran-based Aban Tether. Treasury records state that digital-currency addresses belonging to the Islamic Revolutionary Guard Corps sent more than $1 million in digital assets to Shelbit addresses, that more than $2 million flowed back to IRGC addresses, and that Kayvanpour-controlled addresses sent over $2 million to the previously designated Iranian exchange Nobitex. Aban Tether, per the release, processed millions of dollars in transactions involving designated platforms including Nobitex, Wallex, Bitpin, and Ramzinex.
The second package targets the exchange-house network allegedly serving Iran’s Shahr Bank, including Dubai-based Titan Exchange — which Treasury says held tens of millions of dollars on the bank’s behalf as of early 2026 — and Alps International, which the department says enabled hundreds of millions of dollars in transfers this year through invoice-generating shell companies in Hong Kong and Singapore, among them Oviedo Overseas, Cailafang Pte. Ltd., Blue Dash, and Gleaming HK. Treasury called it OFAC’s eighth action of 2026 against Iran’s shadow-banking apparatus, and the State Department’s Rewards for Justice program is offering up to $15 million for information on IRGC financial mechanisms. Notably, Treasury’s records indicate the UAE’s Virtual Assets Regulatory Authority took enforcement action against Shelbit-linked firms in January 2025 and again in July 2026 — yet the operation continued, a data point compliance officers in the Gulf should sit with.
2. The Strait of Hormuz “insurance” racket
On July 29, Treasury designated two firms it says are central to an IRGC-backed scheme that forces commercial vessels to buy mandatory maritime “insurance” to transit the Strait of Hormuz — coverage against risks, such as seizure, that Treasury notes are “overwhelmingly created by Iran itself.” According to the release, the Persian Gulf Marine Insurance Company was established by Iran’s state insurance regulator and brokers policies approved by the previously designated Persian Gulf Strait Authority, while HormuzSafe Marine Services Authority, developed by Iran’s Ministry of Economy, accepts payment in Bitcoin and other digital assets to sidestep Western sanctions. “With its economy in freefall and inflation in the triple digits, the regime is desperate for cash,” Treasury Secretary Scott Bessent said in the release.
The same action added ten shipping entities in Hong Kong, the Marshall Islands, and Iran, plus eight tankers, to the SDN List for moving Iranian crude and petroleum products — part of what OFAC’s records describe as a shadow fleet that has now seen more than 100 vessels sanctioned since the start of the year. For shipowners, charterers, and P&I clubs, the compliance implication is stark: payments to Iranian-linked “transit services” in the Strait, in any currency or coin, now carry direct designation risk.
3. Mahan Air’s global sales network, from Shanghai to Srinagar
On July 30, OFAC designated six entities and individuals in China, India, Russia, and Iran tied to Mahan Air, the sanctioned Iranian carrier Treasury describes as a critical conduit for IRGC movement of weapons, operatives, and equipment. The designations reach the airline’s general sales agents: Shanghai Wings International Logistics, which Treasury says coordinated electronics shipments from China to Iran; its managing director Tang Xin, who also half-owns the likewise-designated Shanghai Elite International Travel; Skiez Travels and Logistics, Mahan’s agent in India; and Moscow-based Air Cargo Pro. OFAC’s SDN entries list Skiez at addresses in Srinagar, Jammu and Kashmir, and New Delhi’s Defence Colony — a striking footprint for a company allegedly servicing a U.S.- and EU-sanctioned airline from Indian soil.
The action also swept in DadeNegar Startup Studio, a Tehran software firm Treasury describes as an IRGC-affiliated front that supported Iran’s “kinetic targeting during the ongoing conflict.” The message to aviation-services firms in friendly jurisdictions — India above all — is that general sales agency work for Mahan Air is no longer treated as arm’s-length commerce.
4. A new sanctions front: Cuba’s arms importers
On August 6, OFAC added five Cuban state enterprises and six individuals to the SDN List under Executive Order 14404, the May 2026 order targeting the Cuban regime. A companion State Department fact sheet says the action targets procurement of military equipment for Cuba’s Ministry of the Revolutionary Armed Forces, and follows State’s July 20 report on Havana’s deepening security partnerships with Russia and China. The designated entities include TECNOTEX, Technoimport, the Yuri Gagarin Military Industrial Enterprise, and the Union of Military Industry.
Two details stand out in the public records. First, the individual designations include Cuban nationals listed as based in Moscow and Beijing — suggesting Washington is mapping Havana’s forward-deployed procurement staff, not just its home-island bureaucracy. Second, OFAC updated existing Global Magnitsky entries for senior armed-forces figures, including Álvaro López Miera, to add the new Cuba authority — a sign the administration intends EO 14404 to become the workhorse designation tool for Cuba policy.
5. Venezuela: the Citgo shield gets another extension
On August 3, OFAC issued Venezuela-related General License 5Y, authorizing certain transactions related to the PdVSA 2020 8.5 percent bond only “on or after September 17, 2026,” alongside an amended FAQ 595. The 5-series license has been renewed repeatedly since 2019, and market participants have long understood the mechanism: the 2020 bond is collateralized by a controlling stake in Citgo’s U.S. parent, and each renewal defers the date on which bondholders could move against that collateral.
The six-week extension window is shorter than some past renewals, which bond-market observers may read as a signal that the administration is keeping its Venezuela options deliberately short-leashed while broader policy — including the amended Venezuela general license issued in late July — remains in flux. Holders of defaulted PdVSA paper, and the parties to the long-running Delaware proceedings over Citgo’s ownership, will be watching the September date closely.
6. Fly Baghdad comes off the list
In a quieter but noteworthy move, OFAC on August 5 removed Fly Baghdad Airlines and two of its Boeing 737s from the SDN List. The Iraqi carrier was designated in January 2024; the now-deleted entries carried an explicit linkage to the IRGC-Qods Force. The same action updated — but did not remove — the entry for Basheer al-Shabbani, the airline’s chief executive at the time of designation, whose listing now ties him directly to the IRGC-Qods Force rather than to the airline.
Delistings of this kind are rarely explained in public, and this one arrived barely five weeks after OFAC launched its new online Reconsideration Portal for delisting petitions. Whether Fly Baghdad’s removal came through that portal, through Iraqi government advocacy, or through changed ownership or behavior is not stated in the public record — a gap worth probing, given the airline’s documented history and the continued designation of its former chief.
7. Sanctions modernization, round two: 84 names off the books
On July 27, Treasury announced the second major action in the sanctions-modernization initiative Secretary Bessent unveiled in May: 84 individuals and entities removed, identifying information improved on 22 entries, and 18 sets of duplicate listings resolved. Those removed, per the release, include deceased individuals, defunct entities, and decades-old targets that lack the identifiers modern screening systems need. The department framed the effort as measuring sanctions “in terms of effect, impact, and benefit — not just based on the number of names Treasury places on a list.”
For banks and screening vendors, the practical effect is a cleaner list and marginally lower false-positive burden. The more consequential piece is structural: the June 29 Reconsideration Portal creates, for the first time, a standardized front door for delisting petitions — and, as the Fly Baghdad episode may suggest, that door is now in active use.
8. Commerce shifts suppressor exports to the Commerce Control List
On the trade side, the Commerce Department’s Bureau of Industry and Security announced in late July that as of November 20, 2026, exports of certain silencers, mufflers, and sound suppressors will move from the State Department’s U.S. Munitions List to BIS’s Export Administration Regulations, joining the Commerce Control List with license requirements for certain exports, reexports, and technology releases to foreign persons. Under Secretary Jeffrey Kessler called it “a common-sense move that alleviates the compliance burden on America’s proud firearms industry, while continuing to protect national security.”
The rule extends to suppressors the same treatment firearms received under earlier reform rounds, including access to existing license exceptions. Exporters should note the practical effect: jurisdiction shifts from State’s ITAR regime to Commerce licensing, but controls do not disappear — and the transfer takes effect in November, giving compliance teams a defined runway to reclassify products and update licenses.
What warrants a closer look
Several threads from this fortnight merit deeper TIJ reporting. Skiez Travels’ corporate record in India — a company registered in Jammu and Kashmir in 2020, per its SDN entry, now designated as Mahan Air’s Indian sales agent — raises questions about how the arrangement operated in plain sight and what Indian regulators knew. Tang Xin’s twin Shanghai companies, with unified social credit codes now on the public record, invite a registry-level reconstruction of Mahan’s China logistics. The Shelbit case poses an uncomfortable question for Dubai: how did an exchange survive two enforcement actions by the UAE’s own virtual-asset regulator while allegedly moving IRGC funds? HormuzSafe’s Bitcoin rails offer a rare, traceable on-chain window into an IRGC-linked revenue scheme. And the Fly Baghdad delisting is a test case for how, and for whom, OFAC’s new Reconsideration Portal works — a process story with real accountability stakes.
A note on sourcing: every designation and removal described above reflects allegations and determinations by the U.S. Treasury and State Departments as stated in the linked public records, not judicial findings. Designated parties may petition OFAC for removal, and none of the parties named has been contacted by TIJ for comment for this digest; we will publish substantive responses from any named party. Records cited: OFAC Recent Actions, U.S. Treasury press releases, the U.S. State Department, and the Bureau of Industry and Security.