OFAC Announces New Round of Sanctions Targeting Iran’s Energy Sector

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On the heels of the Trump administration’s June strikes on key nuclear sites in Tehran, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions on July 30, 2025, targeting Iran’s petroleum and shipping sectors.  Described by OFAC in its press release as “massive action,” the designations impact over 115 Iran-linked individuals, entities and vessels. 

New Designations

OFAC’s sanctions focus heavily on the shipping network controlled by Mohammad Hossein Shamkhani, the son of Ali Shamkhani, who is publicly reported as an adviser to Supreme Leader Ayatollah Ali Khamenei.  The designations include:

  • Over 50 individuals and entities and more than 50 vessels that OFAC asserts are tied to Mohammad Hossein Shamkhani, designated under Executive Order 13902; and
  • 20 additional entities, including a terminal operator, vessel management companies and wholesale buyers of fuel, and 10 additional vessels, designated concurrently by the Department of State under Executive Orders 13846 and 13902, for their involvement in the trade and transport of Iranian crude oil, petroleum and petrochemical products.

General License R – Limited Wind-Down and Safety Activities Authorized

OFAC also issued General License R, which authorizes certain limited transactions involving designated persons or vessels for safety and environmental purposes.  These include:

  • Docking, anchoring, or safe passage;
  • Crew health and safety measures;
  • Emergency repairs and environmental mitigation;
  • Delivery and offloading of cargo loaded prior to July 30, 2025 (excluding those involving Russia or Iran);
  • Vessel-related services such as crewing, flagging, bunkering, piloting, and insurance.

Importantly, the General License applies only to the vessels identified in the Annex of General License R “Authorizing Limited Safety and Environmental Transactions and the Offloading of Cargo Involving Certain Persons or Vessels Blocked on July 30, 2025,” is only valid through October 1, 2025, and does not extend to many of the other persons and entities designated by OFAC on July 30 who are immediately subject to full blocking sanctions absent specific authorization from OFAC. The full text of the license and annex is available here

Conclusion

Persons and entities located in the U.S. and abroad who are engaged in global shipping or connected to Iran’s energy sector should assess their exposure to the named individuals, entities, and vessels, particularly given the risk of both primary and secondary sanctions exposure.  For any persons subject to the wind-down authorizations in General License R, any involvement with cargo loaded near the July 30 cut-off date, or planned activity through October 1, 2025, should be carefully reviewed for compliance with the terms of that license. 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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